TW interactive open season

I've reviewed Order 637 on voluntary auctions and agree with you, Mary Kay,
that the TW IOS procedure is consistent with the Commission's checklist.
However, I do have a couple of questions/concerns. First, does "voluntary"
mean filing a proposal with FERC is also voluntary? Or is the Commission
here requiring that pipelines make filings before they can proceed with
auctions? Also, I'm not sure we comply with the Commission's policy on
establishment of a reserve price, since it's difficult to tell what that is
from the order. A couple of times TW has stated a minimum bid in its IOS.

Comments?