Mary, I finally was able to locate my copy of the Alternative Rates Policy  Statement and found the following language:  "A pipeline may file the numbered tariff sheet implementing the negotiated  rate at the time it intends the rate to    go into effect.
The Commission does not intend to suspend the  effectiveness of negotiated rate filings or    impose a refund obligation for those rates.
For these reasons, the  Commission will readily grant requests to    waive the 30 day notice requirement."
I think it might be fair to interpret the first sentence such that it's OK to  file on the same day.
This reinforces my belief that  our waiver language is fine as is.

message for Mary Darveaux

Mary, I finally was able to locate my copy of the Alternative Rates Policy Statement and found the following language: "A pipeline may file the numbered tariff sheet implementing the negotiated rate at the time it intends the rate to go into effect.
The Commission does not intend to suspend the effectiveness of negotiated rate filings or impose a refund obligation for those rates.
For these reasons, the Commission will readily grant requests to waive the <NUMBER> day notice requirement."
I think it might be fair to interpret the first sentence such that it's OK to file on the same day.
This reinforces my belief that our waiver language is fine as is.
alternative rates policy day notice requirement belief waiver language interpret sentence ok sheet suspend effectiveness commission readily pipeline file numbered refund finally able locate