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    North American Energy Standards Board

    1301 Fannin, Suite 2350, Houston, Texas 77002

    Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail:

     Home Page:

TO: Wholesale Gas Quadrant, Wholesale Electric Quadrant, and Interested Parties

    FROM: Laura Kennedy, Meeting/Project Manager

    RE: Final Minutes of e-Tariff Meeting February 1, 2007

    DATE: February 10, 2007

    WEQ and WGQ E-Tariff Meeting

    Washington, DC hosted by Federal Energy Regulatory Commission

    February 1, 2007

    Final Minutes

    1. Opening Remarks

    Chairman Kelliher made brief opening remarks.

    2. Administrative

    Ms. Kennedy gave the antitrust guidelines. Mr. Buccigross welcomed the attendees and

    reviewed the agenda.

    3. Background on e-Tariff presented by Commission Staff

    Prior to making comments, Mr. Goldenberg, Sr. Counsel, Office of the General Counsel, OMTR,

    stated that the views expressed by the Staff during this meeting were not necessarily the views

    of the FERC or any FERC Commissioner.

    FERC Staff provided a work paper prior to this meeting “for advanced background information

    and the areas in which standards may be required to implement an eTariff database” that was

    posted on the NAESB e-Tariff page: Background E-Tariff Information. The work paper

    describes the purpose of the e-Tariff Program and provides examples of basic fields required for

    the FERC tariff database.

    Mr. Goldenberg, Mr. Pierce, and Mr. Nutsch of the FERC provided background information for

    the participants.

    Mr. Goldenberg stated that the FERC began working with GISB and the gas industry fourteen

    years ago to develop standards for electronic commerce. The FERC is now seeking to develop

    an efficient mechanism for tariff sheets, transmittal letters, and other documents that are

    submitted with tariffs to be submitted in a format that can be used in a FERC tariff database.

    The FERC developed an e-Tariff database program that has been tested by the electric, gas,

    and oil industries. Industry participants have raised and continue to raise objections to the

    proposed FERC e-Tariff development software. As a result, FERC Staff has asked NAESB to

    work alongside FERC Staff and affected industries to develop an efficient method of

    entry/electronic filing process for tariff and related documents and to develop negotiated

    standards and procedures so that electronic filing of tariffs can become a reality. Mr.

    Goldenberg noted that FERC Staff need to see proposed amendments in the context of whole

    tariffs and need to be able to accept some amendments, reject others, and end up with the

    approved tariff. He also noted that maintaining historic information is crucial to FERC Staff,

    especially for rate cases and complaints. FERC Staff often need to examine the tariff language

    as it existed at the time the issues at hand took place. This proves difficult when there have

    been multiple filings since the time the complaint was filed and when the proposed revisions

    were accepted in part; suspended in part; and/or rejected in part by the FERC or any

    combination thereof. In addition, FERC Staff receives requests for the paper index for the

    effective tariff rate schedule at a particular point in time. The paper indices will not be

    WEQ and WGQ e-Tariff Meeting Final Minutes February 1, 2007

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    North American Energy Standards Board

    1301 Fannin, Suite 2350, Houston, Texas 77002

    Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail:

     Home Page:

maintained as the FERC moves toward an e-Tariff filings and database program. The end

    result will be for the FERC Staff and the industry to be able to determine the effective tariff

    language at a particular point in time.

    Mr. Pierce stated that the e-Tariff filing system needs to manage the tariff sheets and manage

    the receipt of the tariff accompanying documents. Under the current process, all tariff filings

    are made on paper. The gas industry currently has the FASTR tool that is outdated. The e-

    Tariff filing system also needs to have the functionality to: receive the tariff filing, receive the

    proposed tariff provisions (in either section or sheet format); and require the inclusion of

    sufficient information to allow FERC Staff to duplicate and automate the current paper process

    of receiving and processing tariff filings and inserting and removing tariff sections while

    updating the status of those sections. The e-Tariff filing system should also result in providing

    the ability to search the tariff by metadata and by text.

    Mr. Pierce reviewed the XML based tariff maintenance system developed by Staff in 2001 but 1 this system was not embraced by the industries at that time. In 2004, FERC issued a NOPRfor the creation of a database of tariffs and tariff filings that supplies the metadata needed to

    manage tariff sheets. The Applicant’s database would always be synchronized with the FERC’s

    view of the tariff in question. The Applicants would also see the same data as the FERC Staff.

