Attached is the cite you forwarded earlier.  

----- Forwarded by Gerald Nemec/HOU/ECT on 07/06/2000 03:50 PM -----

	LEXIS(R)/NEXIS(R) Print Delivery <lexis-nexis@prod.lexis-nexis.com>
	07/06/2000 03:31 PM
		 
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		 cc: 
		 Subject: LEXIS(R)-NEXIS(R) Email Request (711:0:11094446)


                                                                         
108CKF



Print Request:   LEXSEE

Time of Request: July 6, 2000  04:31 pm EST

Number of Lines: 394
Job Number:      711:0:11094446

Client ID/Project Name:

Research Information:

Lexsee 84 FERC P61,210

Note:


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PAGE 1


                             LEXSEE 84 FERC P61,210

                      Clear Creek Storage Company, L.L.C.

                            Docket No. CP98-256-000

               FEDERAL ENERGY REGULATORY COMMISSION - COMMISSION

                     84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726

                           ORDER ISSUING CERTIFICATE

                               September 1, 1998

PANEL:
 [*1]  Before Commissioners: James J. Hoecker, Chairman; Vicky A. Bailey,
William L. Massey, Linda Breathitt, and Curt Hebert, Jr.

OPINION:

   On March 2, 1998, Clear Creek Storage Company, L.L.C. (Clear Creek) filed 
an
application pursuant to section 7 of the Natural Gas Act (NGA), for a
certificate to convert a natural gas production reservoir to a natural gas
storage facility, to construct appurtenant facilities, and to operate the
storage field and related facilities for the sole use of Clear Creek's two
owners, Questar Energy Trading Company (Questar Energy) and Montana Power
Ventures, Inc. (Montana Power). Clear Creek requests that, to the extent
feasible, the authorization granted to it be a limited jurisdiction 
certificate.
Clear Creek also requests waivers of various Commission regulations and
requirements.

   For the reasons discussed below, we will grant Clear Creek's request for
authorization to convert the production reservoir to a gas storage facility 
and
to construct and operate facilities. However, we will require Clear Creek to
operate the facility on an open access basis.

I. Background

   Questar Energy and Montana Power formed Clear Creek to own and operate the
proposed Clear Creek storage [*2]  project. Questar Energy owns 75 percent and
Montana Power owns 25 percent of Clear Creek. Questar Energy is a wholly-owned
subsidiary of Questar Corporation and a natural gas marketing affiliate of
Questar Pipeline Company, an interstate pipeline. Questar Energy engages in
marketing of natural gas, crude oil, and electricity. It purchases natural gas
from affiliated production companies and unaffiliated companies.

   Montana Power is an affiliate of Montana Power Company, an electric and gas
utility regulated by the Commission as well as the State of Montana. Montana
Power engages in natural gas business development, which will include 
purchasing
and selling natural gas upon approval of Clear Creek's application.

Clear Creek states that both Questar Energy and Montana Power plan to actively
purchase and sell natural gas in the Rocky Mountain region, and elsewhere in 
the
United States. Therefore, they both wish to develop storage capabilities to
better manage their natural gas supplies, including the balancing of their
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PAGE 2
                 84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726, *2

respective natural gas supplies and supply acquisition opportunities with
current and projected demand for natural gas. Clear Creek states that the
storage capacity will [*3]  assist Questar Energy and Montana Power to buy and
sell gas when it is most economically favorable to do so, to offer more 
reliable
supply products to potential customers, and to manage transportation 
obligations
to minimize exposure to penalties and cashout charges.

   Clear Creek proposes to locate its storage project in the depleted Nugget
reservoir in the Clear Creek Field in Uinta County, Wyoming, an active natural
gas production region. Chevron, Inc. discovered the field in 1978. The field
produced gas from 1979 until 1994 when it was shut-in after production of oil
and gas from the field was no longer economic. Prior to shut-in, 15 wells
produced natural gas that was delivered through existing pipeline facilities
into Northwest Pipeline Corporation, Kern River Gas Transmission Company, and
Questar Pipeline Company.

   Clear Creek states that the interconnecting pipeline taps, laterals,
gathering facilities and wells are still in place and, with minor 
modifications,
will be used to transport gas in and out of the proposed storage facility.

