RE: (1) EPSA Draft Comments on Pipeline Capacity Recall NOPR

Guys --

I understand the differences. Becky is going to get on the EPSA call tomorrow and tell them that we are ok with the NOPR (and will file as such) and that EPSA should make sure to not blow up the NOPR (or try). Becky if EPSA wants complete agreement, then they shouldn't file. Grab me if you want to talk.

Jim

-----Original Message-----
From: Nicolay, Christi L.
Sent: Tuesday, November 13, 2001 4:48 PM
To: Steffes, James D.
Subject: FW: (1) EPSA Draft Comments on Pipeline Capacity Recall NOPR

Jim -- Leslie responded that ENA's comments are in favor of the NOPR, as long as the shipper and released-to-customer agree on the terms and subject to legitimate pipeline operational (accounting/balancing) concerns (which accommodate the pipelines' concerns). Therefore, ENA is taking a different position than EPSA. Furthermore, EPSA's comments include Dynegy comments against the NOPR.

I agree with ENA's position. Is this something that EPSA would want agreement of all members to file? Also, it seems that ENA's approach is consistent with being allowed to make something you purchased into a product that your customer wants.

-----Original Message-----
From: Nicolay, Christi L.
Sent: Tuesday, November 13, 2001 1:28 PM
To: Lawner, Leslie
Subject: FW: EPSA Draft Comments on Pipeline Capacity Recall NOPR

FYI.

-----Original Message-----
From: Michael Reddy [mailto:Mreddy@epsa.org]
Sent: Friday, November 09, 2001 5:13 PM
To: acomnes@enron.com; Hawkins, Bernadette; Nersesian, Carin; Nicolay,
Christi L.; Fulton, Donna; Steffes, James D.; Scheuer, Janelle; Hartsoe,
Joe; Shelk, John; Noske, Linda J.; Robertson, Linda; Alvarez, Ray;
Cantrell, Rebecca W.; Shapiro, Richard; Novosel, Sarah; Mara, Susan;
Lindberg, Susan; Hoatson, Tom
Subject: EPSA Draft Comments on Pipeline Capacity Recall NOPR

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: 11/9/2001

RE: EPSA Draft Comments on Pipeline Capacity Recall
NOPR
? Comments due November 19th
? Conference Call November 14th
?
As discussed on the last Gas Issues Working Group conference call, attached are draft EPSA comments on FERC's Notice of Proposed Rulemaking (NOPR) on pipeline capacity recall. EPSA opposes the NOPR because it (a) will reduce competition in the secondary market for transportation services and (b) may reduce the pipeline operational flexibility needed by electric generators. Thus, EPSA urges the Commission not to impose a broad based recall requirement throughout the natural gas industry but rather gain experience with this difficult issue in individual Order No. 637 proceedings.

Please review the draft and forward any comments or proposed changes to the draft to Jack Cashin at EPSA at jcashin@epsa.org by noon on Thursday, November 15th so that we can make a timely filing by Monday, November 19th. EPSA will hold a conference call on Wednesday, November 14th, at 1:00 P.M. (EST) to discuss the draft. To access the call, dial 1-800-937-6563. Ask for the Jack Cashin/EPSA Call.

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