MIGC LLC WRITTEN PROCEDURES: MARKETING AFFILIATE STANDARDS OF CONDUCT 
                           IN COMPLIANCE WITH ORDER NO. 717

I.  BACKGROUND

On October 16, 2008, the Federal Energy Regulatory Commission ("Commission") issued 
Order No. 717 (Docket No. RM07-1-000, 125 FERC ¶61,064) establishing revised Standards 
of Conduct for Transmission Providers ("Standards of Conduct") as set forth in Part 358 
of the Commission's Code of Federal Regulations ("CFR"), which govern the relationship 
between Transmission Providers and their marketing affiliates.  These Standards of Conduct 
revise previous standards promulgated in Order No. 2004 and interim Order No. 690, and 
their progeny. The revised Standards of Conduct apply to any interstate natural gas 
pipeline that conducts transportation transactions with an affiliate that engages in 
marketing functions.

MIGC is a transmission provider as defined in Section 358.3(k)(2) of the Standards of Conduct. 
MIGC conducts no pipeline marketing functions as defined in Section 358.3 (c). MIGC conducts 
transportation transactions with certain of its marketing affiliates, and is therefore subject 
to the Standards of Conduct. 

MIGC LLC ("MIGC") documents herein its written procedures in compliance with Section 358.7(d) 
of the Standards of Conduct.  MIGC reserves the right to amend these procedures and any 
application thereof, in accordance with future regulatory or industry guidance, practices or 
requirements.


II.   SMALL PIPELINE PARTIAL WAIVER

FERC issued an order in Docket Nos. TS04-256 and 266 (July 7, 2004) granting MIGC a small 
pipeline exemption from Order 2004 waiving MIGC's obligation to comply with the independent 
functioning requirement, and waived certain information disclosure prohibitions.  
Order No. 717 at P 31 specifically extended the waivers granted in response to Order No. 2004.  
MIGC's partial waiver from Order 2004 remains in full force and effect with respect to the 
revised Standards of Conduct as stated in Order No. 717.  As a result, MIGC is not required to 
comply with the current Section 358.5 requirement for independent functioning between employees.  
Nor is MIGC required to comply with the Standards of Conduct in Section 358.5(b)(ii) related to 
limiting access and prohibiting disclosure to MIGC information and the contemporaneous disclosure 
posting requirements in Sections 358.7(a) and 358.7(h) of disclosed information.


III. NON-DISCRIMINATION REQUIREMENT 

MIGC will treat all transmission customers, affiliated and non-affiliated, on a not unduly 
discriminatory basis, and must not make or grant any undue preference or advantage to any 
person or subject any person to any undue prejudice or disadvantage with respect to any 
transportation of natural gas in interstate commerce. 
  
MIGC and its employees will apply all tariff provisions relating to the sale or purchase of 
open access transmission service in a fair and impartial manner that treats all transmission 
customers in a not unduly discriminatory manner.  MIGC will exercise discretion only if its 
tariff provisions permit the use of discretion and only to the extent permitted by its tariff.

MIGC may not, through its tariffs or otherwise, give undue preference to any person in matters 
relating to the sale or purchase of transmission service (including, but not limited to, issues 
of price, curtailments, scheduling, priority, ancillary services, or balancing).  MIGC will 
process all similar requests for transmission in the same manner and within the same period 
of time. 


IV.  INDEPENDENT FUNCTIONING RULE 

As discussed in Section II of these procedures, MIGC received an order which remains in full 
force and effect waiving its obligation to comply with the Independent Functioning requirement 
of the Standards of Conduct.

MIGC endeavors, to the maximum extent practicable and in accordance with industry best practices, 
to maintain functional independence between its transmission function employees and the marketing 
function employees of Anadarko.


V.  NO CONDUIT RULE 

MIGC will not use anyone as a conduit for disclosing non-public transmission function information 
to its marketing function employees.


VI.  POSTING REQUIREMENTS

MIGC will post on its Internet website its written procedures implementing the standards of 
conduct, the names and addresses of all its affiliates that employ or retain marketing function 
employees, a complete list of employee-staffed facilities shared by any of the transmission 
provider?s transmission function employees and marketing function employees (including types of 
facilities shared and addresses of the facilities), and the job titles and job descriptions of 
its transmission function employees.

MIGC will post information concerning potential merger partners as affiliates that may employ or 
retain marketing function employees, within seven days after the potential merger is announced. 

MIGC will post a notice on its Internet website of any transfer of a transmission function employee 
to a position as a marketing function employee, or any transfer of a marketing function employee to 
a position as a transmission function employee. The information posted under this section must 
remain on its Internet website for 90 days. No such job transfer may be used as a means to circumvent 
any provision of this part. The information to be posted must include the name of the transferring 
employee, the respective titles held while performing each function (i.e., as a transmission function 
employee and as a marketing function employee), and the effective date of the transfer. 

MIGC will update on its Internet website in readily accessible form, the information required above 
in this Section VI. within seven business days of any change and post the date on which the 
information was updated, except in the event of an emergency, in which the posting requirements in 
this part may be suspended by the transmission provider as outlined in Section 358.7(g)(2) of the 
Standards of Conduct. 

Posting of waivers - MIGC must post on its Internet website notice of each waiver of a tariff 
provision that it grants in favor of an affiliate and maintain a log of the acts of the waiver 
in accordance with Section 358.7(i) of the Standards of Conduct.


VII.  CHIEF COMPLIANCE OFFICER

MIGC's Chief Compliance Officer (CCO) will be responsible for compliance with the Standards of 
Conduct applicable to MIGC and shall be identified, along with all contact information, on the home 
page of MIGC's website, as well as under the Standards of Conduct link.  The CCO is responsible for 
compliance and enforcement of the Standards of Conduct applicable to MIGC and MIGC's written 
procedures, with ultimate responsibility for monitoring compliance.  The CCO is the initial contact 
for the Commission Staff.

All Anadarko employees are obligated to report any known noncompliance with or violation of these 
written procedures or the Standards of Conduct applicable to MIGC.


VIII.  TRAINING

MIGC and Anadarko transmission function employees, marketing function employees, officers, directors, 
supervisory employees, and any other employees likely to become privy to transmission function 
information (the employees designated in Section 358.8(b)(2) of the Standards of Conduct) will 
receive initial training as required by Order No. 717.  Annual training for the identified employees 
will occur at least once a year after the completion of the initial training, and MIGC will provide 
training to new employees in the categories listed above within the first 30 days of their employment.  
MIGC will train the identified employees either through live training or through third-party training 
software, which will include discussion of the Standards of Conduct general principles, their 
applicability, and details pertaining to MIGC's implementation of the Standards of Conduct.  All 
employees who have taken the training will certify electronically or in writing that they have 
completed the training.  MIGC will distribute these written procedures to all employees who 
have been trained, as identified in Section 358.8(b)(2) of the Standards of Conduct.  


IX.  BOOKS AND RECORDS

MIGC shall maintain its books of account and records separately from those of its affiliates 
that employ or retain marketing function employees, and shall make these books and records 
available for Commission inspections.


X.  OTHER

MIGC will periodically review its website and written procedures to ensure compliance with the 
Standards of Conduct posting requirements.