In general, the comments submitted confirm INGAA’s view that the CIG/Granite State policy is based on an unsupported presumption that shippers with discounted firm primary capacity are similarly situated with any shipper that has previously obtained a discount for either firm or interruptible transportation at any other point on the system. The comments also support the operational and economic concerns, addressed by the Court of Appeals (see Williston Basin Interstate Pipeline Co. v. FERC, 358 F.3d 45, 49-50 (2004), that the policy will discourage economically efficient discounting that contributes to the effective use and management of the system, and encourage uneconomic discounting that benefits only the capacity holder/arbitrageurs. Those commenters urging retention of the CIG/Granite State policy (BP America Production Company, et al. and Dominion Resources, Inc.), and those urging additional restrictions on pipelines’ secondary point pricing (ProLiance Energy LLC), fail to come to grips with the economic ramifications of a regulatory policy that compels pipelines to discount capacity under circumstances that do not justify the discount.