I've reviewed Order 637 on voluntary auctions and agree with you, Mary Kay,  that the TW IOS procedure is consistent with the Commission's checklist.
However, I do have a couple of questions/concerns.
First, does "voluntary"  mean filing a proposal with FERC is also voluntary?
Or is the Commission  here requiring that pipelines make filings before they can proceed with  auctions?
Also, I'm not sure we comply with the Commission's policy on  establishment of a reserve price, since it's difficult to tell what that is  from the order.
A couple of times TW has stated a minimum bid in its IOS.
Comments?

TW interactive open season