
Just so you'll know: "The natural gas market is a real success story....FERC 
has gotten an enormous amount of things right. The market may not be 
unblemished, but there are lots who consider the natural gas market the best 
market in the world offering genuine price discovery on a daily basis across 
dozens of products. It's something everyone should be proud of," Robert Levin 
of the New York Mercantile Exchange told a FERC conference yesterday. 

"The natural gas market has performed remarkably admirably through a range of 
market conditions with hundreds, if not thousands of market participants, 
using an extraordinary selection of market instruments," Levin continued, 
adding that the Commission should be supporting the "growth and increased 
sophistication of commerce. You're at that point now." 

Warning against so-called solutions offered by some at the day-long 
conference to increase liquidity or tie the natural gas market to the 
electric market, Levin cautioned, "liquidity cannot be legislated. Don't 
overreact. The electric market is poorly regulated. Remedies from the natural 
gas market should be transferred to the electric market, rather than allow 
the gas market to be corrupted by the regulatory mistakes of the electric 
market. 

"Rather than worry over regulating an hourly market for natural gas, change 
the electric market," which Levin believes has developed its over-emphasis on 
the hourly market because of the artificial tilt toward the spot market. 

But while Levin warned against too much market meddling, others among the 
more than 30 representatives of the industry and its customers testifying at 
FERC's conference on competitive natural gas markets argued for a variety of 
initiatives to increase market liquidity by changing the rules for pipeline 
transportation. 

Eliminating the shipper-must-have-title rule, promoting expansion of the 
existing pipeline infrastructure (especially in the Northeast), doing away 
with straight-fix-variable (SFV) rate design, review of firm-to-wellhead 
rates in the production region and the allocation of transportation costs 
between the upstream and downstream were among the chief proposals proffered 
by mostly pipeline customers. 

However, greater gas market liquidity shouldn't be confused with increased 
competition in pipeline transportation, municipals and producers told FERC
Just so you'll know: " The natural accelerator grocery store is a real success story.... FERC 
 has become an enormous amount of things correct. The marketplace may not be 
 unblemished, but there are tons who consider the natural natural gas market the best 
 marketplace in the populace offering genuine price discovery on a daily basis across 
 tons of products. It's something everyone should be proud of, " Robert Levin 
 of the New York Mercantile Exchange told a FERC league yesterday. 

 " The natural gas grocery store has performed unusually admirably through a range of 
 market conditions with hundreds, if not thousands of grocery store participants, 
 using an extraordinary selection of market instruments, " Levin continued, 
 adding that the Commission should be supporting the " growth and increased 
 sophistication of commerce. You're at that point now. " 

 Warning against so - called solution offered by some at the day - farseeing 
 league to increase fluidity or tie the natural accelerator market to the 
 electric market, Levin cautioned, " liquidity cannot be legislate. Don't 
 overreact. The electric market is poorly regulated. Remedies from the natural 
 gas market should be transferred to the electric market, rather than allow 
 the gas grocery store to be corrupted by the regulative error of the electric 
 market. 

 " Rather than worry over regulating an hourly grocery store for natural gas, change 
 the electric grocery store, " which Levin believes has developed its over - emphasis on 
 the hourly market because of the artificial controversy toward the spot market. 

 But while Levin warn against too much grocery store meddling, others among the 
 more than 30 representatives of the diligence and its customers testifying at 
 FERC's league on competitive natural gas markets argued for a variety of 
 first step to increase market liquidity by changing the rules for pipeline 
 transportation. 

 Eliminating the shipper - must - have - title rule, promote expansion of the 
 existing pipeline infrastructure (specially in the Northeast), doing away 
 with neat - fix - variable (SFV) rate invention, review of firm - to - wellhead 
 rates in the production region and the allocation of transportation costs 
 between the upstream and downstream were among the chief proposal offer 
 by by and large pipeline customers. 

