92 F~RC 61,08 1 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION ORDER ACCEPTING AND SUSPENDING TARIFF SHEETS SUBJECT TO CONDITIONS

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1 92 F~RC 61,08 1 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Before Commissioners: James J. Hoecker, Chairman; William L. Massey, Linda Breathitt, and Curt Hdbert, Jr. t" Natural Gas Pipeline Company of America Docket No. RP ORDER ACCEPTING AND SUSPENDING TARIFF SHEETS SUBJECT TO CONDITIONS (Issued July 27, 2000) On June 30, 2000, Natural Gas Pipeline Company of America (Natural) filed tariff sheets) pursuant to section 4 of the Natural Gas Act (NGA), proposing to establish a new Rate Schedule FFTS which would provide a flexible firm transportation service. Natural proposed an August 1, 2000, effective date. As discussed below, the Commission accepts and suspends the proposed tariff sheets to be effective August 1, 2000, subject to conditions. I. Description 0fthe Filing Natural filed tariff sheets to implement a new Flexible Firm Transportation Service, FFTS, which consists of firm service for a certain number of days (Available Days) in a specified time period. Natural would decide what days are Available Days based on operational considerations and/or its commitments under other firm agreements including the agreements for the new service. Natural states that the new service is needed to provide customers with flexible service options, to meet competition, and to provide a further means of continuously remarketing its capacity as contracts expire. It notes the Commission has previously t See Appendix. CKY) 3t o6 o.

2 Docket No. RP approved such a service for other pipelines, including its competitors. 2 (In these previous filings, the service has been called limited firm transportation service.) Natural and the shipper would decide by contract on a minimum number of Available Days, a maximum number of Available Days, whether partial Available Days would be permitted, and the time period. Natural states it recognizes that, as the number of Available Days is flexible, it may have to file individual FFTS Agreements with the Commission since the individual FFTS contracts wiu deviate materially from the standard service agreement on file with the Commission. 3 Natural does not believe such filings should be required, but is willing to file each contract if the Commission determines that it must do so. Natural would determine on a contract by contract basis whether a day was an Available Day. If a day was not an Available Day or if a day was a partial Available Day, Natural would give notice to the shipper at least two and one half hours prior to the deadline for timely nominations. 4 The FFTS service will be provided from unsubscribed capacity which is posted on Natural's electronic bulleting board (EBB). Natural will determine whether such capacity will be used for Finn Transportation Service (FTS) or FFTS service. Natural will award FFTS capacity through its auction procedures. It will then adjust the amount of capacity available by one of two methods. Natural believes that the new service will not have an adverse impact on existing firm services. Natural attests that before granting any request for FFTS service, it will do an engineering assessment which shows that service can be 2 Panhandle Eastern Pipe Line Co., 72 FERC 61,185 (1995), technical cqnfcren, 74 FERC 61,102 (1996), denvina reh'a and accevfina tariff sheets subject to conditions, 75 FERC 61,272 (1996); Trunkline Gas Co., 77 FERC 6 l, 169 (1996). re_b_~ 78 FERC 61,025 (1997); Transwestem Pipeline Co., 88 FERC 61,206 (1999), r~ 90 FERC 61,044 (2000); Great Lakes Transmission Limited Partnership, 90 FERC 61,065, reh ~g, 91 FERC 61,061 (2000) (Great Lakes); Northern Natural Gas C Qo., 91 FERC 61,075 (2000) (pending). a 18 C.F.R ('o) and (d) (2000); Great Lakes Transmission Limited Parmership, 90 FERC 61,065 at 61,244 (2000), eht~g, 91 FERC 61,061 at 61,214 (2000). 4 The deadline for timely nominations is 11:30 a.m on the day before the day on which gas flows (the Gas Day). The Gas Day begins at 9:00 a.m. Cenn'al Clock time.

