Natural Gas Pipeline Company of America LLC Submits Response to FERC Data Request

Strategic Insights -

The Natural Gas Pipeline Company of America LLC has submitted a response to a data request from the Federal Energy Regulatory Commission (FERC) regarding their Gulf Coast Storage Expansion Project. The response addresses questions regarding the company's pre-tax return, composite tax rate, and service agreements with project shippers. The company's Director, Regulatory, Rahul Singh, prepared the response, which was submitted to FERC on August 4, 2025.

Key Takeaways:

  • The company used a 14.98% pre-tax return for the project, which was established in a previous settlement in Docket No. RP95-326-000.
  • The pre-tax return cannot be recalculated due to the individual components of the return not being separately stated.
  • The company used a 21% federal income tax rate for the calculation of the composite tax rate of 24.11% for the project.
  • The composite tax rate was calculated using the formula: a + b - (a * b), where a is the federal tax rate (21.00%) and b is the state tax rate (3.94%).
  • The company requested that FERC make a determination as to whether certain non-conforming provisions in the service agreements with project shippers are permissible deviations from their pro forma service agreement.
  • The company included a non-public, redlined version of the non-conforming provisions in Exhibit I, Volume II - Privileged, and attached a redline of each shipper's non-conforming creditworthiness provisions to the response.

Statistics:

  • The pre-tax return used for the project is 14.98%.
  • The composite tax rate used for the project is 24.11%.
  • The federal income tax rate used for the calculation of the composite tax rate is 21.00%.
  • The state tax rate used for the calculation of the composite tax rate is 3.94%.
  • The 14.98% pre-tax return was established in a previous settlement in Docket No. RP95-326-000.

Sources:

  • Natural Gas Pipeline Company of America LLC, Response to July 29, 2025, Data Request, Docket No. CP25-52-000, submitted to FERC on August 4, 2025.
  • FERC, Notice of Filing of Response to Data Request in the Above-Referenced Proceeding.