    FERC Staff developed Distributed Software that would allow Applicants to assemble an entire

    tariff filing in pieces and once complete send the entire package. The Distributed Software

    would also incorporate the Secretary’s rules for submitting filings and would make sure the

    filing was complete. Thus, Applicants would be less likely to get a rejection for a filing for

    failure to comply with the Secretary’s requirements for that particular type of filing.

    4. Requirements for e-Tariff presented by Commission Staff

    Mr. Pierce stated that while the FERC Distributed Software is ready to implement now, FERC

    Staff is open to the development of a web-based interface e-Tariff filing system or to

    modifications of the Distributed Software. He set forth several requirements for a web-based

    interface e-Tariff filing system:

    ? FERC would maintain a website to receive tariff filings and tariff provisions or sheets;

    ? Applicants will need to provide sufficient information to trigger docketing and tariff

    database rules;

    ? Applicants must maintain their own tariff database, including any Commission actions,

    in order to generate the necessary and correct input data for tariff filings;

    rd? 3 Party applications must be updated for any changes in FERC filing requirements or

    format changes; and

    ? A web-based interface e-Tariff filing system would need standards for submission of

    tariff provisions or sheets to enable management of tariff sheets after receipt.

    In addition, Mr. Pierce noted that a web-based interface e-Tariff filing system would likely have

    longer upload and download times than the Distributed Software. FERC internal software is

    not set up to work with a web-based interface e-Tariff filing system at this time and would have

    to be modified to do so. The current FERC NOPR in effect at this time was written for the

    development of the Distributed Software, so either a new NOPR or modifications to the current

     1 Docket No RM05-1-000 “Notice of Proposed Rulemaking, Prototype Testing, and Technical Conference”, July 8, 2004.

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    North American Energy Standards Board

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NOPR would have to be issued if a web-based interface e-Tariff filing system were to be


    Mr. Pierce stated that he had reviewed the INGAA presentation and that the proposal was in

    line with what FERC Staff thinks the final product, conceptually, would look like if it is the

    consensus to develop a web-based e-Tariff filing system.

    5. Comments from Association of Oil Pipelines

    Mr. Milbourne was the speaker on behalf of Association of Oil Pipelines (AOPL). The comments

    are posted in their entirety on the NAESB e-Tariff page: Comments from the Association of Oil

    Pipelines (AOPL).

    To summarize Mr. Milbourne’s comments, AOPL supports the FERC’s electronic tariff filing

    initiative. AOPL shares the FERC’s goals as expressed in the e-Tariff NOPR (RM01-5-00). It is

    AOPL’s position that the benefits of an e-Tariff filing solution must outweigh the burdens. Mr.

    Milbourne emphasized several differences between oil pipeline tariff filings and tariff filings for

    the gas and electric industries. AOPL supports an alternative to an e-Tariff filing solution for

    oil pipelines: to continue to allow oil pipelines to submit tariff filings electronically in PDF

    format using the existing eFiling system. He disagreed with the FERC proposed eTariff

    software. By contrast, he noted the positive attributes of the Commission’s current eLibrary system, including that it keeps documents intact, allows them to be submitted in native format

    or as PDF files, and lets everyone see the same document as what was submitted. Oil

    companies would like an electronic service option.

    Mr. Milbourne stated that members of AOPL are concerned about how the e-Tariff effort will

    proceed. He and other members of the industry are not familiar with NAESB and the NAESB

    process. He noted that the oil pipeline industry is different from the other FERC regulated

    industries. The oil pipeline tariffs are very simple. AOPL and its members do not want an e-

    Tariff filing system to result in requirements that would be overly burdensome for the oil

    pipeline industry when compared to current oil pipeline tariff filing requirements.

    Mr. Buccigross noted that NAESB’s scope does not provide for development of standards for oil

    pipelines. NAESB develops business practice standards for the electric and natural gas

    industries. All NAESB standards are voluntary. Only when a jurisdictional entity, such as

    FERC, chooses to adopt NAESB standards as regulations would an organization regulated by

    the FERC be required to comply with NAESB standards. Mr. Buccigross added that he hoped

    that whatever standards are developed in the e-Tariff effort would not be inconsistent with the

    needs of the oil pipeline industry.

    Mr. Milbourne asked FERC Staff whether the FERC would go through its NOPR process for any

    e-Tariff standards submitted by NAESB. Mr. Goldenberg stated that should NAESB submit e-

    Tariff standards to the FERC, if the FERC chose to adopt those standards, the FERC would

    issue a supplemental NOPR to incorporate the standards by reference and ask for comment on

    the new standards.

