The Honorable Cheryl LaFleur
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Dear Chairman LaFleur:
We write in regard to requests for rehearing that have been filed in the Portland Natural Gas Transmission System (PNGTS) 2010 rate proceeding (Docket No. RP10-729). PNGTS applied for a rate increase on May 12, 2010, and since the fall of 2010 has been charging a firm transportation rate of approximately $1.32 per Dth. This case is complex and, because of rehearing requests and compliance filing challenges, natural gas consumers in northern New England continue to pay interstate transportation rates that may be more than 50 percent higher than the rate that the Commission finally approves.
While these higher rates may ultimately be refunded, we are concerned that consumers face another winter heating season paying more than they should. Moreover, given that the previous PNGTS rate case (Docket No. RP08-306) overlapped with the 2010 case, it has been more than six years since shippers on PNGTS have paid transportation rates that have received Commission scrutiny and approval. Unless these higher rates are found by the Commission to be just and reasonable, consumers cannot be asked to pay higher shipping rates during a time of skyrocketing natural gas and electricity prices.
Further, uncertainty about transportation rates creates a difficult business climate for the pipeline owners, the shippers, and, ultimately, retail customers. The pipeline owners need business certainty and the retail customers should not pay higher than necessary rates. Additionally, our Maine paper mills face too many challenges -- from foreign trade to changing market conditions -- and they should not be asked to continue paying gas pipeline shipping rates that have not been approved by the Commission.
We urge the Commission to decide this rate proceeding as expeditiously as possible.
Sincerely,