FERC Filings
MOTION TO INTERVENE OUT OF TIME AND REQUEST FOR REHEARING OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: TENNESSEE GAS PIPELINE COMPANY
CONCLUSION
WHEREFORE, for the reasons set forth above, EPSA respectfully requests that the Commission grant rehearing and modify the September 13 Order by 1) expanding the scope of the Tennessee technical conference as a vehicle for an industry-wide ruling on pipeline credit provisions and 2) encouraging NAESB to assist in the implementation of creditworthiness standards and credit requirements based on guidelines pursuant to a Commission Order in the broader proceeding. The credit issue is ripe for discussion, evaluation and determination by the Commission, and must be addressed sooner rather than later for the benefit of both pipelines and customers. Pipelines should not bear risk beyond for what they are compensated and, likewise, customers should not be burdened by credit requirements that result in over-collateralization.
October 15, 2002
Respectfully submitted,
/S/______________
Julie Simon
Vice President of Policy
Jack Cashin
Senior Manager of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 New York Avenue, NW, 11th Floor
Washington, DC 20005
(202) 628-8200
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the comments by first class mail, postage prepaid, upon each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Washington, D.C., October 15, 2002.
/S/__________________
Julie Simon