Reply Comments of the National Grid Gas Delivery Companies under RP11-2253.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION In The Matter Of: ) ) Docket No. RP11-2253-000 Columbia Gas Transmission, LLC ) REPLY COMMENTS OF THE NATIONAL GRID GAS DELIVERY COMPANIES Pursuant to the procedural schedule established at the technical conference held on September 8, 2011 in the above proceeding, the National Grid Gas Delivery Companies1 hereby submit these reply comments concerning Columbia Gas Transmission LLCs (Columbia) July 1, 2011 Transportation Cost Rate Adjustment (TCRA) filing in this proceeding.2 As discussed below, National Grid requests that the Commission accept Columbias TCRA filing as a one-time solution to a unique problem and further requests the Commission to require Columbia to make an informational or other filing within ninety days of the Commissions order setting forth Columbias future plans for addressing operating conditions in the Northern Ohio portion of its system. 1 The National Grid Gas Delivery Companies comprise The Brooklyn Union Gas Company d/b/a National Grid NY; KeySpan Gas East Corporation d/b/a National Grid; Boston Gas Company, Colonial Gas Company, and Essex Gas Company, collectively d/b/a National Grid; EnergyNorth Natural Gas, Inc. d/b/a National Grid NH; Niagara Mohawk Power Corporation d/b/a National Grid; and The Narragansett Electric Company d/b/a National Grid, all subsidiaries of National Grid USA, Inc (collectively the National Grid Gas Delivery Companies or National Grid). 2 National Grid has received initial comments from Columbia, the Independent Oil and Gas Association of West Virginia, Inc., Indicated Shippers, NiSource Distribution Companies, Old Dominion Electric Cooperative (ODEC), Proliance Energy LLC (Proliance) and United States Gypsum Company, Calpine Energy Services, L.P. and Stand Energy Corp. (US Gypsum). Initial Comments will be identified as IC. National Grid Supports Proposals That The Commission Accept Columbias Filing As A One-Time Solution To A Unique Set Of Circumstances In its initial comments, ODEC states that it does not oppose the interim TCRA but requests the Commission to clarify that it is acceptable only in light of the unique circumstances described in Columbias filing and that it should not be viewed as general precedent or an endorsement of the use of the TCRA to impose on customers costs that can be avoided or reduced.3 In a similar vein, Indicated Shippers request that the Commission accept Columbias filing as a short-term interim fix for what appears to be a long-term problem.4 National Grid concurs with these comments and further agrees ...