   Questar Energy has owned and operated the Clear Creek field since late 
1993,
having acquired it from its affiliate, Universal Resources Corporation [*4]
(Universal), a natural gas producer. Universal tested the field in 1996 and 
1997
and determined that the depleted oil/gas reservoir in the Nugget formation can
economically be converted to a storage project of up to 4 Bcf of working gas. 
n1
Questar Energy plans to transfer its interests in the field to Clear Creek.

- - - - - - - - - - - - - - - - - -Footnotes- - - - - - - - - - - - - - - - - 
-

   n1 Universal requested and received an exemption, pursuant to section
7(c)(1)(B) of the NGA, to test the Clear Creek field for a possible storage
project to be undertaken by it or one of its affiliates. See Universal 
Resources
Corp., 76 FERC

   P 61,002 (1996)(Docket No. CP96-528-000).

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-

II. Proposal

Clear Creek proposes to convert a reservoir in the Nugget formation in a
depleted natural gas production field in the Clear Creek Participation Area 
(PA)
of the Painter Reservoir Unit to a gas storage facility. The Clear Creek PA is
located in Uinta County, Wyoming, approximately 15 miles northeast of 
Evanston.
The proposed project would reuse facilities in place within the Clear Creek PA
from previous activities [*5]  in Sections 4 and 9 of the production field.
Lands in Section 4 are administered by the Bureau of Land Management (BLM) and
lands in Section 9 are owned privately by Uinta Livestock Grazing Partnership.

   The Nugget formation is located at an approximate depth of 8700 feet and
storage will be water driven. Clear Creek expects to operate the storage
reservoir at a pressure of approximately 3200 psi. Clear Creek proposes to
develop 4 Bcf of working storage capacity, supported by 2 to 4 Bcf of cushion
gas. Questar Energy and Montana Power will supply cushion gas in proportion to
their membership interests. The project is expected to have a maximum gas
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                 84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726, *5

injection capability of up to 35 MMcf/day (at approximately 4200 psi) and a
maximum withdrawal capability of up to 50 MMcf/day (at approximately 750 psi).

   Clear Creek states that it will own and be responsible for operating the
storage project. Under the Construction, Operation and Management Agreement
between Clear Creek, Questar Energy and Montana Power, Clear Creek will 
contract
with Questar Energy to operate the field on a day to day basis.

   A. Facilities

   Clear Creek states that conversion of the field to storage will require
minimal construction [*6]  and will enable it to maximize the use of existing
facilities that were installed in connection with previous exploration and
production activity at the field.

   Clear Creek proposes to use a single, existing well (#44-4) for injections
and withdrawals and up to 8 existing wells for monitoring. Clear Creek expects
to use the existing roads, pipeline facilities, buildings, fencing,
rights-of-way, pads, and cleared areas, and some of the existing storage 
tanks.

   Clear Creek proposes to install the following new facilities:

   two 2100-hp compressors (possibly leased), which will be installed in an
existing building designed and historically used for compressors;

   one Joule-Thompson Liquid Extraction Plant (skid mounted), which will be
located in an already cleared, fenced site;

   new insulation, wrapping and electric heat tracing for the existing
injection/withdrawal line that connects the injection/withdrawal well to the
compressor building;

   one 30,000-gallon natural gas liquids storage tank, located in an existing
cleared, fenced site;

   a skid-mounted production unit to separate water and free hydrocarbon 
liquids
from the production stream during withdrawal operations;

   two additional 400-barrel [*7]  water tanks, to be located in pre-disturbed
sites;

   new 3.5-inch tubing in the injection/withdrawal well, #44-4, inside the
existing 5.5-inch casing; and communications and monitoring equipment.

   Clear Creek anticipates that it also will be necessary to modify existing
pipeline facilities that connect the field to Questar Pipeline. Clear Creek
expects Questar Pipeline to replace, under its blanket construction 
certificate,
approximately 50 feet of 4-inch pipe and meter run with an equivalent length 
of
6-inch pipe and meter run. Clear Creek requests authority to modify its line
connected to the Clear Creek Field to accommodate those modifications by 
Questar
Pipeline.