    6. Comments from Interstate Natural Gas Association of America

    Mr. Kirk was the speaker on behalf of the Interstate Natural Gas Association of America

    (INGAA). The comments are posted in their entirety on the NAESB e-Tariff page: Comments

    from INGAA.

    To summarize Mr. Kirk’s comments, INGAA supports an e-Tariff filing process. It is INGAA’s

    position that “the transition to e-Tariff should be as simple, efficient and least costly to the industry as possible”. The use of sheet-based tariffs should be maintained and gas pipelines

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    North American Energy Standards Board

    1301 Fannin, Suite 2350, Houston, Texas 77002

    Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail:

     Home Page:

should be allowed to continue to use their existing tariff management programs independent of

    the oil and electric industries, while adapting for the metadata required to implement an

    electronic tariff filing process.

    INGAA proposed a solution that would result in a modification to the FERC Online eFiling

    system using an XML similar format for submission of metadata. Other filing documents

    would be filed in native format. In addition, Applicants would submit a PDF version of the

    filing in its entirety to be posted on the FERC eLibrary. Notification of filing acceptance and

    notification of orders would be made via e-mail. The posted INGAA comments include

    additional detail of an e-Tariff Filing Architecture Proposal. Mr. Kirk noted that the proposal

    leaves many details yet to be developed and was intended to serve as general guidance. He

    added that INGAA and its members have expended considerable time and effort to assist the

    FERC Staff in the development of an electronic tariff filing system and are committed to

    continue with that support.

    7. Comments from EEI

    Mr. Bartholomot, Ms. Key, Mr. Hairston, and Mr. Lotto were speakers on behalf of the Edison

    Electric Institute (EEI). The presentation used by EEI is posted on the NAESB e-Tariff page:

    EEI Presentation. EEI also submitted two additional work papers to aid in their comments: EEI Sample Tariff in Two Views and EEI Essential Elements Analysis.

    Mr. Bartholomot stated that EEI supports FERC’s goal of receiving documents electronically.

    He stated that the eLibrary and eFiling systems the Commission currently uses for most other

    filings are dependable, efficient, and easy to use. EEI supports making revisions to the current

    eLibrary and eFiling systems to achieve the goals of the Commission receiving tariffs and

    related documents electronically. Mr. Bartholomot stated that EEI and its members have

    repeatedly tested the eTariff Distributed Software over time and have come to the conclusion

    that the Distributed Software simply is not workable. EEI has included in its presentation an

    overview of an alternative approach to the Distributed Software that uses the eLibrary and

    eFiling systems to receive electronic filing of tariffs and the related documents and organizes

    those documents in a way that can be searched and maintained by the FERC.

    Ms. Key stated that the database should be used to locate tariffs and related documents, not to

    create the documents themselves. Ms. Key noted that the documents in question; namely

    tariffs and related documents, are meant to serve as stand-alone legal documents. The

    database FERC uses to maintain these documents should not have any impact on the effect of

    the documents and the documents should not be linked to each other to give the appearance

    that the documents are not stand-alone documents. Ms. Key stated that in most cases, when

    the documents are created they are e-mailed, redlined, commented on and finalized in most

    cases in Microsoft Word? format. Technology now provides the ability to search text in a PDF

    formatted document and in scanned documents using OCR software. Ms. Key stated that

    eLibrary currently has 20-30 pieces of metadata associated with filed documents. Simple

    enhancements to the current eLibrary system that add the fields of metadata that are needed

    would be sufficient to meet the FERC’s goals to update the FERC tariff filing and maintenance

    system. The e-Tariff Distributed Software would require the industry to disaggregate

    documents into smaller sections of text and then put the sections back together to be viewed or

    printed, creating substantial unnecessary work and leading to confusion. When industry

    participants tested the Distributed Software it often took hours to input the information.

    Mr. Lotto noted that he spent hours trying to import a table in his existing tariff into the

    Distributed Software. The document posted for this meeting titled “EEI Sample Tariff in Two Views” shows a snapshot of a page of Southern California Edison’s tariff viewed using Adobe

    WEQ and WGQ e-Tariff Meeting Final Minutes February 1, 2007

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    North American Energy Standards Board

    1301 Fannin, Suite 2350, Houston, Texas 77002

    Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail:

     Home Page:

Acrobat Reader?. The second slide shows a snapshot of the same page of Southern California

    Edison’s tariff viewed using the public viewer of the Distributed Software. Mr. Lotto stated that

    he was unable to format the table so that it could be viewed correctly.

