Wisconsin Public Service Corp. (WPSC) has called on FERC to settle a contract dispute that involves reducing service on ANR Pipeline in order to accommodate deliveries from a competing pipeline's proposed expansion.

In a complaint filed at the Federal Energy Regulatory Commission (FERC) last Wednesday, the Green Bay, WI-based local distribution company (LDC) asked the Federal Energy Regulatory Commission to find that ANR cannot require it to reduce the capacity under one particular transportation contract (Contract No. 104404) when it seeks to reduce certain transportation and storage entitlements under another contract (Contract No. 1600). WPSC has requested expedited treatment of the complaint.

"WPSC is currently aligning its pipeline capacity needs in light of the construction schedule of Guardian Pipeline Co.'s pipeline expansion to Green Bay as well as the construction by WPSC of its related facilities," the LDC said. "In anticipation of acquiring for the first time access to more than one pipeline to the citygate, WPSC has been planning for the arrival of Guardian and focusing on the rearrangements of its ANR capacity portfolio."

Guardian's proposed 110-mile expansion of its mainline currently is awaiting FERC approval. The facilities, which would go head-to-head with ANR in northern Wisconsin, are targeted for operation on Nov. 1, 2008. WPSC has executed a precedent agreement for 205,245 Dth/d of the expansion capacity for a term of 15 years.

In August, WPSC said it notified ANR of its desire to reduce its maximum daily quantity under a number of service agreements, two of which are at the center of the complaint -- Contract 1600 (a transportation agreement) and Contract 30800 (a storage agreement). ANR responded that any reduction in Contract 30800 would have to be accompanied by a corresponding cut in Contract 104404, a firm service agreement with a designated receipt point at ANR's Southwest Headstation and a delivery point at ANR storage.

"WPSC needs to retain the total contract quantity under Contract 104404 and disagrees with ANR that reduction of that service agreement is required by [its tariff]," the utility said.

WPSC said it sought the proportionate capacity reductions in Contracts 1600 and 30800 because they are related. It noted that ANR's tariff requires a shipper's request for service reduction in one contract to be accompanied by a similar request for service reduction in another contract if the two contracts are related. "This [tariff] language does not say that in order to reduce one transportation contract, a shipper must reduce all storage and transportation contracts. It only requires reduction of the contract that is 'related,'" the LDC told FERC.

In addition, WPSC said its requested aggregate capacity reductions, including those not used in prior years, would be less than the 57% required by ANR's tariff.

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