   Clear Creek states that, historically, gas was delivered from the field 
into
Questar Pipeline, and was received from and delivered back to Questar Pipeline
during Universal's well tests. Clear Creek submits that, in the future, it
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                 84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726, *7

expects to receive gas from and deliver gas to other pipelines in the area,
including Northwest Pipeline Corporation and Kern River. However, Clear Creek
does not seek approval at this time to construct any facilities necessary to
implement these additional receipt and delivery points.

   B. Services [*8]

   Clear Creek proposes to render storage services solely for its two members,
Questar Energy and Montana Power, which will receive storage capacity rights 
in
direct proportion to their ownership interests, i.e., Questar Energy will have
use of 75 percent of the field's storage capacity and Montana Power will have
use of 25 percent of the capacity. Questar Energy and Montana Power will also
have firm use of injection and withdrawal capabilities totaling 35 MMcf/d and 
50
MMcf/d, respectively, on a percentage basis equal to the share of storage
capacity rights. Each will have a right to unused injection and withdrawal
capabilities on an interruptible basis.

Clear Creek proposes to provide no storage service to any entity other than 
its
owners. Questar Energy and Montana Power will each own and store its own gas 
in
the capacity it holds.

   C. Requested Waivers

   Clear Creek states that it neither requests nor desires a blanket 
certificate
to transport for others. Therefore, Clear Creek requests the Commission to 
waive
any requirement that the proposed project be operated on an open access basis.

   Clear Creek submits that its proposal is different from the situations
presented in two cases,  [*9]  Total Peaking Services, L.L.C. (Total Peaking) 
n2
and Hopkinton LNG Corporation (Hopkinton), n3 in which the Commission rejected
private storage proposals involving existing liquid natural gas (LNG) 
facilities
belonging to local distribution companies (LDCs) and required the applicants 
to
provide open access storage. Unlike those cases, Clear Creek maintains, its
proposed project is not located in a market area but in a supply area 
surrounded
by both major production areas and major interstate pipelines. In addition, 
the
reservoir Clear Creek proposes to convert to storage was not previously
developed by a regulated LDC or any other form of regulated entity and thus
there are no risks of cross-subsidies by ratepayers. Further, submits Clear
Creek, there are no concerns about an affiliated LDC engaging in capacity
brokering to deliver gas to or from market area LNG plants, a unique market
advantage described by the Commission in Total Peaking.

- - - - - - - - - - - - - - - - - -Footnotes- - - - - - - - - - - - - - - - - 
-

   n2 81 FERC P61,246 (1997).

   n3 81 FERC P61,291 (1997).

- - - - - - - - - - - - - - - - -End Footnotes- - - - - - - - - - - - - - - - 
-
[*10]

   Further, Clear Creek argues, its proposal is for a small, low budget 
project
which cannot readily be increased in size to accommodate new demands for 
storage
from a third-party without a great increase in associated costs and, to a 
lesser
extent, environmental consequences. Clear Creek also maintains that dilution 
of
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PAGE 5
                 84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726, *10

the quantity of storage available to Questar Energy and Montana Power would
undermine their incentives to proceed. Clear Creek states that the project's
costs would increase due to the sizable regulatory burdens associated with
preparing and maintaining tariffs, ratemaking, utility-based accounting
practices, reporting, GISB, EBBs, additional personnel, and 
marketing-affiliate
rules requiring separation of Clear Creek from its two marketer owners. 
Further,
it contends, an open access requirement would expose it to economic risks and
third-party liability issues such as risks of gas loss, force majeure, project
failure, and credit that do not exist for a project that would only serve its
two owners.

Accordingly, Clear Creek requests waivers of all reporting requirements,
including the obligation to file Form 2 or similar reports; any obligation to
file rates, tariffs,  [*11]  contracts, or contract amendments; any obligation
to justify rates on any basis other than those the parties negotiated as part 
of
the Agreement; any obligation to follow the Uniform System of Accounts; any
obligation to adhere to GISB standards or to maintain an EBB; any obligation 
to
separate personnel or otherwise to adhere to marketing affiliate rules as they
might otherwise apply to the relationship between Clear Creek and its owners; 
n4
and any other rules or requirements that would otherwise apply to an open 
access
pipeline or storage company.