3 Docket No. RP provided on a firm basis within the operating parameters in the FFTS Agreement without jeopardy to Natural's existing firm obligations, s The FFTS service is based on Naturars existing firm transportation rate schedule and has the same characteristics such as primary and secondary point rights and service options. 6 In addition, the same General Terms and Conditions that apply to Natural's Firm Transportation Service (FTS) apply to the FFTS service. Thus, scheduling priorid'. curtailment procedures, and capacity release are the same for both. The FITS rates are derived from the firm transportation service rates. The maximum and minimum FFTS reservation rates are the maximum and minimum FTS reservation rates stated on a daily basis. It appears that the minimum FFTS charge for a defined time period would be the minimum number of Available Days times the agreed on rate times the MDQ. ~ The reservation charge would increase if additional Available Days are provided, up to the maximum number of Available Days. In addition, Natural is proposing to transport FFTS volumes on days in excess of the maximum number of Available Days at the FFTS priority for service if the Shipper actually nominates service under the FFTS Agreement for that day and the nomination is confirmed by Natural. In that case, the reservation charge would increase by the number of additional Available Days and the volumes transported. Natural estimates that the costs of the new service for the first year will be $195,000 and the revenues will be $330,000. Natural will keep the net revenue. s Testimony of Ronald L. Brown at 4, Appendix E, Filing of June 30, 2000, Docket No. RP Service options are Late Notice (LN) (late nominations and intra-day nominations); System-Wide Service (SW) (nomination at all Receipt and Delivery points on the system on a secondary point basis); and No-Notice Balancing (NB) (inject or withdraw gas from storage on a no-notice basis on an Available Day). 7 The description of the variation in the reservation charges is contained in Natural's letter of transmittal, but not in its proposed tariff.

4 Docket No. RP II. Public Notice, Ill rventions and Pro~ sts Public notice of Natural's filing was issued on July 6, Interventions and protests were due as provided in section of the Cormmssion's regulations (18 C.F.R (2000). Pursuant to Rule 214 (18 CFR (2000), all timely filed motions to intervene and any motions to intervene out-of-ume filed before the issuance date of this order are granted. Granting late intervention at this stage of the proceeding will not disrupt the proceeding or place additional burdens on existing pajxies. The filing is protested by Dynegy Marketing and Trade (Dynegy), Indicated Shippers, s The Process Gas Consumers Group (PGC), 9 MidAmerican Energy Company (MidAmerican), Nicor Gas (Nicor), 10 and The Peoples Gas Light and Coke Company and North Shore Gas Company (collectively, Peoples). Among other things, these parties protest the need for the service, possible adverse effects on existing finn services, what capacity will be used to provide the service, how Available Days will be determined, and a number of specific features of the service. III. Discussion The Commission has reviewed the filing and will accept it and suspend it, subject to conditions, to be effective August 1, The Commission is requiring Natural to file information on certain issues and makes other modification in the filing, as discussed below. 1. Support for filing in general Many protestors assert that Natural has not adequately supported the filing and recommend the Commission reject it. Peoples II suggests if the filing is not rejected that s Indicated Shippers is comprised of Amoco Production Company, Amoco Energy Trading Corporation, Burlington Resources Oil & Gas Company, and Marathon Oil Company. 9 PGC is described as an association of industrial consumers of natural gas. The individual members are not provided. Motion to Intervene and Limited Protest of The Process Gas Consumers Group (July 12, 2000). to The exact legal name of Nicor Gas is Northern Illinois Gas Company. u The protester has designated itself "Peoples" in its filing rather than "People's," (continued...)

