kmi ngpl order 637 changes protested note see gas quality section bottom propose adding pipelines like ngpl shippers protest kmi order 637 tariff changes kinder morgan interstate gas transmission kmi attempted end run around ferc order 637 filing wide ranging operational rate changes early expedited tariff procedures avoid rigorous review store compliance filings according customer protests items kmi tariff filing fall less 13 general categories indicated shippers said include imbalance provisions storage balances small customer service gas quality point allocations curtailment priorities right first refusal scheduling priorities incidental purchase sale capacity release unauthorized gas capacity rights overrun charge miscellaneous indicated shippers called summary rejection maximum suspension kmi june 5 tariff filing rpo 0 316 saying changes proposed case represent effort kmi implement elements order 637 selectively manner designed minimize opportunity meaningful review comment kmi customers 12 days allowed intervention comment usually routine tariff filings federal energy regulatory commission allotted 30 days comments order 637 compliance filings kmi among group pipelines slated make compliance filings june 15 kmi said filing constitute compliance filing aimed changing tariff reflect current natural gas business climate evolving business practices acknowledge number changes proposed herein consistent advance commission goals order 637 indicated shippers also protested changes would make decisions regarding negative storage imbalances end season inventory swaps matter kmi discretion without standards decisions would made shippers also protested changes default methodology point allocations billing purposes injection kmi discretion formula accepting rejecting predetermined allocation agreements upstream downstream parties addition curtailment provisions filed kmi appear contrary order 637 mandate shippers moving gas within primary path primary rights filing also would give pipeline opportunity bottle significant quantities coal bed methane gas wyoming powder river basin imposing rigorous standards nitrogen content according western gas resources key change would impose nitrogen gas quality specification 3 volume kmi states change necessary accommodate transfers interconnecting pipelines six seven connecting pipelines identified nitrogen specifications kmi affiliate natural gas pipeline co america similar rules western gas said kmi proposed nitrogen specification would enable kmi refuse accept coal bed methane production transportation thereby foreclosing availability one principal means downstream pipeline egress powder river production areas western gas added producers would shut production construct costly nitrogen facilities could create least temporary gap downstream movement coal bed supplies mid continent eastern markets thus frustrating consumer access significant supplies