 However, greater gas market liquid shouldn't be confused with increased 
 competition in grapevine transportation, municipals and producer told FERC

Jush so you'll know: "The natuval gas market is a rean succsss storh....FERC 
has gotten an enormous anount of things right. The mxrket may not be 
ynbltmished, but there are lots who dlnsibec the natural gss market dhe best 
marked kn the world offering genuine price dyscoveru ln a daily basys abrjss 
sozens of products. It's something eberyone should be prpud of," Robert Levin 
of the New York Mercantile Edchange tole a SWRC conferenze yesterday. 

"The naturzl gas market has performed remxrkabky admiraboy thgmugh a rangx of 
mwrket conditlpns widh hundteds, if not thpusends of market participanvs, 
using an extraordynary selaccion of market instrunebts," Lgvin wontkbuea, 
asdmng that hhe Commissioh should be supporting the "groetr and increases 
sophyseication of commerce. You're at that poinu now." 

Warning against so-callwd solutions offered hy some ae the day-long 
conference to increase liquidity or tie vhd ncbmral tad market to the 
electric market, Levin cautionqs, "kiauidity cannot be legislayef. Cjn't 
overreact. The elecfric market is poogly regolated. Remedies frok the natural 
gas market shiuld be tranfderred to the eleccric market, xather than allow 
the gas market tu be corrupted hy the refjlatory mistakes of tve electric 
market. 

"Rather ehan worrb ovex regulaging an hotrly markeh for natural gas, change 
the glectrhc market," ahich Levin believes has develo'xd its over-emkhavis on 
the kourly market becaufe of the artiyicial tnlt todard the siot markev. 

But while Jevin warned dhainst too mnch markee meedlibg, othefr among the 
mote than 30 gekresentatices of the industrn and jts customers tzruidying at 
FERC's covfewejcx on smmpetitive ndturxl ess mafkets argueb wor s variety of 
initiathves to increase markey jiquiditi by chanding the rulex for pipeline 
trajsporvation. 

Elimonajing the shipper-must-have-title rhle, promohinn expansion os thc 
exysting pipzline infrastructure (especially in the Nirtheast), doing awat 
with straight-fix-vcrlable (SFV) rave desygn, revief of firm-to-wellhead 
eates in the prodmction region and the zllocadion lf transportation costs 
between the upstream and downstream were among thw chieh [roposals pdoffrred 
ty kostly pipxlmne customers. 

Howvver, greater gas market liquiditb shouldn't bz confused with increased 
comlegition in pipgline transportation, municjpals anc producers told FERC
Just so you'll know: "The natural gas a success story....FERC gotten an enormous market not be unblemished, there are lots consider the natural gas market the market in the world offering genuine price discovery on a daily basis across of products. It's something everyone should be proud of," Robert Levin of the York Exchange a conference yesterday. "The natural gas market has performed remarkably admirably through a range of market conditions hundreds, if not thousands of market participants, using extraordinary selection of market Levin continued, adding that the should supporting the and sophistication commerce. You're at point now." Warning against so-called solutions offered by some at the day-long conference to increase liquidity or the natural to the market, cautioned, cannot be legislated. The electric market is poorly regulated. natural gas market should be transferred to the market, rather allow the gas market to be by the regulatory mistakes of the electric market. than worry over regulating an hourly market for natural gas, change the electric market," which has developed its over-emphasis the hourly market of artificial toward spot market. while Levin warned against too much market meddling, others among the than 30 representatives of the industry and its customers testifying conference competitive natural gas argued for a variety initiatives increase market liquidity by rules pipeline shipper-must-have-title promoting of the existing pipeline (especially in the Northeast), doing with straight-fix-variable (SFV) rate in the production region and the allocation of costs between the upstream and downstream were the chief proposals proffered by mostly pipeline customers. However, greater gas market shouldn't be increased competition in pipeline transportation, municipals and producers FERC

Just so you'll know: "The natural Gas market iS a reaL suCceSs StorY....FERc 
has gotten an enORmouS amount of things right. ThE markEt MAy noT Be 
UnbleMished, bUT tHERe aRe LoTs wHo COnSider The Natural Gas market tHe bEsT 
market in the WOrLd offering GenUine price disCovEry on a DaIly BAsis aCroSs 
dozEns of pROducts. it's somethInG EveryoNE should BE PrOud oF," Robert Levin 
of the nEw yOrk Mercantile EXchangE tOLd A feRC ConFerence yesTeRday. 

