 cautioned against policy changes that would force the 
development of new market centers and hubs. Market centers should be allowed 
to develop at their "own pace," and at locations where the market "sees fit," 
he said. 

EEA's Henning estimated more than 40 "liquid and transparent" market centers 
exist today, which permit industry participants to buy and sell gas daily 
under "extremely competitive" conditions. He said he's "confident" more will 
be added because of the options that they provide to gas customers. As 
another way to enhance liquidity, KeySpan's Daverio --- as well as others --- 
supported eliminating the shipper-must-have-title rule, which requires the 
customer to retain title to the gas while it's being shipped. Doing away with 
the rule would pave the way for the development of new pipeline products and 
services, such as operational balancing and virtual storage, he told the FERC 
staff. 

But Dena Wiggins, an attorney with the D.C. law firm of Sutherland, Asbill & 
Brennan LLP, which represents the Process Gas Consumers Group (industrial gas 
customers), said her group was "very concerned" about efforts to repeal the 
rule. "...I haven't heard anything yet [today] that satisfies the concerns 
that we might have." She noted the Commission already has granted exceptions 
to the shipper-must-have-title rule in certain cases, and should continue 
with this policy where necessary. 

Moreover, Wiggins said industrial customers were increasingly worried about 
the mounting market power of unregulated companies, especially gas marketers. 

At the conference, she also expressed her group's dismay with the pipeline 
compliance filings with Order 637, particularly on the penalty issue. Rather 
than an "improved" penalty structure, pipelines are proposing higher 
penalties, Wiggins said. "[We] continue to be shocked at the absolute 
wholesale departures" from 637. 

BP's Jeff Holligan also waded into the fight against all the new services 
outlined by pipelines in their Order 637 filings, which he said were "nothing 
more than penalties disguised as balancing services that customers can't 
refuse." He urged the Commission to check with a pipeline's customers
cautioned against policy changes that would force the 
 development of newfangled grocery store centers and hubs. Market center field should be allowed 
 to develop at their " own footstep, " and at locations where the market " see fit, " 
 he said. 

 EEA's Henning estimated more than 40 " fluid and transparent " market center 
 exist today, which permit industry participants to bribe and sell gas daily 
 under " extremely competitive " condition. He said he's " confident " more will 
 be total because of the options that they supply to gas customers. As 
 another way to enhance liquidity, KeySpan's Daverio --- as well as others --- 
 support eliminating the shipper - must - have - title rule, which requires the 
 customer to retain title to the accelerator while it's being shipped. Doing away with 
 the rule would pave the way for the development of new pipeline products and 
 services, such as functional reconciliation and virtual storage, he told the FERC 
 staff. 

 But Dena Wiggins, an attorney with the D.C. jurisprudence firm of Sutherland, Asbill & 
 Brennan LLP, which represents the Process Gas Consumers Group (industrial gas 
 customers), say her group was " very concerned " about efforts to repeal the 
 rule. "... I haven't listen anything yet [ today ] that satisfies the concerns 
 that we might have. " She notice the Commission already has granted exceptions 
 to the shipper - must - have - title rule in sealed cases, and should cover 
 with this policy where necessary. 

 furthermore, Wiggins say industrial customers were increasingly worried about 
 the mounting grocery store power of unregulated companies, especially accelerator marketers. 

 At the conference, she also expressed her group's alarm with the pipeline 
 complaisance filings with Order 637, peculiarly on the penalty issue. Rather 
 than an " improved " punishment structure, pipelines are aim higher 
 penalties, Wiggins say. " [ We ] continue to be shocked at the absolute 
 wholesale departures " from 637. 

 BP's Jeff Holligan also waded into the fight against all the new services 
 outlined by pipelines in their ordering 637 filings, which he said were " nothing 
 more than penalty disguised as balancing serve that customers can't 
 refuse. " He urged the Commission to match with a pipeline's customers
 caktioned against policy cmanges that woulb force the 
dsvelopmevt of new market centers and hybs. Mqrket centers should bd allowed 
to deveoop et their "own pacx," and at locatjlns chxre the market "xees fit," 
ha said. 

