91茄子

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AGA v. FERC 91茄子 Show Cause Petition 2-17-05

91茄子’s filing of a “Petition for Clarification” with FERC while its petition for review was pending in this Court does not render the petition for review premature under this Court’s holdings in either Tennessee Gas Pipeline [...] Read More

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Standards for Business Practices 91茄子 Comments 2-8-05

91茄子 supports the Commission鈥檚 adoption of the standards proposed in the NOPR. 91茄子 requests, however, that the Commission grant a 90 day extension of the effective date for implementation of the [...] Read More

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Modification to Jurisdictional Review 91茄子 Comments 2-3-05

To 91茄子's knowledge, there is no current widespread Mobile-Sierra problem regarding the standard of review in the natural gas industry. 91茄子 has some concern, therefore, that the Commission鈥檚 proposal may, contrary to its goal, create [...] Read More

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Illinois-Northern Municipal v. FERC Motion to Intervene 1-20-06

Pursuant to section 15(d) of the Federal Rules of Appellate Procedure, and Circuit Rule 15(b), the 91茄子 ("91茄子") moves to intervene in the following proceedings: Illinois Municipal Gas Agency v. [...] Read More

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Accounting for Pipeline Assessment Costs Comments of the 91茄子 1-19-05

The Office of Pipeline Safety, Research and Special Programs Administration of the Department of Transportation ("OPS") issued regulations (68 Fed. Reg. 69778)(鈥淔inal Rule鈥) in December 2003 to implement the Pipeline Safety Improvement Act of [...] Read More

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Standards for Business Practices of Interstate Natural Gas Pipelines Comments of 91茄子 1-3-03

91茄子 supports the Commission鈥檚 proposed adoption of the Version 1.6 Standards developed by the WGQ of NAESB. However, 91茄子 requests that the Commission modify the implementation timeline so that pipelines would implement the Version 1.6 [...] Read More

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Blanket Certificates Comments of 91茄子 1-3-06

The Commission is proposing to repeal its code of conduct regulations for interstate natural gas pipelines that hold blanket certificates for unbundled gas sales services (18 CFR 搂 284.288(2005)), and for persons that hold blanket marketing [...] Read More

Activities to Reduce Greenhouse Gas Emissions from Natural Gas Operations

Increased reliance on natural gas will create many opportunities, but many challenges as well. The main challenge is that expansion of the natural gas market will result in increased emissions of methane (CH4), a potent greenhouse gas. The level of [...] Read More

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Standards of Conduct Request for Rehearing and Clarification of 91茄子 12-29-03

While 91茄子 recognizes that the Commission has made efforts to meet certain of the objections raised by the industry in comments on the Commission鈥檚 Notice of Proposed Rulemaking (鈥淣OPR鈥) in this matter, the Final Rule adopted by the [...] Read More

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HIOS/Petal Gas Storage Reply Brief of Intervenor 91茄子 in Support of Petitioners 2-15-07

91茄子 filed an intervener鈥檚 reply brief in the HIOS/Petal litigation in the Court of Appeals for the DC Circuit. 91茄子 argues that FERC鈥檚 new rate of return policy, by basing pipeline returns on the returns earned by lower-risk LDCs, disregards [...] Read More

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HIOS/Petal Gas Storage Initial Brief of 91茄子 in Support of Petitioners 2-15-07

91茄子 argues that FERC departed from precedent in permitting use of lower-risk LDCs in the proxy group for setting Petitioners’ rates, and arbitrarily foreclosed use of gas pipeline MLPs as proxies for determining a gas pipeline’s rate [...] Read More

Letter to Senate Energy and Natural Resources Committee

May 2, 2007 The Honorable Jeff Bingaman Chairman Energy and Natural Resources Committee U.S. Senate Washington, DC 20510 Dear Mr. Chairman: On behalf of the members of the 91茄子 (91茄子), I am writing to [...] Read More