INGAA STRONGLY DISPUTES FERC'S CHARACTERIZATION OF BURDENS THAT PIPELINES FACE WITH NEW REPORTING REQUIREMENTS; NGSA WEIGHS IN ON NEED FOR STANDARDS FOR GAS STORAGE REPORTS

摘要

On 2/22/11 the Interstate Natural Gas Association of America (INGAA) formally requested rehearing and clarification of FERC Order No. 710-B (RM07-9), Revisions to Forms, Statements, and Reporting Requirements for Natural Gas Pipelines, issued 1/20/11. INGAA had previously argued in its comments that the proposal to require pipelines to separately report fuel use in Form 2 on pages 521a and 521b for transactions that use discounted or negotiated rates would require pipelines to track fuel use by individual contract. Because pipelines operate on an integrated basis, requiring them to separate out the amount of fuel consumed as part of discounted or negotiated rate agreements, regardless of whether the pipeline is waiving or discounting the fuel component of its rates under such agreements, would be unnecessarily burdensome and would produce data that is neither useful nor reliable.1