    Mr. Hairston stated that the goal of this effort is to have a database to be used by FERC Staff

    and the affected industries to include each utility’s tariffs, rates, and rate schedules. The

    proposal presented by EEI would result in the modification of the eFiling and eLibrary systems

    to include the metadata fields FERC Staff deems necessary. The EEI proposal would change

    the advanced search capabilities on the FERC website to enable an eLibrary user to search

    documents. Mr. Hairston stated that it is more feasible to adopt the EEI proposal instead of

    the FERC Distributed Software because:

    ? eFiling and eLibrary are widely used by the industry today;

    ? the eFiling and eLibrary currently contain more than a decade’s worth of filings and

    interventions that are linked to the existing and previous tariffs;

    ? many of the metadata elements included in the work paper provided by FERC Staff for

    this meeting already exist in the FERC eLibrary; and

    ? modifications to eFiling and eLibrary would be easy to implement: changes could made

    without undue delay.

    Mr. Hairston reviewed EEI’s proposal for modifying the current eFiling and eLibrary systems.

    Mr. Buccigross asked the EEI speakers to identify the common points of the EEI and INGAA

    proposals. Mr. Hairston stated that both proposals would provide the ability to file an

    agreement and retrieve a current version. Both proposals also concluded that using the

    current eFiling and eLibrary systems with some modifications would be the most efficient way

    to obtain the metadata FERC Staff is seeking. Mr. Bartholomot stated that the EI, INGAA and

    AOPL presentations all support the eFiling and eLibrary systems already in place.

    Mr. Kirk stated that both INGAA and EEI support using FERC Online as the portal and using

    the eFiling system as the interface. Mr. Kirk added that INGAA’s proposal would accommodate FERC Staff’s desire to have a tariff management system so filing would be submitted through

    the FERC Online portal to be loaded into the FERC database, but would also include the ability

    to attach a PDF version of the filing for posting on eLibrary.

    Mr. Milbourne stated that the oil pipeline industry shares the concerns of EEI about the e-

    Tariff Distributed Software. Mr. Milbourne added that AOPL does not support the use of the

    Distributed Software to create the document because it would be interruptive to business

    process when trying to create and approve documents to be filed with the FERC. AOPL and its

    members do not support the requirement to disaggregate the document and support filing as a

    finished product. AOPL supports using either eLibrary or a separate customer database. Mr.

    Milbourne added that there should be a way to determine what metadata needs to be collected

    and at what level the metadata should be attached without undue difficulty.

    8. Comments from Texas Pipeline Association

    Mr. Baskin was the speaker on behalf of the Texas Pipeline Association (TPA). The comments

    of the TPA are posted in their entirety on the NAESB e-Tariff page: Comments from Texas

    Pipeline Association. Mr. Baskin provided an overview of the filing requirements for intrastate

    pipelines providing 311 services. Mr. Basking stated that TPA supports an electronic filing

    system that accommodates the differences in filing requirements that would not result in

    burdensome filing requirements for intrastate pipelines. He noted that the system needs to

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    North American Energy Standards Board

    1301 Fannin, Suite 2350, Houston, Texas 77002

    Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail:

     Home Page:

    accommodate documents in native format, including Word. Mr. Baskin concluded his remarks by stating that the TPA hopes to work with the participants to “develop a system that will work for all stakeholders without unduly burdening any one of the stakeholders.”

    9. Plan for Addressing Needs of Industry and FERC

    Mr. Buccigross stated that NAESB will publish a calendar of meeting dates. The meetings could take place in Houston unless someone volunteers to host elsewhere. Mr. Buccigross provided an overview of the NAESB process and noted that all NAESB meetings are accessible by phone and when applicable web conferencing. For the next meeting, NAESB will post a presentation that describes the NAESB process in graphic format. The effort will be assigned to a cross quadrant subcommittee of the WEQ and WGQ. The subcommittee will develop the standards. The final product will be posted as a recommendation for thirty day comment period during which any interested party can submit comments. After the expiration of the comment period, the WEQ and WGQ Executive Committees will consider all comments and vote on the recommendation. The Executive Committee voting requirement for adoption of standards requires a super majority vote. The Executive Committees can modify the standards based on discussion and comments. If the Executive Committees adopt standards, the standards are posted for a thirty day member ratification ballot. All members of the WEQ and WGQ will be eligible to vote on the ratification ballot. The standards the become Final Actions and are filed with the FERC.