- - - - - - - - - - - - - - - - - -Footnotes- - - - - - - - - - - - - - - - - 
-

   n4 Clear Creek acknowledges that Questar Energy would remain subject to the
marketing affiliate rules as they apply to its dealings with Questar Pipeline
Co.

- - - - - - - - - - - - - - - - -End Footnotes- - - - - - - - - - - - - - - - 
-

III. Interventions

   Notice of Clear Creek's application was published in the Federal Register 
on
March 24, 1998 (63 Fed. Reg. 14077). Colorado Interstate Gas Company, Natural
Gas Clearinghouse, Northwest Pipeline Corporation, and Questar Pipeline 
Company
filed timely motions to intervene.  [*12]  n5 No protests were filed.

- - - - - - - - - - - - - - - - - -Footnotes- - - - - - - - - - - - - - - - - 
-

   n5 Timely, unopposed motions to intervene are granted by the operation of @
385.214(c)(1) of the Commission's regulations.

- - - - - - - - - - - - - - - - -End Footnotes- - - - - - - - - - - - - - - - 
-

IV. Discussion

   A. Jurisdiction

   Since the proposed facilities will be used for the transportation of 
natural
gas in interstate commerce subject to the Commission's jurisdiction, the
requested authorization is subject to section 7(c) of the NGA.

   B. Public Convenience and Necessity

   Order No. 636 n6 was designed to encourage interstate pipelines to provide
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PAGE 6
                 84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726, *12

unbundled, open-access transportation. Clear Creek proposes that the 
Commission
make an exception for its storage proposal, and not require it to provide open
access storage services. As we stated in Hopkinton and Total Peaking, we find
that such proposals are not in the public interest.

- - - - - - - - - - - - - - - - - -Footnotes- - - - - - - - - - - - - - - - - 
-

   n6 Pipeline Service Obligations and Revisions to Regulations Governing
Self-Implementing Transportation; and Regulation of Natural Gas Pipelines 
After
Partial Wellhead Decontrol, 57 Fed. Reg. 13,267 (April 16, 1992), III FERC
Stats.

   & Regs. Preambles P 30,939 (April 8, 1992); order on reh'g, Order No. 
636-A,
57 Fed. Reg. 36,128 (August 12, 1992), III FERC Stats. & Regs. Preambles P
30,950 (August 3, 1992); order on reh'g, Order No. 636-B, 57 Fed. Reg. 57,911
(December 8, 1992), 61 FERC P61,272 (1992); reh'g denied, 62 FERC P61,007 
(1993)
remanded in part sub nom., United Distribution Co. v. FERC, 88 F.3d 1105 (D.C.
Cir. 1996), order on remand, Order No. 636-C, 78 FERC P61,186 (1997); cert.
denied, 117 S. Ct. 1723 (1997).

- - - - - - - - - - - - - - - - -End Footnotes- - - - - - - - - - - - - - - - 
-
[*13]

   Clear Creek seeks to distinguish its proposal from those in Hopkinton and
Total Peaking by noting that, unlike those two proposals, its proposed storage
facility is not in the market area and does not raise cross-subsidization or
capacity brokering issues. We recognize that those issues are not present in
Clear Creek's proposal. Nevertheless, its proposal is the same in one 
overriding
aspect. Clear Creek seeks authorization to perform jurisdictional interstate
transportation with no requirement that such service be offered on an
open-access basis. Such proposals are inconsistent with the regulatory goals
embodied in Order No. 636, which was intended to encourage interstate 
pipelines
to provide open-access services, including storage. Therefore, we will require
Clear Creek to restructure its proposal into one that is consistent with the
principles of Order No. 636. Specifically, we will issue Clear Creek a Part 
284
blanket transportation certificate conditioned on Clear Creek's filing, within
60 days of the date of issuance of this order, a revised Exhibit P to its
application, setting forth its proposed tariff and initial rates along with
supporting schedules for open-access firm [*14]  and interruptible storage
service and storage-related transportation that comply with the requirements 
of
Part 284 and with the Commission's restructuring rules as expressed in Order 
No.
636.

