Subject: Re: GISB Rules Governing Capacity Release Recalls
From: [email-masked]
To: [email-masked]
Cc: [email-masked]
Date: Wed, 20 Mar 2002 14:01:04 -0800 (PST)

See below -- the only response I got to a query as to whether anyone at the
pipes is thinking about filing for rehearing or clarification.

===================
Nancy Bagot
Manager, Govt. Affairs
Northern Natural Gas Co.
1500 K Street, NW
Suite 400
Washington, DC  20005
202-216-1129 direct dial
----- Forwarded by Nancy Bagot/NNG/Dynegy on 03/20/02 04:59 PM -----
                                                                                                                                       
                      "Dave Reitz"                                                                                                     
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                                               Subject:  Re: GISB Rules Governing Capacity Release Recalls                             

There were 2 places in the order that left me scratching my head:

para. 32 - Pipelines will have to waive non-critical penalties for bumped
shippers.  I thought Order 637 was supposed to rid pipeline tariffs of
unnecessary penalties.  I don't know what "non-critical" means as applied
to our post-637 tariff.

para 61 - I can't tell if the new rule is applicable only to releases
implemented after the effective date, or will it also apply to existing
recallable releases that do not have a condition precluding intra-day
recalls.

Ordinarily, we could try to use our compliance filing to clarify such
things but here FERC has dictated the tariff language we have to use.

We haven't decided whether to seek clarification.  Our business folks are
still looking at this.

>>> <[email-masked]> 03/15/02 04:03PM >>>

I'm wondering if anyone has discussed or thought about filing for rehearing
or clarification on this rule (which would be due April 10, I believe).
- Nancy Bagot
Northern Natural

===================
Nancy Bagot
Manager, Govt. Affairs
Northern Natural Gas Co.
1500 K Street, NW
Suite 400
Washington, DC  20005
202-216-1129 direct dial