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 e'-~~ : ~<?.... ~'t ORIGINAL ~, . X ~ : . .. ~' :':'- ,, ~9 ? ~ ~ UNITED STATES OF AMERICA ~55"'; :;:'~~ : : ~ ' ~ L ENERGB~OG~LTA~oRY COMMISSION 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 ...