Comments of Kern River Gas Transmission Co on August 1 Report of El Paso Natural Gas Co re Aera Energy LLC et al under RP00-336 et al.

Jnofflclal FERC-Generated PDF of 20020815-0094 Received by FERC OSEC 08/12/2002 in D o c k e t # : R P 0 0 - 3 3 6 - 0 0 2

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El Paso Natural Gas Company ) Docket No. RP00-336-002

Aera Energy, LLC, et al., )

Complainants )

v. ) Docket No. RP01-484-000

El Paso Natural Gas Company, )

Respondent )

Texas, New Mexico and Arizona Shippers, )

Complainants )

v. ) Docket No. RP01-486-000

El Paso Natural Gas Company, )

Respondent )

KN Marketing, L.P., )

Complainant )

v. ) Docket No. RP00-139-000

El Paso Natural Gas Company )

Respondent )

COMMENTS OF

KERN RIVER GAS TRANSMISSION COMPANY l

ON AUGUST 1 REPORT OF

EL PASO NATURAL GAS COMPANY

Kern River Gas Transmission Company ("Kern River") owns and operates a 926-

mile interstate pipeline system extending from southwestern Wyoming, through the states

of Utah and Nevada, to points of termination in Kern County, California. Kern River thus

competes with El Paso Natural Gas Company ("El Paso") in providing transportation

services to California and Nevada gas consumers and distributors. In the interest of

Kern River is not currently a party to this proceeding. Kern River filed a motion for

leave to intervene out of time on June 26, 2002, but the Commission has not yet acted on

that motion.

Jnofflclal FERC-Generated PDF of 20020815-0094 Received by FERC OSEC 08/12/2002 in D o c k e t # : R P 0 0 - 3 3 6 - 0 0 2

providing the Commission with a full spectrum of views on the issues now before it in

this proceeding, Kern River offers these comments on El Paso's August 1, 2002 report to

the Commission in response to the Commission's order of May 31, 2002. 2

Kern River urges the Commission, consistent with the approach of the May 31

Order, to keep its role in the capacity marketplace to the minimum necessary to resolve

the problems on the El Paso system that the order identified. The Commission otherwise

should allow market forces to determine the most efficient combinations of existing and

new capacity to satisfy any demand for capacity that E1 Paso's existing capacity cannot

fulfill.

El Paso's August 1 report makes clear that the Commission must decide two

questions: (1) how much of the existing capacity of the El Paso system, plus the capacity

of the Line 2000 project, is available to be allocated to El Paso's full requirements ("FR")

customers, and (2) how should that available capacity be allocated among the FR

...

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