โ Scribed by Moring, Frederick
No coin nor oath required. For personal study only.
T ronment created by Order 636 has caused many LDCs, not to mention other pipeline customers, to pay more attention to both the mechanics and the substance of the pipeline rate increase process. While the Natural Gas Act (NGA) Section 4 procedure has always armed the pipelines with the right to collect higher rates subject to refund (after a suspension period of five months or less), the pipelines' post-Order 636 use of that right has the potential to cause more competitive injury than ever before. An aggravating factor in today's environment is that the standard pipeline rate design adopted in Order 636 leaves the average pipeline relatively unaffected by its own rate increase activity.
๐ SIMILAR VOLUMES
Here we go again. Amid a number of well-thoughtat observations and valid questions in the FERC's ratedesign policy statement, we find, one more time, the notion that pipeline customers should have a unilateral right to reduce their contracts. The wording seems innocuous enough at first: In a section