From: Kate Holden [kate_holden@transcanada.com]
Sent: Monday, March 23, 1998 2:50 PM
To: gas_strategy@cpuc.ca.gov
Subject: R.98-01-011

March 23, 1998




Docket Clerk
California Public Utilities Commission
505 Van Ness Avenue, Room 2001
San Francisco, CA 94102

Re:	R.98-01-011

Enclosed for filing with the Commission are the original and five (5)
copies of the "Initial Comments of ANG Pipeline on the Commission's
Order Instituting Rulemaking (OIR) on Reforms to its Natural Gas
Regulations."  As requested, ANG Pipeline has submitted an electronic
copy of its comments to the Commission's website,
gas_strategy@cpuc.ca.gov.

Please time-stamp and return one copy in the enclosed stamped,
self-addressed envelope.

Thank you.

							
Sincerely,

ORIGINAL SIGNED BY

Rebecca A. Blackmer
Legal Counsel


Enclosure

c.c.		All Parties on Service List






BEFORE THE PUBLIC UTILITIES COMMISSION 
OF THE STATE OF CALIFORNIA



Rulemaking on the Commission's	)		R. 98-01-011
Own Motion to Assess and Revise	)
the Regulatory Structure Governing	)
California's Natural Gas Industry	)







INITIAL COMMENTS  OF  ANG PIPELINE,
A DIVISION OF TRANSCANADA PIPELINES LIMITED,
ON THE COMMISSION'S RULEMAKING ON CHANGES TO
ITS NATURAL GAS REGULATIONS






Rebecca A. Blackmer
Legal Counsel
ANG Pipeline
111 - 5th Avenue S.W., 19th Floor
Calgary, Alberta, Canada  T2P 3Y6
Phone: (403) 267-2453
FAX:  (403) 267-1055



Electronic mail:  rebecca_blackmer@tcpl.ca



 

BEFORE THE PUBLIC UTILITIES COMMISSION 
OF THE STATE OF CALIFORNIA


Rulemaking on the Commission's	)		R. 98-01-011
Own Motion to Assess and Revise	)
the Regulatory Structure Governing	)
California's Natural Gas Industry	)



INITIAL COMMENTS OF ANG PIPELINE ON THE COMMISSION'S RULEMAKING ON
CHANGES TO ITS NATURAL GAS REGULATIONS

	Pursuant to the schedule established in the Administrative Law Judge's
ruling dated February 10, 1998, ANG Pipeline, a division of TransCanada
PipeLines Limited, hereby submits its initial comments on the
Commission's Order Instituting Rulemaking ("OIR") to assess changes in
the current market and regulatory framework for California's natural gas
industry.

INTRODUCTION
	ANG Pipeline ("ANG") owns and operates a major natural gas transmission
system in southeastern British Columbia.  The ANG system is a vital link
in the Alberta-California pipeline corridor and is connected to Pacific
Gas & Electric Company Gas Transmission, Northwest Corporation ("PG&E
GT-NW") system at the international border near Kingsgate, British
Columbia and Eastport, Idaho.  ANG transports up to 2.6 Bcf/d of
Canadian-sourced natural gas to its Kingsgate interconnection with PG&E
GT-NW.  Approximately 70 percent of these volumes are transported by
PG&E GT-NW to Malin, Oregon and subsequently delivered through the
Pacific Gas & Electric Company system to gas markets in northern and
southern California.
	As one of the largest upstream transporters of gas to the California
market, ANG has a direct interest in this proceeding.  For this reason,
ANG plans to be an active participant in this proceeding. 


COMMENTS
	The OIR and the accompanying Division of Strategic Planning report,
"Strategies for Natural Gas Reform: Exploring Options for Converging
Energy Markets," contain numerous broad-ranging proposals that could
affect the availability and cost of intrastate gas transportation
services for consumers in northern and southern California as well as
access to storage, balancing, and other services required to market
Canadian-sourced gas in California.  The proposals include
recommendations to change the Commission's regulations regarding: the
unbundling of interstate pipeline and storage services for core
customers; tightening of balancing tolerances for noncore customers; the
ratemaking methodology used to establish and revise intrastate
transportation rates; removal of the regulated utilities from the gas
procurement function; establishing an independent system operator for
gas; and measures to prevent the exercise of market power in gas
transportation services.  Although these proposals primarily address
intrastate issues, ANG is concerned that they may have broader
implications on natural gas access to the California market.  
	ANG is not offering specific comments on these proposals at this time. 
However, ANG will carefully review the comments of other parties to this
proceeding and will file substantive reply comments, if needed, to
protect and advance its interests as a transporter of gas for
consumption in California. 



Respectfully submitted,
TRANSCANADA PIPELINES LIMITED

ORIGINAL SIGNED BY 
REBECCA A. BLACKMER
By:	_______________________
	Rebecca A. Blackmer, Esq.
	U.S. Regulatory Law
	TransCanada PipeLines Limited
	19th Floor
	111-5th Avenue S.W. (T2P 3Y6)
	P.O. Box 1000, Station M
	Calgary, Alberta   T2P 3Y6
	Tel:	(403) 267-8849
	Faz:	(403) 267-1055

Attorney for TransCanada PipeLines Limited


March 23, 1998