    Ms. Grimm asked whether FERC Staff would set forth the requirements they need for the e-Tariff metadata elements, etc. before the NAESB Subcommittee drafts standards that may or may not meet FERC Staff’s requirements. Mr. Pierce stated that the standards and

    requirements that are needed will vary depending on the platform the industries choose to move forward. Mr. Pierce stated that the document FERC Staff submitted as a work paper for this meeting focused on filing of tariffs.

    Mr. Milbourne stated that while the members of AOPL are free to attend NAESB meetings and free to make comments, members of AOPL do not have a place within NAESB to vote on standards. In addition members of AOPL do not have the resources to attend numerous meetings. In light of the simple nature of the oil pipeline tariffs and tariff filings, AOPL and its members are concerned about an end result that would require a burdensome filing process for oil pipelines that does not exist today. Mr. Buccigross stated that any standards ratified by NAESB are voluntary. NAESB does not have the ability to require that any organization, whether member or non-member, comply with its standards. Assuming standards are adopted for this effort, they will be filed with the FERC. It will be the decision of the FERC whether to require industries to comply with the standards submitted by NAESB through incorporation into the Federal Regulations. It is likely that the FERC would propose to incorporate the standards through the NOPR process, which would provide the oil pipeline industry the ability to submit comments.

    Mr. Goldenberg stated that FERC Staff is willing to work with NAESB to move forward with this electronic tariff effort. FERC Staff plans on attending some of the meetings. Mr. Goldenberg stated that the requirements should include a method to create an effective tariff from sheets, and should include the ability to see the historical status to show what the tariff language was at a particular point in time. Mr. Goldenberg noted that for smaller kinds of tariffs and contracts FERC would be willing to accept the entire filing as one sheet. That type of filing would not be acceptable for the typical gas pipeline tariffs or ISO and RTO tariffs.

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    Ms. Nagle asked if the electric tariffs and gas tariffs have to use the same platforms. Mr. Pierce stated that FERC does not have the desire to support five different filing and database management systems.

    Mr. Bartholomot asked whether the proposed eLibrary application would be considered by FERC Staff. Mr. Goldenberg stated that the problem with using eLibrary is that eLibrary maintains documents filed for the entirety of the document. He stated that if everyone agreed to file the entire tariff every time a tariff filing is made, then eLibrary may be a solution. He stated that he did not think that entities would want to file the entire tariff each time a modification is requested. Mr. Bartholomot noted that EEI members who have been working on this issue are willing to do so.

    Ms. Nagle asked whether FERC Staff supported using a section-based tariff system (in lieu of a sheet based system) and if so does everyone need to move to the section-based system. Mr. Pierce stated that FERC Staff does not prefer one method over the other. Mr. Pierce added that the INGAA presentation is similar to what FERC Staff would be willing to accept as long as the metadata needed is included.

    Ms. Van Gordon stated that FERC Staff wants to be able to reference the page before and the page after the proposed revision. The goal is to create a baseline tariff in the software. Ms. Van Gordon asked if eLibrary could be modified to include the baseline and then include the sheet-by-sheet filings, noting that the Staff’s eTariff approach is not efficient. Mr. Pierce stated

    that eLibrary is an archival database not designed to be a dynamic database. He stated that the task of the NAESB Subcommittee is to create the appropriate metadata standards to create filings. FERC Staff maintains the decision on how they will process the data using downstream software and the database maintenance remains with FERC. FERC Staff also maintains the determination of how to provide the information to the public. Mr. Goldenberg added that FERC Staff is not fixed on using the Distributed Software, but once the industry determines how the information will be submitted, FERC Staff will determine what will be done with the information.

    Mr. Milbourne reiterated AOPL concerns about the FERC electronic tariff filing process being kept simple, oil companies not being part of the NAESB process, and oil companies being able to submit their tariffs in their entirety as PDF files using eFiling/eLibrary.

