American Gas Association Clarifies its Position on Reporting of Backhaul Throughput by Interstate Pipelines

摘要

The American Gas Association (AGA) recently submitted to FERC follow-up reply comments in response to the reply comments of the Interstate Natural Gas Association of America (INGAA) filed on September 16 with respect to proposed Revisions to Forms, Statements, and Reporting Requirements for Natural Gas Pipelines (RM07-9). AGA has argued that the Commission should consider requiring the separate reporting of forwardhaul and backhaul throughput volumes associated with the specific fuel data reported on pages 521 a and 521 b of Form No. 2. INGAA contends that the separate reporting of backhaul fuel volumes is unwarranted. In INGAA's view, the Columbia Gulf proceeding (2010) cited by AGA does not support a generic requirement that all pipelines provide backhaul information, that the Columbia Gulf decision arose out of facts unique to the case, and that on many pipelines there may be no specific or designated transportation path for many services. The latter situation makes reporting problematic if not impossible, in the view of the interstate pipelines.