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COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: NOTICE OF INQUIRY CONCERNING NATURAL GAS PIPELINE NEGOTIATED RATE POLICIES AND PRACTICES

INTRODUCTION

Notice of Inquiry Concerning Natural Gas Pipeline Negotiated Rate Policies and Practices

Docket No. PL02-6-000

The Electric Power Supply Association (EPSA) welcomes the opportunity to comment on the Federal Energy Regulatory Commission’s (Commission) Notice of Inquiry (NOI) issued on July 17, 2002, requesting comments on negotiated rate policies and practices, established in Alternatives to Traditional Cost-of-Service Ratemaking for Natural Gas Pipelines, Regulation of Negotiated Transportation Services of Natural Gas Pipelines, Statement of Policy and Request for Comments. The Commission sought specific comments on the recourse rate and whether or not it serves as a viable alternative and safeguard against the exercise of market power of interstate gas pipelines with respect to the broader negotiated rate program.