EPSA Draft Comments on Commission's Proposed Reporting Requirement

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MEMORANDUM

TO: Regulatory Affairs Committee
Gas Issues Working Group

FROM: Jim Steffes, Regulatory Affairs Committee Chair
John Orr, Gas Issues Working Group Chair
Julie Simon, Vice President of Policy
Jack Cashin, Senior Manager of Policy

DATE: June 12, 2001

RE: EPSA Draft Comments on Commission's Proposed
Reporting Requirement on Natural Gas Sales to California
Market
?Comments to EPSA by Friday, June 15th, 12:00 p.m.
(EST)
?Filing Due June 18th

Attached are draft EPSA comments in response to the Commission's proposed
requirements on natural gas sales to the California market. The Commission
is proposing that market participants (including pipelines and LDCs) submit
quarterly reports on price and volume data on physical transactions. EPSA's
comments focus on four key issues:

?The reporting requirements represent an unnecessary burden;

?The information requested has proprietary and confidential aspects;

?Increased reporting requirements will not adequately address gas
infrastructure needs in California; and

?If reporting requirements are imposed, a sunset date should provide a
definite end to the filing obligation.

As discussed on the Gas Issues Working Group call on June 7th, members asked
that EPSA file these comments.

Comments are due at FERC on Monday, June 18th. In order to ensure we file on
time, please forward any comments by noon on Friday, June 15th to Jack Cashin
at 202-628-8200 or jcashin@epsa.org.

Attachment

- CA NG Reporting.doc