Opinion for the Court filed by Circuit Judge BROWN.
BROWN, Circuit Judge:
The Federal Energy Regulatory Commission ("FERC" or "the Commission") issued an Accounting Order, instructing natural gas pipeline companies to expense certain costs associated with the Pipeline Safety Improvement Act of 2002, Pub.L. No. 107-355, 116 Stat. 2985 ("PSIA"). After FERC denied a request for rehearing, the Interstate Natural Gas Association of America ("INGAA") petitioned...
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