GTN

The proposed Ruby Pipeline is subject to FERC's jurisdiction. GTN asserts that FERC's approval of the construction and operation of the Ruby Pipeline will face serious policy hurdles, including the alleged violation of FERC rules barring affiliated electric and gas divisions of a utility from procuring natural gas transportation services jointly (FERC Rule 2004), and unduly discriminatory terms favoring PG&E relative to other shippers on price and step-down rights. GTN claims that if FERC modifies the Precedent Agreement, PG&E's costs will rise and it will lose other benefits obtained by contract.