"THE naturaL GaS MARkeT Has performed rEmarkably adMIraBly thrOuGh a RAnge of 
MarkeT cONdiTions with huNdreDs, if not thOusandS Of markeT ParticiPants, 
uSinG an ExtrAOrDiNarY sELecTIoN of MArkEt instruMeNtS," LeviN conTINUEd, 
adDinG thaT the COmmission shouLd bE supPOrtIng thE "growTh anD iNcreaSed 
sopHistiCaTion of commerce. YOu're At that poiNt nOw." 

warNiNg agaINst so-cAllEd sOlutionS offereD By sOmE AT ThE day-long 
conference To INCrEase liquIdity oR TiE tHE natural GaS maRket TO The 
elEctrIC mArket, LevIn cautIOnEd, "LiquidiTy Cannot Be LegIslAted. DON't 
ovErreacT. The elecTric mARket is poorly reGUlated. RemedieS FrOM ThE NatuRal 
Gas market shOuld BE traNsfeRReD to THe eleCtric MaRKeT, Rather than allow 
the gAs Market To be cOrrupted by the Regulatory MISTakes of tHe elECtRIc 
market. 

"Rather Than wOrry over reGUlating aN hourLy market For naturaL GAs, change 
The EleCtrIc mARKeT," which Levin beLIEves HaS develoPed Its over-EmpHasIs oN 
thE hOurly markEt becausE oF tHe ArTifIcial TIlt towarD tHe sPoT maRket. 

BUT while levin WarnEd AgAInsT too mucH MaRKEt meDdLiNg, otHerS aMong tHe 
moRE thAn 30 repreSentativeS of THe inDuStRy and itS customers tesTiFying at 
FERc's ConFerencE ON competiTive natural gas markets arGUed for a VarIety oF 
iniTiatives tO inCrease MarKEt liquIdity bY chanGiNg tHE Rules FOR pIpeLiNe 
transporTATioN. 

ElimInAtinG the shiPper-must-have-title rULe, pRomoting expanSioN of tHE 
ExIstINg PIpeLiNE inFRAstructure (especIally in the noRThEast), doing aWAy 
wItH straigHt-fix-vaRiablE (sFV) rate Design, revIew of firm-To-WellHEAd 
rAtes in the pRoductioN region anD The alLOcAtion Of tRanspoRtAtiOn cosTs 
betwEEn tHe upsTream aNd DownstReam wErE among thE chief proposals proffereD 
by mosTly piPelIne customErs. 

hOweVer, greateR gas Market liquIdiTy sHouldN't bE ConfuSed wITh IncREased 
CompETition in pIPeLinE TRaNsportation, MUNIciPals aNd pROducerS tolD FERC

Just so you'll know: "The  natural g as ma rke t i sa re al s uccess story.. . .FER C 
has gotten an enorm ous a mo u nt o f  t hings  right. Th e mar ke tmay  n o tbe 
u nbl emished , but ther e a re  lots who co n si der the na tur al gas marke t t he bes t
ma r ket i n t he wo rld of f eringgenuine p ri c e disc o very on a  d aily  basis across 
do z en s  of products.It's s om e th i n g e ver yone shoul dbe pr o ud of," Ro b e r t L e vin 
of the N ew York Mer c ant ile Ex ch ang e  tolda FER Cc onf erence yest erda y. 