    Ms. Key advocated that metadata should be required only at the full document level. Ms. Van Pelt stated that NAESB standards govern the relationship between parties in the industry or the performance and expectations. NAESB standards do not typically affect the relationship between a regulatory body and parties in the industry. She stated that Panhandle Eastern Pipe Lines thought that NAESB would take on an administrative role to bring parties together for this effort rather than act as a standards setting body. She stated that when the Docket for e-Tariff was included as a Provisional Item on the WGQ 2007 Annual Plan it was an effort to be responsive to what came out of the FERC Docket. She asked whether NAESB could act as a facilitator rather than seeking to set standards. There was no discussion to address Ms. Van Pelt’s concerns.

    10. Organization, Tasks and Assignments

    After further discussion, Mr. Buccigross stated that a series of meetings would be scheduled with the first meeting taking place no sooner than one month from now. Mr. Bartholomot volunteered EEI to host one of the meetings. All meetings will be accessible via phone and web conference.

    Mr. Buccigross stated that the WEQ and WGQ would form a joint subcommittee for this effort.

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11. Next Steps and Meetings

    NAESB will work with those who volunteer to host meetings to schedule several meetings with

    the next meeting to be no sooner than one month from today. NAESB will post a call for work

    papers once the next set of meetings is scheduled.

    12. Adjournment

    The meeting adjourned at 3:23 PM Eastern.

    13. Attendees in Person

    Attendee Organization

    Michael Alexander Duke Energy

    Marianne Alvarez Exelon Corporation Pat Barry Northern Natural Gas Henri Bartholomot Edison Electric Institute Lee Baskin Kinder Morgan & Texas Pipeline Association

    Louise Bradford Panhandle Energy Pipelines Mary Brosnan NiSource

    Jim Buccigross 8760, Inc.

    Kathryn Burch Spectra Energy Transmission Christopher Burden Williams Gas Pipeline Jay Carriere Mid American Energy Holdings Co. Amy Castronovo Enbridge, Inc.

    Marg Carmardello Transco

    John Ciza Southern Company Generation Breanne Clarke El Paso Corporation - Western Pipelines Patty Cox CenterPoint Energy Valerie Crockett Tennessee Valley Authority John Cutting New York ISO

    Kate Daley INGAA

    Dale Davis Williams Gas Pipeline Rhonda Denton BP Energy Company Roy Dewitt El Paso Corporation - Western Pipelines Elizabeth Dieterich Entergy

    Bud Earley Allegheny Energy, Inc. Chris Folkes FERC

    Les Fyock APGA

    Michael Goldenberg FERC

    George Godding FERC

    Mark Gracey Tennessee Gas Pipeline Machelle Grim Dominion

    Jerry Gross Questar Pipeline Co.

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    Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail:

     Home Page:

KC Hairston Balch & Bingham

    Brian Hall CenterPoint Energy Maurene Hamilton Panhandle Energy Pipelines Larry Jensen Discovery/Black Marlin Brian Kaeser Dominion

    Andrea Katz Northeast Utilities

    Andrea Kells Bracewell & Giuliani Laura Kennedy NAESB

    Jennifer Key Steptoe & Johnson Steve Kirk Northern Natural Gas Sneha Kohli FERC

    Ralph Kravis Unicon

    Gary Kravis Unicon

    Len Levine Leonard B. Levine & Associates Marcus Lotto Southern California Edison Company Paul Love Natural Gas Pipeline James Mauldin FERC

    Marcy McCain Spectra Energy Transmission Rae McQuade NAESB

    Dan Mihalik AOPL

    Steve Milbourne AOPL/Buckeye Partners Jeff Molinaro Enterprise Products Lynn Myers Southern California Edison Company Molly Nagle Tennessee Gas Pipeline David Nick DTE Energy

    Casey Nutsch FERC

    Gordon Pennington Attorney for United Illuminating Keith Pierce FERC

    Mark Pierce Spectra Energy Transmission Jan Rogers Chevron Pipe Line

    Sue Rosenberg Self

    Marv Rosenberg Self

    Matthew Royalty Southern Star

    Cesar Seymour Suez Energy

    Toni Sharp Kern River Gas Transmission Demce Simpson Ameren

    Virginia Snyder PJM Interconnection Mike Stender El Paso Natural Gas Priya Swamy Dominion

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    Cindy Thompson Southern Star Central Gas Pipeline Kathy Thornton Enbridge, Inc.

    Marianna Toma Morgan Lewis & Bockius Pat Van Midde SDG&E

    Michelle Van Gordon Midwest ISO

    Kim Van Pelt Panhandle Energy Pipelines Mark Vaughn NiSource

    Marshia Youngleed Williams

    Don Zeiszler Williston Basin Pipeline

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