On April 11 91¹ú²ú filed comments in the PG&E and Coral Petitions regarding the Commission’s capacity release regulations. PG&E petitioned FERC to remove the price cap on released capacity transactions. Coral asked FERC to “clarify” various aspects of its capacity release regulations (see 3-07 Board Bulletin).
91¹ú²ú advocated that:
The Commission should lift the maximum rate cap for capacity release on the entire market (including primary short-term firm and interruptible transportation as well as capacity release), subject to monitoring and reporting requirements;
91¹ú²ú does not oppose Coral’s request to package/ tie pipeline capacity with gas supply, aggregating the releasing shipper’s capacity. 91¹ú²ú, however, stated that it is not clear that the Commission lawfully can grant the relief Coral seeks through their clarification comments rather than through notice and rulemaking comments. 91¹ú²ú advocated that, whatever it chooses to do, the Commission first needs to consider the value of a level playing field for the primary and secondary markets (it should not put the pipeline at a competitive advantage vis-à-vis its firm shippers); and that
The Commission should retain the shipper-must-have-title rule.