5 Docket No. RP it be suspended with the requirement that Natural file supporting information subject to comment, citing Northern Natural Qas Co., 91 FERC 61,975 (2000). In particular, Peoples asserts Natund has not shown the tmpact of the new set,aces on its existing firm services. It is not clear, Peoples asserts, when FFTS service ~ould be provided. For example, would Natural grant a Rate Schedule FFTS request tf st would cause existing firm shippers to lose secondary point rights on Available Days9 Peoples believes Natural should provide information on the impact of FFTS service on receipt and delivery point flexibility, allocations, operating conditions and curtailments, and also information on the available capacity on Naturars system and more detailed information on costs and revenues. Indicated Shippers also allege that Natural has not adequately explained the impact of the new service on other servaces, noting that the fa~ FFTS has a higher priority than interrnptible service will reduce the amount of interruptible service available. Indicated Shippers question whether FFTS will truly be a firm service. The Commission finds Natural has generally included appropriate support for its proposal in its filing. However, the Commission is requiring Natural to provide more information on specific issues as discussed below. Natural asserts this service will make it competitive with other pipelines. Many pipelines are offering a limited firm service similar in nature to what Natural has proposed. Natural has stated that FFTS service is the same as FTS service except that it is only provided on Available Days. Since this is a firm service paying a reservation charge it would appropriately have a higher priority than interruptible service and it would be entitled to the same receipt and delivery point flexibility as other firm services. Since the FFTS reservation charge is based on the FTS monthly rate converted to a daily rate, FTS shippers should not be supporting the FFTS shippers. The Commission will accept and suspend Natural's proposed FFTS service tariff sheets, subject to conditions. 2. Discrimination in provision of FFTS service Peoples feels that Natural should not have the discretion to offer FFTS service when there is unsubscribed capacity because Natural may refuse to provide FFTS service thus discriminating among shippers, contrary to the Commission regulations prohibiting undue discrimination. PGC believes that giving Natural the authority to provide FFTS, as proposed, will create different customer classes. n(...continued) and the Commission follows that designation here.

6 Docket No. RP The variation in types of transportation service that FFTS promises does not necessarily mean that the rate schedule will produce undue discrimination. The demand for Natural's transportation service can vary considerably by customer. The FFTS schedule can help Nanual to uulor transportation servace to help meet the varying needs of customers. However, Natural may be able to exercise undue discrimimmon under the FFTS schedule. In order to protect customers from undue discrimination, the Commission, as discussed below, is requiring Natural to file all FFTS contracts thirty days before service takes effect. This will help customers to monitor whether Natural is offering the FFTS service in an unduly discriminatory manner. In addition, Natural will be required to file a report with the Commission atter twelve months of operating experience with the FFTS service. The report should be filed on November 1, 2001, unless Natural asks for an extension based on lack of operations on that date. The purpose of the report is to provide Naturars operating experience under the FFTS contracts. For each contract, Natural must document (1) the term of the contract; (2) the defined time period(s) in the contract; and (3) for each month in each defined time period-a) the quantity of gas shipped (in Dr), b) the price per Dt for this service, c) the costs associated with providing this service and d) the operational factors the pipeline used in determining the availability of this service during the days that it was made available. 3. eapaciw for FFTS ~ervice Nicor believes that sales of FFTS capacity should be based only on capacity that is in excess of the total firm contract quantities of existing firm services, and not on estimates of how much capacity firm shippers may use on any given day. This protects the quality of firm service. Nicor believes this appears to be Natural's intent, but it is not clear. MidAmerican would like Natural to further clarify and represent that sale of service under Rate Schedule FFTS will not degrade the fights of other firm shippers and that the sale of FFTS service will not cause Natural to oversubscribe its firm services. Peoples allude to this point as well. Indicated Shippers would also like more explanation as to how Natural will determine at the time of contracting how many Available Days there will be for a customer in a month. In Mr. Brown's testimony, he states that Natural will not grant any FFTS service request unless it has done an engineering assessment which shows that the service can be provided on a firm basis within the operating parameters in the FFTS agreement and without jeopardy to Naturars existing firm obligations. The Commission reminds Natural that it can sell finn service once and if not utilized could sell it as interruptible service; it may not sell already subscribed firm service as fu'm service to another shipper. The Commission will require Natural to clarify its procedures for determining whether firm

