FERC Filings

EPSA'S COMMENTS ON FERC'S PIPELINE CAPACITY RECALL NOPR

INTRODUCTION

Standards for Business Practices Of Interstate Natural Gas Pipelines
Docket No. RM96-1-000

Regulation of Short-Term Natural Gas
Transportation Services
Docket No. RM98-10-008

Regulation of Interstate Natural Gas

Transportation Services
Docket No. RM98-12-008

The Electric Power Supply Association (EPSA) is filing the following comments to the Federal Energy Regulatory Commission’s (Commission) October 12, 2001 Notice of Proposed Rulemaking (NOPR) in the captioned proceeding. In the NOPR, specifically, the Commission proposes to require pipelines to permit shippers to recall released capacity and renominate such recalled capacity at each nomination opportunity provided by the pipeline according to the notice and bumping provisions applicable to interruptible shippers. EPSA has concerns with the NOPR because it (a) will reduce competition in the secondary market for transportation services and (b) may reduce the pipeline operational flexibility needed by electric generators. Thus, EPSA urges the Commission not to permit such a broad based recall authority throughout the natural gas industry but rather gain experience with this difficult issue in individual Order No. 637 proceedings.

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