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From:katherine.kelly@enron.com
To:chris.germany@enron.com, dan.junek@enron.com
Subject:ANR Wins on Transco Interconnect Complaint!
Cc:
Bcc:
Date:Wed, 19 Apr 2000 08:26:00 -0700 (PDT)

---------------------- Forwarded by Katherine L Kelly/HOU/ECT on 04/19/2000
03:25 PM ---------------------------

Enron North America Corp.

From: Rebecca W Cantrell 04/19/2000 02:44 PM


To: Chris Meyer/HOU/ECT@ECT, Ruth Concannon/HOU/ECT@ECT, Theresa
Branney/HOU/ECT@ECT, George Smith/HOU/ECT@ECT, Hunter S Shively/HOU/ECT@ECT,
Ray Hamman/HOU/EES@EES, Carrie Hollomon/HOU/ECT@ect, Robert
Superty/HOU/ECT@ECT, Laura Luce/HOU/ECT@ECT, Cary M Carrabine/HOU/ECT@ECT,
Colleen Sullivan/HOU/ECT@ECT, John Hodge/Corp/Enron@ENRON, Judy
Townsend/HOU/ECT@ECT, Katherine L Kelly/HOU/ECT@ECT, Scott Neal/HOU/ECT@ECT,
Paul Tate/HOU/EES@EES, Stephanie Miller/Corp/Enron@ENRON
cc:
Subject: ANR Wins on Transco Interconnect Complaint!

Well, they will probably file a court appeal, but it doesn't look good.


NGI's Daily Gas Price Index
published : April 19, 2000

ANR Gets Green Light for Transco Interconnect

ANR Pipeline last week won a two-year battle at FERC to build a direct
interconnect to Transcontinental
Gas Pipe Line's mainline facilities at Evangeline Parish, LA --- near
the site of an active natural gas sales
market.

On rehearing, the Commission upheld a July 1998 order granting a
complaint in which ANR accused
Transco of discriminating against it by denying a request to construct
minor interconnection facilities that
would provide its shippers with direct access to gas sales markets on
Transco's system at Evangeline.

Specifically, the Coastal Corp. pipeline has fought to obtain a direct
connection to Station 50, which is one
of several compressor stations on Transco's mainline serving as pooling
points. There, producers and
marketers sell gas to LDCs and other buyers who hold firm capacity on
Transco for shipment to
downstream markets. The gas sale market at Station 50 is said to be a
"premium one."

In order to get their gas to Station 50 now, ANR shippers must deliver
gas via ANR's existing
interconnection on Transco's Central Louisiana Lateral at Eunice, LA,
and then purchase interruptible
transportation (IT) service on Transco for a distance of about 7.4
miles. So, in effect, ANR shippers
currently must pay "stacked rates" for service on ANR's existing
interconnect and for service on Transco's
IT feeder to reach Station 50.

But the Commission last week found that ANR's request for a direct
interconnection at Evangeline was
reasonable under three different analyses. "First, the evidence shows
that Transco has provided no
reasonable justification for denying ANR's request, given Transco's
history of granting such requests made
by similarly situated parties," the order said [CP98-74]. Six pipelines
other than ANR currently have direct
interconnections on Transco's mainline in the Gulf region that were
established prior to Transco's
restructuring under Order 636, and none of the shippers pay an IT rate
in order to get gas to Transco's
mainline markets, according to the order.

Secondly, evidence suggests the denial of an interconnection for ANR
has led to "specific competitive harm
to the operations of sales markets on Transco's mainline," the
Commission said. That's because buyers at
Station 50 have been barred access to the competitively priced gas
supplies that ANR's shippers seek to
offer, FERC noted. Lastly, it said the establishment of the Evangeline
interconnect for ANR was required
under the new five-step interconnection policy for gas pipelines, which
FERC unveiled last week.

In upholding the July 1998 decision, the Commission overturned an
administrative law judge's (ALJ) initial
findings that competition hadn't been adversely harmed at Station 50,
and that FERC's prior approval of the
IT feeder system provided "appropriate support" for Transco to deny ANR
the Evangeline interconnect.

"We are persuaded by the record in this case that ANR cannot offer a
pipeline transportation service
reasonably competitive with those provided by Transco and other
interstate pipelines, without the
Evangeline interconnect, a minor facility consisting of valve access to
Transco's mainline," the order
concluded.

The Commission also rejected Transco's claim that it partly denied
ANR's request for the Evangeline
interconnect because it would have led to a revenue loss on its IT
Feeder system. As the FERC staff noted,
"six other interstate pipelines currently use mainline interconnects
[on Transco].....but no evidence indicates
the extent of even arguably identifiable business loss from these
pipeline competitors," the order noted. If
anything, "Transco has accorded itself an anti-competitive
preference.....to assure that its own IT service is
used in lieu of the potential alternative proposed by ANR."