FYI, Kim.

 -----Original Message-----
From: 	Miller, Mary Kay  
Sent:	Friday, October 26, 2001 3:35 PM
To:	Harris, Steven; Watson, Kimberly; Lokey, Teb; Neubauer, Dave; Miller, Kent; Fossum, Drew; Pavlou, Maria; Kirk, Steve; Porter, Gregory J.; Hartsoe, Joe; Kilmer III, Robert; Williams, Jo
Subject:	Columbia Gulf order on negotiated rates

I received a copy of an order issued by the FERc on Columbia negotiated rate transaction, which includes a formula ie indexed rate.  They accepted the negotiated rate deal but they are requiring  them to file in their tariff within ONE DAY after the rate has been determined the contract and actual rate. ( Each time the actual rate changes during the term)   Just think about this for the upcoming TW_ USGT deal and NNG"- Reliant deals.    Notwithstanding the time to actually make the filing, the cost to serve it each day if the negotiated rate is different by day and then the service when an order is issued each day---  I believe this is FERC's way to attempt to eliminate negotiated rate indexed based deals-  they are punishing themselves as well, as each filing will require a notice etc-  so every day they could need to issue an order.   

I feel we need to discuss with Columbia, INGAA and join in filing for rehearing on this administrative nightmare.  An alternative would be to require you to post on Internet website the day of the transaction the actual rate, so similarly situated customers would have access to the actual rate.  I'm sending you guys a copy of the order.