Rulemaking Comment of The Society for the Preservation of Oil Pipeline Shippers under RM02-3.

March 11, 2002 Via E-Mail Honorable Magalie Roman Salas Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re: Accounting and Reporting of Financial Instruments, Comprehensive Income, Derivatives, and Hedging Activities, Docket No. RM02-3-000 Dear Madam Secretary: Enclosed for "e-filing" with the Commission are the Comments of the Society for the Preservation of Oil Pipeline Shippers in the above-captioned proceeding. I understand that no paper copies need be filed. Kindly acknowledge and confirm receipt of this document. Thank you for your assistance in this matter. Sincerely, /s/ Elisabeth R. Myers-Kerbal Counsel for the Society for the Preservation of Oil Pipeline Shippers Enclosure 77804.1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) Accounting and Reporting of Financial) Instruments, Comprehensive Income,) Docket No. RM02-3- 000 Derivatives, and Hedging Activities) ) COMMENTS OF THE SOCIETY FOR THE PRESERVATION OF OIL PIPELINE SHIPPERS The Society for the Preservation of Oil Pipeline Shippers ("SPOPS") hereby submits its Comments regarding the Notice of Proposed Rulemaking issued by the Federal Energy Regulatory Commission ("Commission" or "FERC") on December 20, 2001.[1] I. EXECUTIVE SUMMARY SPOPS applauds the Commissions efforts to reform the accounting and reporting requirements for entities that are subject to its jurisdiction to keep up with developments in the market place that affect the transactions being conducted by public utilities and gas and oil pipelines. SPOPS supports the Commissions goal of providing more useful information to regulatory agencies and others who use the financial information reported to the Commission by regulated entities.[2] As the Commission recognizes in the NOPR, the availability of adequate current information is essential for the Commissions analysis of the profitability, efficiency, and risk management of these companies and for the Commissions overall efforts to monitor energy markets and protect the public interest by ensuring that rates are just and reasonable and that services are provided in a non-discriminatory way.[3] SPOPS generally supports the Commissions proposals in the NOPR. The Commission proposes to revise its accounting rules and reporting requirements for electric utilities, interstate gas pipelines and oil pipeline common carriers. SPOPS is pleased to see attention being paid to the reporting requirements of oil pipelines. Having access to adequate information is particularly important to oil pipeline shippers due to the hurdles which shippers must overcome in order to bring complaints and/or protests against oil pipeline rates under the current regulatory regime. SPOPS comments, therefore, focus on certain aspects of ...