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As a matter of law, companies that perform only a gathering function, whether they are independent or affiliated with an interstate pipeline, are not natural gas companies because they neither transport natural gas in interstate commerce nor sell [...] Read More
The Commission must apply its expertise and exercise discretion in applying securities and commodities law precedent to the industries it regulates. The Commission should explicitly adopt the elements and limitations applicable to the SEC鈥檚 [...] Read More
91茄子 requests that the Commission determine that 91茄子鈥檚 letter does not constitute a prohibited off-the-record-communication in the circumstances. 91茄子 does not object to placing its November 2 letter in the non-decisional file in the above [...] Read More
Studies by the 91茄子 Foundation as well as the National Petroleum Council (鈥淣PC鈥�) confirm the need for very substantial new storage (up to 700Bcf) over the next two decades, at a cost in the range of $4 billion to $6 billion. See infra at 4. The [...] Read More
Pursuant to the Notice of Proposed Rulemaking issued September 21, 2006, the 91茄子 (鈥�91茄子鈥�) submits the following comments on the Commission鈥檚 proposals to amend its regulations pertaining to critical [...] Read More
Pursuant to Rule 713(c)(1) and (2), the following is a specification of rehearing errors, along with the issues and law on which 91茄子 relies in this rehearing request: A. Noise Measurement. Whether the Commission erred in amending its regulations [...] Read More
September 7, 2004, the Court granted the joint motion of Petitioners American Gas Association, et al, to hold these consolidated cases in abeyance, and directed the parties to file motions to govern future proceedings on October 8, 2004. The [...] Read More
Last November the 91茄子 (91茄子) and the Natural Gas Supply Association (NGSA) jointly petitioned the Commission to initiate a rulemaking to improve blanket certificate procedures. The Commission followed up on [...] Read More
Without storage data from the non-jurisdictional intrastate, LDC, and independent storage operators, which control almost one half the national inventory, there would be a substantial defect in the data base. In addition, daily storage data, unlike [...] Read More
The 91茄子 (91茄子) submits the following comments on the U.S. Department of Energy and U.S. Department of the Interior Draft Report to Congress required by section 1813 of the Energy Policy Act of 2005. 91茄子 [...] Read More
Pursuant to Rule 207(a)(5) of the Federal Energy Regulatory Commission鈥檚 (鈥淐ommission鈥� or 鈥淔ERC鈥�) Rule of Practice and Procedure, 18 CFR 搂 385.207(a)(5), the 91茄子 (鈥�91茄子鈥�) petitions for [...] Read More
In general, the comments submitted confirm 91茄子鈥檚 view that the CIG/Granite State policy is based on an unsupported presumption that shippers with discounted firm primary capacity are similarly situated with any shipper that has previously [...] Read More
91茄子 and NGSA petitioned the Commission in November 2005 to expand its blanket certificate program. While Petitioners found little room for improvement in the Commission鈥檚 processing of certificate applications, we urged a few changes that would [...] Read More
Pursuant to the proposed rule issued in the referenced proceeding on June 11, 2003, 1 the 91茄子 (91茄子) submits the following comments on the National Oceanic and Atmospheric Administration鈥檚 (NOAA) proposal [...] Read More
In response to the decision of the United States Court of Appeals for the D.C. Circuit in Williston Interstate Pipeline Co. v. FERC, 358 F.3d 45 (2004), the Commission asked interested persons for their views as to whether it should (1) adhere to [...] Read More
Louisiana鈥檚 attempt to circumvent the remedial obligation imposed by the due process clause presents a significant question that warrants review by this court: The decision conflicts with decisions of this court and other state appellate courts on [...] Read More
Pursuant to the Notice of Proposed Rulemaking issued by the Federal Energy Regulatory Commission in the captioned proceeding on May 18, 2006, 91茄子 submits the following comments addressing the Commission鈥檚 proposed regulations for coordinating [...] Read More
91茄子 supports the Commission鈥檚 basic proposal to permit electronic filing of reports under 搂搂 260.9 and 284.270, and to make provision for CEII treatment of the material, and recommends clarification on several [...] Read More
In the short term, the Commission should tailor its proposed damage reporting proposal, as described above, to avoid the reporting of information that is not relevant to the Commission's purpose of obtaining an accurate picture of the natural gas [...] Read More
Pursuant to Rule 15(d) of the Federal Rules of Appellate Procedure, the 91茄子 (鈥�91茄子鈥�) moves to intervene in these consolidated cases. In support, 91茄子 states as follows: 1. Petitioners seek review [...] Read More