7 Docket No. RP capacity is available for FFTS service and that Natural will not provide FFTS service unless it has firm capacity available in excess of its existing firm commitments. 4. Number of Avatlable Days m FFTS conu'acts There are a number of protests to the variable nature of Available Days. PGC asks the Commission to clarify that the proposed FFTS service requires the negotiation of a term and condition of service, the maximum number of Avzulable Days per defined period, t2 PG-C and Indicated Shippers assert that a negotiated term and condition of service is impermissible. They claim that in Order No. 637 the Commission decided not to provide pipelines with pre-approval to negotiate terms and conditions of service. Indicated Shippers, PGC, and Dynegy belie~: that the minimum and maximum number of Available Days per month should be the same for all shippers. The parties are incorrect on this issue. The variable nature of Available Days is not a negotiated term and condition of service. As the Commission explained in Order Nos. 637 and 637-A, it generally regards negotiated terms and conditions of service to be related to operational conditions of transportation service such as scheduling, imbalances, or operational obligations such as Operational Flow Orders. 13 The number of Available Days is not related to the operational conditions of transportation service and can be negotiated. However, as Indicated Shippers, PGC, Dynegy, and Nicor point out, if the number of Available Days is permitted to vary, then Natural must file each FFTS contract with the Commission in accordance with Great Lakes and the Commission's regulations, 18 C.F.R I(d) (2000). The reason is that the individual FFTS contracts do not conform to a form service agreement on file with the Commission. As Indicated Shippers state, the FFTS contracts must be filed at least thirty days prior to the effective date of service lg C.F.R (2000). And, as Indicated Shippers and Nicor note, such filing will permit time for the parties to review individual FFTS contracts and Natural's administration of the FFTS program as a whole. n PGC asserts that a shipper who can negotiate a higher maximum number of Available Days per time period would gain a better, higher priority FFTS service than a shipper who could negotiate only a lower maximum number of Available Days. la Regulation of Short-Term Natural Gas Transportation Services, and Regulation of Interstate Natural Gas Transportation Services, Order No. 637, FERC Stats. & Regs. 31,091 at 31,344 (February 25, 2000); Order No. 637-A, FERC Stats & Regs. 31,099 at 31,648 (May 19, 2000).

8 Docket No. RP Service in excess of maximum Available Days Section 7(aX2) of the FFTS Rate Schedule provides that a day may be considered an Avadable Day for billing and priocity of service arer the maximum number of Available Days has been reached for the time period if the Shipper actually nominates sennce under the FFTS Agreement for that day and the nomination is confu'med by Natural Indicated Shippers, Peoples, and Nicor assert that service beyond the contract maximum Available Days should be considered overrun service and should receive a lower priority under GT&C section 5.3(a)(3) and curtailed similar to other overrun quantities under GT&C section 5.4. Service beyond the contract maximum number of Available Days should not be treated as FFTS firm service, in their opinion. These parties explain that other firm services must rely on interruptible overrun service if they exceed contract limits. Thus, under the proposed tariff, FFTS customers who exceed contract limits would have priority over FTS customers who exceed contract limits. They also object that giving FFTS shippers service in excess of the maximum number of Available Days in their contracts permits Natural to sell any capacity which it projects to be operationally available as "firm dally service," whereas it should, in their opinion, be restricted to selling only capacity that is in excess of firm contract commitments. In addition, Nicor objects to this proposal because it believes it lets FFTS shippers contract for daily firm service without going through the usual capacity allocation procedures. If service beyond the maximum number of Available Days is not treated as authorized overrun service, then Peoples believes that no extra-contractual service should be provided. 14 The Commission agrees with the protestors that FFTS service beyond the contractual maximum number of Available Days is authorized overrun service and must be scheduled and curtailed like other overrun volumes. Natural's proposed FFTS service is intended to be similar to Natural's other firm services in every respect except the number of days the service is provided. There is no reason to give FFTS shippers better conditions of service than FTS shippers that seek to exceed contractual fights. Such treatment could be regarded as a degradation of regular firm FTS service. Natural must delete this provision from its proposed tariff and file a revised provision concerning provision of FFrs service in excess of the maximum number of Available Days that is similar to t4 Citing Great Lakes Gas Transmission Limited Partnership, 90 FERC 61,065 (2000), re gwg, 91 FERC 61,061 (2000).

