Comment of Kinder Morgan Interstate Gas Pipelines under RM14-2.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Coordination of the Scheduling ) Docket No. RM14-2-000 Processes of Interstate Natural Gas ) Pipelines and Public Utilities ) COMMENTS OF THE KINDER MORGAN INTERSTATE PIPELINES The Kinder Morgan Interstate Pipelines1 submit these comments in response to the Federal Energy Regulatory Commissions (Commission or FERC) Notice of Proposed Rulemaking (NOPR) issued in the above-referenced proceeding on March 20, 2014. 2 In its NOPR, the Commission proposes revisions to its regulations to revise the operating day and scheduling practices used by interstate pipelines to schedule natural gas transportation services in order to improve coordination of the scheduling of natural gas and electricity markets. The Commission stated in its NOPR that the proposed revisions affect the business practices of the natural gas industry, as developed through the North American Energy Standards Board (NAESB), and provided the natural gas and electric industries with six months to reach consensus on standards, 1 For purposes of this filing, the Kinder Morgan Interstate Pipelines include Bear Creek Storage Company LLC, Cheyenne Plains Gas Pipeline Company, L.L.C, Colorado Interstate Gas Company, L.L.C., Elba Express Company LLC, El Paso Natural Gas Company, L.L.C., , Kinder Morgan Louisiana Pipeline LLC, Mojave Pipeline Company, L.L.C., Southern LNG Company LLC, Southern Natural Gas Company, L.L.C., Tennessee Gas Pipeline Company LLC, TransColorado Gas Transmission Company LLC, Wyoming Interstate Company LLC, and Young Gas Storage, Ltd. Kinder Morgan is a joint venture participant with unaffiliated entities in the following interstate pipelines and provides these comments as operator of such pipelines: Horizon Pipeline Company, L.L.C., Kinder Morgan Illinois Pipeline LLC, Natural Gas Pipeline Company of America LLC, Midcontinent Express Pipeline LLC, Ruby Pipeline, L.L.C., Sierrita Gas Pipeline LLC, and Young Gas Storage, Ltd. 2 Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities, 146 FERC 61,201 (2014). 1 the start of the gas day. As such, the Kinder Morgan Interstate Pipelines support NAESBs September 29 Filing, as an alternative to the Commissions proposal in the NOPR. As members of INGAA, the Kinder Morgan Interstate Pipelines support the comments filed by the Natural Gas Council collectively supporting the NAESB September 29 Filing and continuation of the 9:00 a.m. Central Clock Time (CCT) start of the gas day as discussed therein. Additionally, the Kinder Morgan Interstate Pipelines that serve the Desert Southwest Pipeline Stakeholders3 have been engaged in discussions with the ...