FERC Filings

Order Proposing Reporting Requirement on Natural Gas Sales to California Market-Docket No. RM01-9-000

V. Conclusion

EPSA urges the Commission to reconsider its proposed reporting requirements on natural gas sellers and transporters serving the California market and the reporting burden it represents to both Commission staff and market participants. Jurisdictional market participants should not have to risk reporting confidential and proprietary market data without a guarantee of its confidentiality.

This potential market data exposure can be avoided by using existing California investigations that should more than provide the Commission with the relevant market information that it needs to assess the California natural gas market. Since infrastructure adequacy plays a significant part in shaping the supply and demand characteristics that determine California natural gas market prices, the Commission should analyze infrastructure adequacy along with the market data from existing investigations. Should the Commission decide that it needs to pursue additional data through a reporting requirement, it should provide for a more narrowly focused set of data and specify a sunset date for market participants.

Respectfully submitted,

Julie Simon, Vice President of Policy
Jack Cashin, Senior Manager of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1101 14th Street, N.W.
Washington, D.C. 20005
202-628-8200

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