Motion to Intervene and Protest of Shell NA LNG LLC under RP05-51.

For Rochester Gas and Electric Corporation: Bruce W. Neely Marjorie L. Perlman Brett A. Snyder Rochester Gas & Electric Corporation LeBoeuf, Lamb, Greene & MacRae, L.L.P. 89 East Avenue 1875 Connecticut Avenue, Northwest Rochester, NY 14649 Washington, D.C. 20009-5728 Telephone: (585) 771-4690 Telephone: (202) 986-8000 Fax: (585) 724-8818 Fax: (202) 986-8102 Email: marjorie_perlman@rge.com Email: bwneely@llgm.com bsnyder@llgm.com For Niagara Mohawk Power Corporation, a National Grid company: Roxane E. Maywalt, Esq. Mr. Daniel Wiecek National Grid USA Service Company, Inc. Niagara Mohawk Power Corporation 300 Erie Boulevard West 300 Erie Boulevard West Syracuse, New York 13202 Syracuse, New York 13202 Telephone: (315) 428-5187 Telephone: (315) 428-5804 Fax: (315) 428-6407 Email: daniel.wiecek@us.ngrid.com Email: roxane.maywalt@us.ngrid.com National Fuel Distribution is a corporation organized and existing under the laws of the State of New York, with its principal place of business located in metropolitan Buffalo, New York. It is a natural gas distribution company whose activities are subject to the jurisdiction of the New York Public Service Commission (NYPSC) and the Pennsylvania Public Utility Commission. National Fuel Distribution is engaged in the business of distributing natural gas in New York and Pennsylvania. National Fuel Distribution purchases gas directly from Southwest, Canadian and Appalachian producers and marketers and transports that gas through one or more of six upstream interstate pipelines and one intrastate pipeline, including DTI. National Fuel Distribution is connected to those upstream pipelines by National Fuel Gas Supply Corporation. NYSEG is a gas and electric corporation, duly organized and existing under the Transportation Corporations Law of the State of New York and has its principal place of 3 * * * 5. Adding new Delivery Points to an existing interruptible Service Agreement. As an initial matter, the MND Group objects to the inclusion of MDDO in the list of service entitlements, and urges the Commission to require Dominion to justify the inclusion of an increase in MDDO among new services. Moreover, the proposed definition of new transportation or storage service is unclear as to whether the language designating as new service any increase in service entitlement (including, but not limited to service entitlements designated as MDTQ, MATQ, or MDDO) under an existing agreement subjects the entire service entitlement to treatment as a new service, or whether only the incremental increase constitutes new service. If DTI intends to designate the entire service entitlement, existing plus the requested increase, as a new service, then the customers existing service entitlement would ...