9 Docket No. RP Section 9 of its Rate Schedule FTS which deals with the treatment of volumes in excess of MDQ. Is 6. Specifi ation of non-avail@;)lc Days in FFTS Anreement Peoples believes that Natural should be required to specify in the FFTS Agreement the conditions under which the pipeline would not fmd a day to be an Available Day under Section 7(a)(3) of its proposed tariff. For example, Peoples suggests, if Natural would enter into an FFTS contract based on operational assumptions that the service would never be provided during critical times or when FTS shippers nominated a specific quantity of FTS capacity, then these conditions should be specified in the FFTS Agreement as part of the definition of Available Days. The Commission agrees with Peoples. Natural will have considerable flexibility in tailoring transportation service under the FFTS rate schedule. To the extent that Natural can identify those conditions under which it will be unable to consider a particular day an Available Day under section 7 (a) (3), it should specify these conditions explicitly in the FFTS Agreement. This will help provide greater certainty for FFTS shippers. However, Natural will still have the ability to determine that it is unable to consider a particular day as an Available Day for FFTS service for other operational reasons that it may be unable to specify in advance. 7. Determination 9f Available Days for existing FFTS contracts Section 7(aX3) of Rate Schedule FFTS provides that Natural will determine Available Days for existing FFTS contracts based on "operational considerations and/or Natural's commitments under other firm Agreements, including the number of Available Days under other FFTS Agreements." Both Peoples and MidAmerican believe these standards should be clearer so as not to diminish the quality of FTS service because of illdefined procedures for the determination of Available Days. The Commission believes it would be beneficial if Natural provided a more detailed explanation of how it expects to determine Available Days for existing contracts. 8. Notice of Available Day Indicated Shippers assert that advising an FFTS shipper 2 ½ hours before timely nominations are due for a gas day that a day will not be an Available Day is an Is Authorized and unauthorized oven-un FFTS volumes are already subject to overrun charges. GT&C, Section 12.2(1), Third Revised Sheet No. 264.

10 Docket No. RP unacceptably short notice period. Naturai's testimony provides that any earlier notice would not allow it to review its operations data effectively before giving notification with respect to Available Days. The Commission accepts Natural's response. 9. Notice to replacement ;shippcr~; Section 8(c) provides that once Natural notifies the original FFTS shipper that a day is not an Available Day or is a Partial Available Day, the original FFTS shipper must notify the replacement shipper to whom capacity has been released, unless there is a permanent release of FFTS capacity. But the Commission agrees with the assertion of Peoples and Nicor that Natural, and not the original FFTS shipper, should give notice to replacement shippers of days that are not Available Days and of Partial Available Days. The Commission finds persuasive the arguments of the parties that since replacement shippers must enter into a capacity contract with Natural, the pipeline has a contractual relationship with replacement shippers and the requisite information to give accurate notice to those shippers. The Commission also finds persuasive the fact that Natural is otherwise responsible in its tariff for notifying faro shippers of curtailments or scheduling restrictions re and should have the same responsibility with regard to FFTS service. The Commission requires Natural to revise its tariff language to provide that Natural will give notice to replacement shippers when a day is not an Available Day and when a day is a Partial Available Day. 10. Partial Available Days Indicated Shippers seek clarification regarding the operation of a partial Available Day. Specifically, Indicated Shippers seek clarification that the volumes would flow at a uniform rate during the day; not flow only for a portion of the day such as fi'om 2 PM to 5 PM. Indicated Shippers also query how two similarly situated FFTS shippers, both having the same MDQ, the same number of Available Days listed in their contracts; and the same number of Available Days that have taken place, would be allocated if the available volume did not support both shippers' nominations. Would both be allocated partial days (if their contracts permitted), or would one shipper be awarded capacity and the other not. The Commission agrees the concept of partial days is confusing. The tariff provides that a partial day is when an FFTS shipper's full MDQ is not available. Indicated Shippers' questions are reasonable in light of the industry's advancement into real-time operation and need to be answered for a full understanding of how Natural's FFTS service t6 General Terms and Conditions, Section 5.2(b), Sheet No. 226.

