fw section 311 know sent redmond 311 case original message hull bryan sent tuesday august 14 2001 7 16 redmond brian subject fw section 311 brian pretty good explanation case thus far commissioner wood aware conflict pg e epgt southern union probably lobbying southern union raised issue southern union states initial brief 9 opposes high demand rates says epgt proposes charge service incorporate consumer protections order 636 argues ferc impose order 636 standards pg e watching video stream meeting whole discussion seemed come nowhere facts case 1 december 20 1999 pg e texas pipeline lp predecessor epgt texas pipeline lp filed petition ferc approval transportation rates section 311 along required intrastate pipelines perform section 311 service must either rates approved ferc must charge rates approved state regulatory body similar service pg e filing proposed addition usual interruptible service firm section 311 service well interruptible parking lending service pg e also filed revised statement operating conditions reflect new services 2 february 25 2000 southern union gas company intrastate transportation customer pg e filed late motion intervene raised issues stated addressed hearing pg e opposed late intervention ferc granted april 14 2000 pg e stated southern union intervening order gain leverage renegotiating contract intrastate service 3 southern union submitted data requests pg e april 13 april 17 pg e attempted get protective order issued ferc rejected request 4 settlement conference held september 7 2000 5 staff panel convened october 2 2000 order conduct advisory non evidentiary proceeding oral arguments issues instructions make recommendations commission within 90 days 6 november 1 2000 ferc requested 5 pages additional information pg e order complete application proceeding pg e provided november 8 th december 8 th pg e provided additional information response ferc data request 7 january 10 2001 southern union submitted proposed alternative cost service rate design filed pg e 8 january 17 el paso field services informed ferc pg e texas pipeline lp acquired el paso december 22 2000 name changed epgt texas pipeline lp 9 january 24 2001 epgt texas southern union filed initial briefs 10 july 17 2001 epgt filed supplemental comments response discussion ferc summarized commissioner wood inquired extension order 636 637 provisions section 311 service providers epgt stated ferc proceeds policy generic rulemaking individual pipeline proceeding july 30 2001 southern union filed reply comments opposing epgt supplemental comments 11 august 3 epgt filed amended statement operating conditions provides electronic nominations two additional nomination cycles bumping clarified updated credit provisions modified quality provisions protect system integrity clearly defined authorized overrun service ngpa gives ferc authority intrastate pipeline rates section 311 service requires service provided non discriminatory basis question whether gives ferc authority require example compliance order nos 636 637 please let know enough detail maybe wanted