MEMORANDUM

TO: Regulatory Affairs Committee
      Gas Issues Working Group

FROM: Jim Steffes, Regulatory Affairs Committee Chair
           John Orr, Gas Issues Working Group Chair
           Julie Simon, Vice President of Policy
           Jack Cashin, Senior Manager of Policy

DATE: 11/9/2001

RE: EPSA Draft Comments on Pipeline Capacity Recall
      NOPR
?			Comments due November 19th
?	Conference Call November 14th
?
As discussed on the last Gas Issues Working Group conference call, attached are draft EPSA comments on FERC's Notice of Proposed Rulemaking (NOPR) on pipeline capacity recall.  EPSA opposes the NOPR because it (a) will reduce competition in the secondary market for transportation services and (b) may reduce the pipeline operational flexibility needed by electric generators.   Thus, EPSA urges the Commission not to impose a broad based recall requirement throughout the natural gas industry but rather gain experience with this difficult issue in individual Order No. 637 proceedings.

Please review the draft and forward any comments or proposed changes to the draft to Jack Cashin at EPSA at jcashin@epsa.org by noon on Thursday, November 15th so that we can make a timely filing by Monday, November 19th.  EPSA will hold a conference call on Wednesday, November 14th, at 1:00 P.M. (EST) to discuss the draft.  To access the call, dial 1-800-937-6563.  Ask for the Jack Cashin/EPSA Call.

Attachment



 - GasDayaheadRechallNOPR DRAFT.DOC