EEA's Hetnkny estimated more than 40 "liquid and trwnsparemt" market centerf 
expse tosay, which permit industry participznts to buy and sell gas daily 
under "extremely comoetitive" conditiond. He said hg'a "cjbfident" more will 
be added because of the options that they proviae to gas custonees. Wv 
another wey to vnhance liquidity, KeyVpan's Dsverio --- as welk av orhers --- 
supported elimmnating the shipper-most-have-titne rule, which requieew the 
cusdomef to reuaii tjtle tl tie gas whils it's being shipped. Doing away wynn 
the rule wkuld pwvq the way for the development of new pikelins products and 
services, such as operational halancing and virtual storage, he told the FERC 
staff. 

But Dana Wmgeinw, wv ahtorney with the D.C. law firm of Sutherland, Asfjlk & 
Brennan LLP, wmich represents thr Orpsess Gas Consomers Gxkul (industrial gas 
ckstomerf), saie her grotp wss "very concerned" about effirts to repecl rhe 
rule. "...I haven't keard anythiug yet [todau] that satisfies the coucerns 
that we mihht have." Afe noted the Comoisximn already has granted excqptions 
ti thz shippef-musj-have-tiele rule ij cerbdin cases, and shoupd coutinua 
with thid policy where necessary. 

Moreovxc, Wiggins saic hndlstrial cbstomevs were increasyngly worried cbout 
thz mounging marken power oh unregulateq companies, evkecially gas karketerf. 

At the conferdvce, she also ecpressed ktr group's eismay with the piieling 
dompliance filiuys with Order 637, pattizulwrpy og the penalty issje. Fsther 
than an "imiroxed" lenalty structure, pi[elihes are proposing ninher 
penaoties, Widgins said. "[We] continue to be shlcked at the sbsjlute 
wholesale departures" froj 637. 

BP's Jevf Molligan also wadcd igto the fiyht against all the new services 
outlinev by pipelines in theit Order 637 filings, whick me said were "nothyng 
more dhan penalties disguused as balancing services that customsrs cat't 
revuse." He urged the Commission to check with a pipeline's customers
cautioned against policy changes that would force of market centers hubs. Market centers at "own pace," and locations where the "sees fit," he said. EEA's Henning more than 40 "liquid and transparent" market centers exist today, which permit industry to buy and sell gas daily under "extremely competitive" conditions. He said he's more be because the options that they provide to gas customers. As another way to enhance liquidity, KeySpan's Daverio as well as others --- supported eliminating the rule, which requires the to retain title to the while being shipped. away the would pave the for the development of new pipeline products and services, such as operational balancing and virtual storage, he the FERC Dena Wiggins, attorney the law firm of & Brennan LLP, which represents the Group (industrial gas customers), said her group was concerned" about to repeal the rule. "...I haven't anything yet [today] that satisfies the concerns that might have." She noted the Commission already has granted exceptions to the shipper-must-have-title rule in and should continue with policy where necessary. Wiggins industrial were worried about mounting market power of unregulated companies, especially gas marketers. At the she also expressed her group's dismay with the pipeline compliance Order particularly on the issue. Rather than an penalty pipelines are proposing higher said. continue at absolute departures" from 637. BP's Holligan also waded into the against all the new their Order 637 filings, which he said were more than penalties disguised as balancing services customers can't refuse." He urged the Commission to check with a pipeline's
 cautioned against policy chaNges that woUld foRce The 
DeVeloPmenT of new market ceNTers And hubs. Market centers shOuld bE aLLoweD 
To DevelOp at theIR "oWN PacE," aNd At lOcATiOns whEre The markEt "sees fit," 
hE saId. 

