n the early days of open access immediately I after FERC's Order 436, the issue was pipeline-affiliated marketer abuse. The reported abuses were blatant. Pipeline transportation staff routinely steered shippers to the pipeline's affiliates and indicated that the pipeline affiliate's gas would be likely to get preferential treatment. The pipeline affiliate knew when the pipeline would open for transportation, always knew when capacity at constrained points was available, or of any changes in rules or interpretation. In response to such complaints, FERC issued Order 497. It set separation requirements and standards of conduct for transactions between pipelines and their affiliated marketers and set up a hot line to receive and attempt to resolve complaints on a timely basis. Some felt that pipeline affiliates continued to receive preference. However, Order 497 and the compliance hot line did work to significantly reduce actual abuse. Almost as important, the order reduced the perception that the pipeline affiliate would receive advantages and therefore be a more reliable supplier. Now the scene has shifted. Similar concerns are being raised about local distribution company (LDC) marketing affiliates. LDC marketing affiliates are not new. There have been LDC marketing affiliates since even before Order 436.' Concerns about LDC marketing affiliate