11 Docket No. RP ll- will operate. Therefore, the Commission directs Natural to respond to these questions and provide adequate clarification of how a partial Available Day will operate. 1 I. Adjtl~micnt of firm SVl;)em copaciw fgr FFTS contracw In Section 2(d) of Rate Schedule FFTS, Natural states that it will adjust the finn capacity posting on its EBB to reflect its obligations under an FFTS Agreement. It states that the adjustment may consist of a reduction in the tmsubscribed firm capacity based on an engineering study. It indicates that the reduction may not have to be on a one-to-one basis in relation to the MDQ under the FFTS Agreement. 17 Natural then describes a second adjustment method consisting of reflecting the capacity dedicated to the FFTS Agreement as unsubscribed firm capacity, but subject to limits on the number of days available based on the Available Day and related parameters under the FFTS Agreement. Indicated Shippers request an explanation of Naturars method of adjusting firm capacity in Section 2(d) of Rate Schedule FFTS once an FFTS contract is executed. Indicated Shippers asks why firm capacity would not need to reduced on a one-to-one basis. Indicated Shippers question if FFTS was contracted for a minimum of 20 days and a maximum of 23 days during a 30 day month, whether Natural would be able to post this same capacity as available for a minimum of 7 days and a maximum of 10 days. Indicated Shippers request clarification as to how the capacity would be listed as available, and how capacity would be reduced on other than a one-to-one basis. Similarly, Peoples states it is not clear how Natural will adjust available capacity under the second of its two adjustment methods once an FFTS request has been granted. As indicated above, Section 2(d) provides that Natural may continue to reflect the capacity dedicated to the FFTS Agreement as unsubscrihed firm capacity, but subject to limits on the number of days available "based on the Available Day and related parameters" under the FFTS Agreement. Peoples asserts that related parameters are not defined and that, in fact, the only relevant parameters are the minimum number of Available Days, the maximum number of Available Days, any specific unavailable days, and the applicable time period. Peoples asserts that the reference to related parameters should be explained or deleted. 17 The Commission agrees with Indicated Shippers that Natural should use FFTS not FTS in Section 2(d) of Rate Schedule FFTS (Sheet No. 32) in the phrase "Natural may not have to reduce posted firm capacity on a one-to-one basis in relation to the MDQ under the FTS agreement." Natural is directed to revise its tariff accordingly.

12 Docket No. RP The Commission finds the protestors have raised meaningful questions concerning the manner in which Natural will make capacity adjustments when FFTS service has been contracted. The Commission directs Natural to provide answers to the questions raised by Indicated Shippers and Peoples concerning these adjustments, in tddmon, the Commission finds that the "related parameters" to which Peoples refers are vague and undefined. The Commission directs Natural to delete this reference or explam what parameters it intends to use in adjusting capacity for FFTS Agreements in its second method. IV. Suspension Based on a review of the filing, the Commission finds that the proposed tariff sheets have not been shown to be just and reasonable, and may be unjust, unreasonable, unduly discriminatory, or otherwise unlawful. Accordingly, the Commission will accept the tariff sheets for filing, and suspend their effectiveness for the period set forth below, subject to the conditions in this order. The Commission's policy regarding rate suspensions is that rate filings generally should be suspended for the maximum period permitted by statute where preliminary study leads the Commission to believe that the filing may be unjust, unreasonable, or that it may be inconsistent with other statutory standards. See, Great Lakes Gas Transmission 12 FERC 61,293 (1980) (five-month suspension). It is recognized, however, that shorter suspensions may be warranted in circumstances where suspension for the maximum period may lead to harsh and inequitable results. See. Valley Ga~ Transmission, Inc,, 12 FERC 61,197 (1980) (minimum suspension). Such circumstances exist here where the pipeline is proposing a new firm service to provide customer choice and meet competition. Therefore, the Commission will accept and suspend the proposed tariff sheets to be effective August I, 2000, subject to conditions. The Commi~ign orders: (A) The tariff sheets listed in the Appendix are accepted and suspended to be effective August 1, 2000, subject to the conditions described in the body of this order and the ordering paragraphs below. (B) Natural must file, within 15 days of the issuance of this order, all of the information and the revised tariff sheets required in this order with the exception of the report described in Paragraph C below.

