Motion to intervene of UGI Utilities, Inc re Transcontinental Gas Pipe Line Corp under RP04-570.

Joel deJesus Counsel September 21, 2004 VIA ELECTRONIC FILING The Honorable Magalie Roman Salas, Esq, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: Docket Nos. TS04-46-000; RM01-10-003 Dear Secretary Salas: Please find enclosed for electronic filing in Docket Nos. TS04-46-000 and RM01-10-003, the Request of National Grid USA for Extension of Time. Please do not hesitate to contact me if you have any questions or concerns. Respectfully submitted, Joel deJesus Counsel for National Grid USA 633 Pennsylvania Ave. NW, Sixth Floor Washington, DC 20004 (202) 783-7959 Fax: (202) 783-1489 joel.dejesus@us.ngrid.com BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION National Grid USA ) Docket No. TS04-46-000 Standards of Conduct for ) Docket No. RM01-10-003 Transmission Providers ) REQUEST OF NATIONAL GRID USA FOR EXTENSION OF TIME Pursuant to Rule 212 of the Commissions Rules of Practice and Procedure, 18 C.F.R. 385.212, National Grid USA (National Grid) hereby respectfully requests an extension of time for compliance with the Commissions standards of conduct. As provided in 18 C.F.R. 358.4(c) (e) (2), transmission providers are generally required to be in full compliance with the Commissions standards of conduct for transmission providers by September 22, 2004 (Compliance Deadline). While National Grid has undertaken to comply substantially with the Commissions standards of conduct by the Compliance Deadline, significant issues concerning the nature of National Grids compliance obligations remain unresolved. In particular, in the above referenced dockets, National Grid has pending waiver and rehearing requests concerning the issue of whether National Grids electric local distribution company (LDC) subsidiaries, Granite State Electric Company and Nantucket Electric Company, must be treated as Energy Affiliates under 18 C.F.R. 358.3(d). If the Commission does not act on those pleadings before the Compliance Deadline, National Grid respectfully requests an extension of time to comply with the Commissions standards of conduct. In addition, if the Commission were to issue one or more orders denying either or both of National Grids pending requests, National Grid respectfully requests an extension of 90 days from the date of such rulings to incorporate any directions by the Commission in such order(s). DISCUSSION This request for extension of time arises out of questions concerning the possible Energy Affiliate status of National Grids two small, electric LDC subsidiaries, Granite State Electric Company and Nantucket Electric Company.1 On February 9, 2004, National Grid filed for a limited waiver of the Commissions regulations with respect to the ...