eEA's Henning eSTiMated more tHan 40 "Liquid and traNspArent" mArKet CEnterS 
exIst toDay, whiCH permiT industry PaRTicipaNTs to buy AND sEll gAs daily 
under "extreMElY Competitive" conDitionS. HE SaID He's "ConFident" more WiLl 
be aDDed becaUSe OF THe oPTions that they Provide to gaS CusTomers. as 
AnoTHer way To enhAnCE liQuidity, KeySPan's daverio --- as Well as OThers --- 
suPPorted eLiminaTinG thE shiPPeR-mUst-HaVE-tiTLe RulE, WhiCh requirEs ThE 
custOmer TO RETain TitLe to The gaS while it's beinG shIppeD. doiNg awaY with 
The rUlE woulD pave tHe way FoR the development Of neW pipeline ProDuCts AnD 
servICes, sucH as OpeRationaL balancINg aNd VIRTuAl storage, he told the fErc 
StAff. 

But DeNa WiggINs, An ATtorney wItH thE D.C. lAW Firm oF SutHErLand, AsbiLl & 
BrenNAn lLp, which rEpResentS tHe PRocEss GaS consUmers GRoup (induStriaL Gas 
customers), saID her group was "vERy CONcERned" AboUt efforts to RepeAL the 
Rule. "...i HaVen'T Heard AnythInG YeT [Today] that satisfies tHe ConcerNs 
thaT we might have." SHe noted the cOMMission aLreaDY hAS granted exceptIons 
tO the shippeR-Must-have-Title Rule in ceRtain caseS, ANd should ConTinUe 
wIth THIs Policy where neCESsarY. 

MOreover, wigGins saiD inDusTriAl cUsTomers werE increasInGlY wOrRieD abouT 
The mountInG maRkEt pOwer oF UnreguLated CompAnIeS, EspEcially GAs MARketErS. 

AT the ConFeRence, She aLSo eXpresseD her group'S diSMay wItH tHe pipelIne 
compliance FiLings with ORdEr 637, pArticuLARly on the Penalty issue. Rather 
than aN "ImproveD" peNalty StruCture, pipeLinEs are pRopOSing hiGher 
peNaltiEs, wigGINs saiD. "[wE] cOntInUe to be shocKED at The abSoLute 
WholesaLe departures" from 637. 

BP'S jefF Holligan also WadEd inTO ThE fiGHt AGaiNsT All THE new services 
outLined by pipElINeS in their OrDEr 637 fIlIngs, whiCh he saiD were "NOthing 
mOre than peNalties diSgUiseD AS baLancing serVices thaT customerS Can't 
rEFuSe." He uRgeD the CoMmIssIon to Check wITh a PipelIne's cuStOmers
 cautioned against policychanges th at wo uld  fo rc e th e 
d evelopment ofn ew m arket centers and hubs . Mar ke t  cen t er s sho uld bea ll o w ed
t odev el o pat th eir  "own p ace," andatlo cations wher e  t he market"se es fit," 
he  sa id. 
EE A's Henni ngestim ated m o re tha n 40 "liq ui d  and t r anspare n t "mark et centers 
exist to d ay, which perm it ind us t ry p art ici pants to b uy  ands ell gas da i l y  
u n der "extremel y competiti v e"condit io ns. He sai d he' s" con fident" mor e wi ll 
be ad ded be c ause of the opt ions t hat  th ey p r ov id e t og asc us tom e rs.  As 
ano th er  wayto e n h a n ce l iqu idit y, Ke ySpan's Daver io---a s w ell a s oth ers-- - 
su pporte d eli mi nating the ship per- must-have -ti tl e r ul e, wh i ch req uir esthe 
cu stomert o r et a i n  t itle to the gas wh il e it 's being  shipp e d.  D o ing away  w ith  
th e rulewoul d  p ave theway fo r  t he  develo pm ent of  n ewpip eline prod ucts a nd 
serv ices, such as operat i onal balancin g  a n d  v i rtua l s torage, hetold theFERC 
s taf f . 

