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Enron Mail |
Susan,
I'm assuming that Ms. Corman is "all over this." I was wondering whether y= ou=20 intended to go to D.C. also to represent TW's interest in the proceeding? = If=20 not, may we assume that Shelley will give us a complete report on the meeti= ng=20 and FERC's next steps? I note with curiosity the reference in the GD article to the fact that=20 parties apparently were asking whether pipelines "needed" to offer new=20 services? Do you know the background behind this issue? It may have some= =20 bearing on the Transport Options filing as at least one party I believe=20 questioned why TW was even offering this new service. In addition to the= =20 question of affiliate relationship/behavior, the question of market power= =20 (ie. capacity hoarding) apparently is ripe for discussion also during the= =20 Jan. 31 meeting. =20 Do you know if we are working to prepare comments or a position paper to=20 submit to FERC by Jan. 5? One last thing, how should we proceed with respect to coordinating the timi= ng=20 of our technical conference on Transport Options with this pending meeting = at=20 FERC? Do we gain more by attempting to schedule a technical conference=20 before the FERC meeting or after? It seems to me that if the technical=20 conference was held before the FERC meeting, all protest issues related to= =20 affiliate marketing rules and/or capacity hoarding questions could easily b= e=20 set aside pending the outcome of the FERC meeting and/or any subsequent FER= C=20 rulemaking on the matter. However, I question FERC's appetite to conduct t= he=20 technical conference prior to the Jan. 31 meeting when it is known in advan= ce=20 that the affiliate marketing rules figure so prominently in the case. What= =20 do you think? Regulatory roundup FERC is getting ready to resume the industry dialogue on promoting=20 competitive interstate transportation markets. In an order issued last week, the commission fixed= =20 the date for a staff conference on one of the most contentious topics in the industry:=20 affiliate transactions. The meeting =01* the second in a series of three =01* is scheduled for Jan.= 31.=20 Comments and requests to participate are due by Jan. 5. Commission staff will have their hands full with this one. At the first=20 roundtable on Sept. 19, FERC tackled efforts to promote greater market liquidity followin= g=20 the introduction of Order 637 (GD 9/20). The discussions were polite, but they failed to=20 yield a consensus over the extent to which FERC needs to overhaul rate design. Likewise, man= y=20 in the energy industry are not in agreement about the need for new pipeline servic= es. A discussion of affiliate issues promises to be more rancorous. At the Sep= t.=20 19 meeting, in fact, some audience participants were eager to call attention to affilia= te=20 problems on certain interstate pipelines. FERC staff, however, kept a lid on those discussions= ,=20 and did not allow comment on any ongoing case. On Jan. 31, the discussion will focus on =01&whether the regulatory policy = with=20 respect to pipeline affiliates and non-affiliates, as well as asset managers and agent= s,=20 should be revised to reflect the changing nature of the gas market=018 and =01&whether there = needs to=20 be revisions to the regulations relating to pipeline affiliates.=018 At present, affiliate relationships are governed by certain standards of=20 conduct. Other market participants can monitor those transactions through various posting= =20 and reporting requirements. But not all pipelines are subject to the same requirements,= =20 and the upcoming discussion is intended to open a dialogue about the market power implicatio= ns=20 of transactions=20 between pipelines and their affiliates. The panel will also examine the=20 relationship between non-pipeline capacity holders and their affiliates.
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