Attached is a draft of our rehearing request on the order FERC issued in RM01-9 requiring sellers of gas into California to file information on their sales, transport, and purchases.  The rehearing request restates our arguments in response to the NOPR  that (1) permanent, formal reporting requirements are not appropriate to address a temporary problem and are beyond the scope of the Commission's powers under the Natural Gas Act and (2) the commission significantly underestimated the burden of the reporting requirements as well as the responding parties' ability to comply.  We also request that the reports, if they must be submitted, be due 45 days after the end of the month instead of the required 30 days.
Please provide any comments or suggestions you may have on this draft to either myself (713-853-5840) or Leslie (505-623-6778) by COB Wednesday (8/22).  
 

Thanks.