B ut De na Wi g gins, an attorney w it h theD.C.law firm of S utherland, A s bill & Bren n an LLP, which rep resen ts the Pro c ess GasConsu mers Gro up (indus t r ial gas
cu sto mer s), s ai d her group w a s  "ve ry  concer ned " about  ef for tstore peal the
rule. " .. .I  h av en' t hea r d anythi ng  ye t[to day]t hat sa tisfi es t he  c o nce rns 
th a tw e  mig ht  h ave. " S he  note d th e  Co mmissio n already  ha s  gra nt ed  except ions 
to thesh ipper-must -h ave -title r ule in c ertain cases, and shoul d  contin ue
with  thi s policywhe re nec ess a ry. 
Moreov er, W ig gin s saidi n du str ia l customer s wer e inc re asin gly wor ried about 
the mo u nti ng market pow erof u n r eg ula t ed com pa n ies , especially gasmarketers.  At  the confe r enc e,  she al so expr essed her gro up's dism ay with t he  pip e l ine  
complian ce filin gs with O r der 6 3 7,  part icu larlyon  th e pen alty i s sue . Rat her 
t ha n an " impro ve d" penal ty structure, pipelines  are p ropos ing  higher pen a lti es, Wiggi ns s aid. "[We]  co nti nue t o b e  shoc keda tthe absol utewholesale de par t u re s" from 637 . 
BP 's Je ffH olliga n al so waded into the fight againstallt h e n ews ervi ce s 
outlined by  pi pe l i nes in t he ir Order 63 7 filing s, which  he sa id wer e "noth i n gmore t hanpen alties di sgu is e d as ba la nc i ng ser vice sthat c ustome r s ca n ' t 
refuse." He u rgedt h e Com m iss ion t ocheck w i th a  pipeline' s customers 
 cautioned_against policy_changes that would force_the 
development_of_new market_centers_and hubs. Market_centers should be_allowed 
to develop at_their "own pace,"_and_at locations where the market "sees fit," 
he said. 

EEA's Henning estimated more than_40_"liquid and_transparent"_market_centers 
exist today, which permit_industry participants to buy and_sell gas_daily 
under "extremely competitive" conditions. He said he's_"confident"_more will 
be_added because of the options that they provide to_gas customers. As 
another way to_enhance liquidity, KeySpan's_Daverio_---_as well as others_--- 
supported eliminating the shipper-must-have-title rule,_which requires the 
customer to retain_title to the gas while it's being_shipped. Doing away with 
the rule_would pave the way for_the development_of new pipeline products and_
services, such as_operational balancing_and virtual storage,_he told the FERC 
staff. 

But_Dena Wiggins, an_attorney with the D.C. law firm_of_Sutherland, Asbill &_
Brennan_LLP,_which represents_the Process Gas_Consumers_Group (industrial_gas_
customers), said her group was "very_concerned"_about efforts to repeal the 
rule. "...I_haven't heard anything yet_[today]_that satisfies the concerns_
that we might have." She_noted the Commission already has granted_exceptions 
to_the shipper-must-have-title_rule in certain cases, and should continue 
with this policy where_necessary. 

Moreover, Wiggins said industrial customers_were increasingly worried about_
the mounting_market_power of unregulated_companies,_especially gas_marketers. 

At the conference, she also expressed_her group's_dismay with the pipeline 
compliance filings_with Order 637, particularly_on_the penalty issue. Rather 
than an_"improved" penalty structure, pipelines are proposing_higher 
penalties, Wiggins said. "[We]_continue_to_be shocked at the absolute_
wholesale departures" from 637. 

BP's Jeff_Holligan also waded_into the fight against all the new_services_
outlined by pipelines in their Order_637_filings, which he said were "nothing_
more_than_penalties disguised as balancing services_that customers can't 
refuse." He urged_the Commission to check with a pipeline's customers