FERC Filings

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

II. Requested Information is Proprietary and Confidential

The information requested in the Commission’s proposed Order is commercially proprietary and confidential, increasing the potential for abuse of the data. The Commission has not provided any specific guarantees of confidentiality, leaving market participants open to the potential financial harm and misrepresentation of the data.

Market participants face seeing their sensitive competitive information opened to competitors, suppliers and customers through the Freedom of Information Act (FOIA) requests. The Commissions suggested use of a standard protective order does not ease these competitive concerns.

Given the commercially sensitive nature of the data, providing it to any employee of a potential customer or supplier, or another competitor, even under protective order, does not provide the necessary protections. Moreover, the politically charged California environment heightens the potential for abuse of this information by way of manipulation and misinterpretation.

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