   To the extent Clear Creek seeks to charge market-based rates, it must make 
a
showing that it lacks market power. The Commission has issued several orders
that provide guidance on the criteria it uses to evaluate market-based rate
proposals. n7 In addition, an applicant's market-based study should be
consistent with the Commission's policy statement on ratemaking n8 and must
show, among other things, that: (a) the relevant market provides good
alternatives to the applicant and is not defined too broadly; (b) the
alternatives are timely; (c) the applicant is not able to exercise market 
power
over the price of the product; and (d) the quality of service is equivalent.
Clear Creek should provide this information in the tariff filing required 
above.

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-
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PAGE 7
                 84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726, *14


   n7 New York State Electric & Gas Corporation (NYSEG), 81 FERC P61,020 
(1997);
Moss Bluff Hub Partners, L.P., 80 FERC P61,181 (1997); Egan Hub Partners, 
L.P.,
77 FERC P61,016 (1996); and K N Interstate Gas Transmission Company, 76 FERC
P61,134 (1996).  [*15]

   n8 Alternatives to Traditional Cost-of-Service Ratemaking for Natural Gas
Pipelines, 76 FERC P61,076 (1996).

- - - - - - - - - - - - - - - - -End Footnotes- - - - - - - - - - - - - - - - 
-

   Clear Creek requests a limited jurisdiction certificate. The Commission
issues such certificates to allow nonjurisdictional parties to engage in 
certain
jurisdictional activities without affecting the status of their otherwise
nonjurisdictional activities. Since Clear Creek's sole function is to provide
interstate storage services, there is no need to issue Clear Creek a limited
jurisdiction certificate. However, we clarify that the authorization granted 
to
Clear Creek will not affect the nonjurisdictional status of Questar Energy or
Montana Power.

   Because we are approving a Part 284 blanket certificate rather than the
limited jurisdiction certificate Clear Creek requested, Clear Creek must 
comply
with the accounting and reporting requirements applicable to other natural gas
companies providing Part 284 service. Accordingly, we deny Clear Creek's 
request
for waiver of those requirements.

   We will not require Clear Creek to hold an open season since it has
agreements [*16]  with Questar Energy and Montana Power for all of the 
capacity
of its proposed storage facility and no party has protested the arrangement.
Clear Creek's concern that an open- access requirement for its storage 
facility
would require it to enlarge its project is unfounded. There is no requirement 
to
offer more capacity than exists or to increase a facility's capacity to
accommodate potential customers. An open-access transporter need only offer on
an open-access basis existing capacity for which it has no contracts. In this
regard, we note that the agreement between Clear Creek and its two owners is 
for
all of the existing capacity for a term of twenty years.

   Finally, we note that Clear Creek may apply for a Part 157 blanket
certificate under which it could undertake future modifications to the storage
facilities and operations.

   C. Engineering

   The Commission has evaluated Clear Creeks's proposal and concludes that the
development of the Clear Creek reservoir as an underground gas storage field 
is
feasible. We also evaluated the proposed storage design, facilities, capacity
and injection/withdrawal estimates and do not foresee any technical problems
regarding the development of this [*17]  field.

   Accordingly, in view of these circumstances, we will require that:

   1. The maximum inventory of natural gas stored in Clear Creek shall not
exceed 8.0 Bcf at 14.73 psia and 60 degrees F, and the maximum shut-in bottom
hole reservoir pressure shall not exceed 5500 psig, without prior Commission
authorization; and
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PAGE 8
                 84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726, *17


2. Clear Creek shall submit semiannual reports in accordance with section
157.214(c) of the regulations. These reports shall continue to be filed until
one year after the storage inventory volume has reached or closely 
approximates
8 Bcf.

 D. Environmental Assessment


   The Commission prepared an environmental assessment (EA) for Clear Creek's
proposal. The EA addresses construction procedures, geology, soils, water
resources, wetlands, vegetation, wildlife, hydrostatic testing, federally 
listed
threatened and endangered species, cultural resources, land use, air and noise
quality, and alternatives.

   Based on the discussion in the EA, we conclude that if constructed in
accordance with Clear Creek's application and supplements filed on April 8 and
May 20, 1998, approval of this proposal would not constitute a major Federal
action significantly affecting the quality [*18]  of the human environment.

