Ruby LLC

Ruby LLC argues that GTN's threatened rate increase is overstated. First, Ruby LLC claims that GTN's calculation ignores the FERC's policy that pipelines must bear some risk for unsubscribed capacity. Second, GTN unreasonably assumed its operating costs would increase, in contrast to other pipelines that have reduced costs in response to competition. Third, GTN unreasonably assumed a large increase in its depreciation rates. Finally, Ruby LLC states that GTN did not assume any revenues from re-marketing its de-contracted capacity and underestimated its revenues from backhaul of Rockies gas received at Malin.