Comment of TOWN OF ASHBY CONSERVATION COMMISSION under PF14-22, Tennessee Gas Pipeline Co. Request to Use Pre-filing Procedures for Proposed Northeast Energy Direct Project; our concerns about the proposed project and belief it should not go forward.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION In The Matter of: Coordination of the Scheduling Processes of ) Interstate Natural Gas Pipelines and Public ) Docket No. RM14-2-000 Utilities ) COMMENTS OF NATIONAL GRID USA, INC. Pursuant to the procedural schedule established by the Federal Energy Regulatory Commission (the Commission) in the above captioned proceeding, National Grid USA, Inc. (National Grid) hereby submits these comments concerning the Notice of Proposed Rulemaking issued March 20, 2014 (NOPR).1 As more fully discussed below, while National Grid supports the Commissions efforts to enhance coordination between the electric and natural gas industries, it submits that the Commission should reject the proposal in the NOPR to change the time for commencing the Gas Day. I. EXECUTIVE SUMMARY National Grid appreciates and supports the Commissions efforts to better align natural gas and electric scheduling practices for the purpose of improving efficiencies in the scheduling systems for both industries. National Grid agrees with the comments submitted by the American Gas Association (AGA) recommending that the Commission adopt final rules implementing 1 Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities, Notice of Proposed Rulemaking, 146 FERC 61,201 (2014). Citations to the NOPR will appear as NOPR at para. __ 1 revisions to the gas nomination schedule developed by the North American Energy Standards Board (NAESB).2 However, in the absence of any electric/gas consensus, National Grid agrees with the Natural Gas Council and AGA that the Commission should decline to adopt proposed changes to the current 9:00 a.m. Central Clock Time (CCT) start of the Gas Day. National Grid further submits, for the reasons discussed by AGA, that the Commission should reject proposed changes to the gas nomination schedule and capacity allocation rules proposed by the Desert Southwest Pipeline Stakeholders. In addition, National Grid urges the Commission to implement any final rule resulting in modifications to the gas nomination schedule contemporaneously with modifications to RTO/ISO schedules required in Docket No. EL14-22-000, et al. If the Commission ultimately determines that an earlier start to the Gas Day is necessary, National Grid recommends moving the start to 12:00 a.m. CCT. This will allow for better accommodation of load increases during the peak morning hours for both natural gas and electric systems. Finally, any changes made to the Gas Day and gas nomination cycles should not be implemented in the peak winter months when demand on natural gas systems ...