Federal Energy Regulatory Commission Requests Additional Information from Natural Gas Pipeline Company of America LLC

Strategic Insights -

The Federal Energy Regulatory Commission (FERC) has issued a request for additional information from Natural Gas Pipeline Company of America LLC (Natural) to assist in the analysis of the company's proposal for a certificate application under Section 7 of the Natural Gas Act. The request seeks specific information on the company's tax rates, service agreements, and pro forma service agreement for Rate Schedule NSS.

Key Takeaways:

  • FERC has requested additional information from Natural to clarify its tax rates, specifically the Pre-Tax Return used for the project and the Composite Tax Rate.
  • The Pre-Tax Return was calculated using a 35% federal income tax rate, which is no longer applicable due to the Tax Cuts and Jobs Act (TCJA) of 2017, which reduced the corporate federal income tax rate to 21%.
  • Natural must provide a new recalculated Pre-Tax Return using a 21% federal income tax rate or explain why it is not possible to recalculate.
  • FERC also requested public copies of the unexecuted Rate Schedule NSS service agreements, including non-conforming provisions.
  • Natural must provide clean and redline/strikeout versions of the service agreements, with negotiated rates redacted.
  • The Commission's Division of Pipeline Regulation is seeking this information to ensure compliance with regulatory requirements.

Statistics:

  • The tax rate reduction due to the TCJA is 14% (from 35% to 21%).
  • The Pre-Tax Return used for the project is 14.98%.
  • The Composite Tax Rate used for the project is 24.11%.
  • The Deadline for filing the response is five business days from the date of the issuance of this letter.
  • The response must be filed electronically via the eFiling link on the Commission's web site at http://www.ferc.gov.

Sources:

  • Federal Energy Regulatory Commission, "Notice of Data Request Request for Additional Information", Docket No. CP25-52-000 (July 29, 2025)
  • Tax Cuts and Jobs Act (TCJA) of 2017