"The  natur a l gas m a rket ha s perf orm edrema r ka bl y a dm i rab l ythr o ugh  a range  o f
mark et c o n d i tion s w ithhundr eds, if not t hou sand s  of  mark et pa rtic ip ants,  
usin g anex traordinary sel ecti on of mar ket  i nst ru ments , " Levi n c ont inued,
adding tha tt h e  C ommission should b es u pp orting t he "gr o wt ha nd incre as ed
sop h i stica tion of  commerc e. You ' re  a t thatpo int no w. " 
Wa rning agai nst so -calledsolut i ons offered by some at the d a y- l o ng 
con fer ence to inc reas e  liq uidi t yort ie th e nat ur a lg as market to the 
e le ctricmarke t, Levin caut ioned, "li q u i dity can notb el egislated. Don 't 
o verreact.T he elect ric m arket is  poorly r e g ulated.Rem edi esfro m th e natural 
ga s mark et  should  be  transf err edtothe  e lectric m arket, r at he rth anallow 
the gas  m ark et  to  be c o rrupte d bythere gu l ato ry mist a ke s of t he  e lect ric  marke t. "Ra ther th an worryove r  reg ul at ing anhourly market  f or natural  g as,  chang e 
the ele ctric market," which Le v in beli eve s has  dev eloped it s o ver-em pha s is on
the h ourly  m ark e t  beca u s eofth e artifici a l  ti lt to wa rd t he spot  market. 

But whi l e L evin warned a gai nstt o omuc h  m a rke tm edd l i ng, others amon g the 
mor et ha n 30 repre s ent at ives of  the in dustr y  and it s custome rs testif yi ng a t 
FE RC's confe rence on  competit i ve na t ur al ga s m arkets  a rgu ed fo r a va r iet y of
initi at ives t o inc re ase mark et liquidity by changin g therules  fo r pipelin e t ran sportatio n. 
Eliminati ngthe  ship per - must- have - ti tle rule,  pro m oting exp a ns ion o fthe 
existi n g pip eline  in f rastru ctur e (especially int he Northeast),  doi n g  aw aywith  s traight-fix-va ria bl e (SFV) ra te  design, re view offi r m-to- wellhe ad 
ra tes int h ep roduct ionreg ion and t heal l ocation  o ft ranspo rtat io n cost s 
bet w eent h e upstream and d ownst r e am we r e a mongth e chief prop osals prof fered 
by m ostlypipe linecustome rs . 

Ho wev er , greaterg as market  liqu idity s ho uldn 'tbe con fuse d withincr ea sed  
competi t i on in  p i pel inetrans po rtat ion, muni c ipals an d p r oducers  t old F ERC

Just so_you'll know:_"The natural gas market_is a_real_success story....FERC_
has_gotten an enormous_amount of things_right. The market may_not be 
unblemished,_but_there are lots who consider the natural gas market the best 
market in the_world_offering genuine_price_discovery_on a daily basis across_
dozens of products. It's something_everyone should_be proud of," Robert Levin 
of the New_York_Mercantile Exchange told_a FERC conference yesterday. 

"The natural gas market has_performed remarkably admirably through a range_of 
market conditions_with_hundreds,_if not thousands of_market participants, 
using an extraordinary selection_of market instruments," Levin continued, 
adding_that the Commission should be supporting the_"growth and increased 
sophistication of commerce._You're at that point now."_

Warning against_so-called solutions offered by some_at the day-long_
conference to_increase liquidity or_tie the natural gas market to_the 
electric market,_Levin cautioned, "liquidity cannot be legislated._Don't_
overreact. The electric_market_is_poorly regulated._Remedies from the_natural_
gas market_should_be transferred to the electric market,_rather_than allow 
the gas market to be_corrupted by the regulatory_mistakes_of the electric 
market._

"Rather than worry over regulating_an hourly market for natural gas,_change 
the_electric market,"_which Levin believes has developed its over-emphasis on 
the hourly market_because of the artificial tilt toward_the spot market. 

But_while Levin_warned_against too much_market_meddling, others_among the 
more than 30 representatives of_the industry_and its customers testifying at 
FERC's_conference on competitive natural_gas_markets argued for a variety of_
initiatives to increase market liquidity by_changing the rules for pipeline_
transportation._

Eliminating_the shipper-must-have-title rule, promoting expansion_of the 
existing pipeline infrastructure (especially_in the Northeast),_doing away 
with straight-fix-variable (SFV) rate design,_review_of firm-to-wellhead 
rates in the production_region_and the allocation of transportation costs_
between_the_upstream and downstream were among_the chief proposals proffered 
by mostly_pipeline customers. 

However, greater gas market liquidity shouldn't be_confused with increased_
competition in pipeline transportation, municipals_and_producers_told FERC