   As recommended in the EA, this authorization includes the following
conditions:

   1. Clear Creek shall follow the construction procedures and mitigation
measures described in its application and supplements (including responses to
staff data requests) and as identified in the EA. Clear Creek must:

   a. request any modifications to these procedures, measures, or conditions 
in
a filing with the Secretary of the Commission;

   b. justify each modification relative to site- specific conditions;

   c. explain how that modification provides an equal or greater level of
environmental protection than the original measure; and

d. receive approval in writing from the Director of Office of Pipeline
Regulation (OPR) before using that modification.

   2. The Director of OPR has delegated authority to take whatever steps are
necessary to ensure protection of all environmental resources during
construction and operation of the project. This authority shall allow:

   a. the modification of conditions of this Order; and b. the design and
implementation of any additional measures deemed necessary (including stop 
work
authority) to assure continued compliance with the intent of the environmental
[*19]  conditions as well as the avoidance or mitigation of adverse
environmental impact resulting from project construction and operation.

   Any state or local permits issued with respect to the jurisdictional
facilities authorized herein must be consistent with the conditions of this
certificate. The Commission encourages cooperation between natural gas 
companies
and local authorities. However, this does not mean that state and local
agencies, through application of state or local laws, may prohibit or
unreasonably delay the construction or operation of facilities approved by 
this
Commission. n9
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PAGE 9
                 84 F.E.R.C. P61,210; 1998 FERC LEXIS 1726, *19


- - - - - - - - - - - - - - - - - -Footnotes- - - - - - - - - - - - - - - - - 
-

   n9 See, e.g., Schneidewind v. ANR Pipeline Co., 485 U.S. 293 (1988); 
National
Fuel Gas Supply v. Public Service Commission, 894 F.2d 571 (2d Cir. 1990); and
Iroquois Gas Transmission System, L.P., et al., 52 FERC P61,091 (1990) and 59
FERC P61,094 (1992).

- - - - - - - - - - - - - - - - -End Footnotes- - - - - - - - - - - - - - - - 
-

   Clear Creek shall notify the Commission's environmental staff by telephone
[*20]  or facsimile of any environmental noncompliance identified by other
Federal, state, or local agencies on the same day that such agency notifies
Clear Creek. Clear Creek shall file written confirmation of such notification
with the Secretary of the Commission within 24 hours.

   At a hearing held on September 1, 1998, the Commission on its own motion
received and made part of the record in this proceeding all evidence, 
including
the application, supplements, and exhibits thereto, submitted in support of 
the
authorization sought herein, and upon consideration of the record,

The Commission orders:

   (A) A certificate of public convenience and necessity is issued authorizing
Clear Creek to construct and operate the proposed storage and related pipeline
facilities as described in this order and more fully in the application.

   (B) A blanket certificate of public convenience and necessity is issued
pursuant to section 284.221 of the Commission's regulations to Clear Creek
authorizing it to perform the activities specified in Part 284, Subpart G, of
the regulations conditioned on Clear Creek's filing, within 60 days of the 
date
of issuance of this order, tariff provisions setting forth terms  [*21]  and
conditions and rates for open-access firm and interruptible storage service 
and
storage-related transportation.

   (C) The certificate issued in ordering paragraph (A) is conditioned on 
Clear
Creek's compliance with the Commission's Regulations including Part 154, 157 
and
284 and paragraphs (a), (c), (e), and (g) of the section 157.20 of the
Commission's Regulations.

   (E) Clear Creek is required to complete the facilities and place them in
service within one year from the date of this order.

   (F) The authorization granted in ordering paragraph (A) is conditioned on
Clear Creek's compliance with the environmental and engineering conditions set
forth in this order.

   (G) Clear Creek shall notify the Commission's environmental staff by
telephone and/or facsimile of any environmental noncompliance identified by
other Federal, state, or local agencies on the same day that such agency
notifies Clear Creek. Clear Creek shall file written confirmation of such
notification with the Secretary of the Commission within 24 hours.

By the Commission.
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108CKF
**********  Print Completed  **********

Time of Request:   July 6, 2000  04:31 pm EST

Print Number:      711:0:11094446
Number of Lines:   394
Number of Pages:   9
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