Motion/Notice of Intervention of Southwest Gas Corporation re Northwesy Pipeline Corp under RP03-89.

# UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Complaint of Reliant Energy Services, Inc.)Docket No. RP03-77-000 vs. ) Florida Gas Transmission Company ) MOTION TO INTERVENE AND COMMENT OF CALPINE ENERGY SERVICES, L.P. On November 15, 2002, Reliant Energy Services, Inc. ("RES") filed a complaint with the Federal Energy Regulatory Commission ("Commission") against Florida Gas Transmission Company ("FGT" or "the Pipeline"). Pursuant to Rule 214 of the Commissions Rules of Practice and Procedure,[1] Calpine Energy Service, L.P. ("Calpine") submits this motion to intervene and comment concerning the RES Complaint ("the Complaint"). I. BACKGROUND In the Complaint RES, one of four firm shippers anchoring the FGT Phase VI Expansion, alleges that FGT has violated the terms of its tariff by demanding collateral in excess of the three-month prepayment requirement set forth in Section 16 of the FGT Tariff. Furthermore, RES states that, upon RES rejecting FGTs excessive collateral demand, the Pipeline terminated its Phase VI precedent agreement with RES, claiming that it now considered its deal with RES "uneconomical." FGT indicated that it intended to go forward and construct only those facilities necessary to serve the other Phase VI shippers.[2] Calpine has reviewed the Complaint filed by RES. If FGT is requiring collateral support beyond what is required by its tariff, or is otherwise applying its tariff on an unduly discriminatory basis, the Complaint has merit, and the relief sought by RES should be granted with FGT further required to revise its business practices and tariff. Because this complaint present issues of importance to all FGT shippers, Calpine hereby moves to intervene in this proceeding and provides its comments concerning the Complaint. In support of its submission, Calpine states as follows: I. COMMUNICATIONS Communications concerning this filing should be addressed as follows, and the following should be included on the official service list in this proceeding: Mr. Craig Chancellor Mr. James Downs National Director, Gas Regulatory Manager - National Regulatory Calpine Corporation Calpine Corporation 1000 Louisiana Street 1000 Louisiana Street Suite 800 Suite 800 Houston, TX. 77002 Houston, TX. 77002 Tel: 713/335/4071 Tel: 713/335/4131 Fax: 713/651/3059 Fax: 713/651/3059 Email: craigc@calpine.com Email: jdowns@calpine.com Mr. Alex Makler Senior Counsel Calpine Corporation 1350 I Street NW Suite 1270 Washington DC 20005 Tel: 202/589/0909 Fax: 202/589/0922 Email: alexm@calpine.com I.MOTION TO INTERVENE Calpine owns and operates numerous natural-gas-fired generation facilities throughout the United States and Canada. Consequently, Calpine relies heavily upon the natural gas interstate pipeline grid. Calpine currently holds firm transportation service ...