13 Docket No. RP (C) On November 1, 2001, Natural must file a report on twelve months of operating experience under its FFTS contracts as specified in the body of this order. By the Commission. (SEAL) Secretary

14 Docket No. RP Appendix Page I of 3 Nanull Gas Pipeline Company of.~aenca Docket No. RP OOO FER Qas Tariff. $ixqh Revised Volume No I Tariff Sheets proposed to be effective August i, 2000 Eleventh Revised Sheet No. 1 Ninth Revised Sheet No. 2 Thirteenth Revised Sheet No. 3 Original Sheet No. 14C Original Sheet No. 14D Original Sheet No. 14E Original Sheet No 14F Sixth Revised Sheet No. 15 Fourth Revised Sheet No. 16 Fifth Revised Sheet No. 18 Fifteenth Revised Sheet No. 22 Tenth Revised Sheet No. 24 Fifteenth Revised Sheet No. 25 Eighth Revised Sheet No. 26 Seventh Revised Sheet No. 28 Second Revised Sheet No. 30 First Revised Sheet No. 31 First Revised Sheet No. 32 First Revised Sheet No. 33 First Revised Sheet No. 34 Second Revised Sheet No. 35 Second Revised Sheet No. 36 First Revised Sheet No. 37 Second Revised Sheet No. 38 Second Revised Sheet No. 39 Second Revised Sheet No. 40 First Revised Sheet No. 40A First Revised Sheet No. 41 First Revised Sheet No. 42 First Revised Sheet No. 43

15 Docket No. RP Appendix Page 2 of 3 FERC Gas Tariff. Sixth Revised Volum~ No. I Tariff Shee~s proposed to be effeoase August 1, 2000 First Revised Sheet No. 44 First Revised Sheet No. 45 First Revised Sheet No. 46 First Revised Sheet No. 47 First Rexdsed Sheet No. 48 Original Sheet No. 48A Original Sheet No. 48B Second Revised Sheet No. 63 Fourth Revised Sheet No. 65 Eighth Revised Sheet No. 200 Tenth Revised Sheet No. 203 Second Revised Sheet No. 225 Fourth Revised Sheet No. 226 Fourth Revised Sheet No. 227 Fourth Revised Sheet No. 228 Original Sheet No. 228A Sixth Revised Sheet No. 229 Fourth Revised Sheet No. 230 Third Revised Sheet No. 232 Fifi.h Revised Sheet No. 233 Sixth Revised Sheet No. 238 Third Revised Sheet No. 238A First Revised Sheet No. 241A Eighth Revised Sheet No. 246 First Revised Sheet No. 253B Fourth Revised Sheet No. 261 Fourth Revised Sheet No. 262 Third Revised Sheet No. 262A Second Revised Sheet No. 262B Fifth Revised Sheet No. 263 Third Revised Sheet No. 264 Seventh Revised Sheet No. 264A Sixth Revised Sheet No. 268

16 Docket No. RP Appendix Page 3 of 3 FERC Gas Tariff. Sixth Revi~ed Volume No, 1 TanffSheets proposed to be effective August 1, 2000 Second Revised Sheet No. 287B Fourth Revised Sheet No. 294 Fifth Revised Sheet No. 32] Seventh Reprised Sheet No 323 Seventh Revised Sheet No. 324 Eighth Revised Sheet No. 370 Seventh Revised Sheet No. 385B Fifth Revised Sheet No. 411 Fourth Revised Sheet No. 500