PNM filing: shipper must have title

When the Commission granted Texas Eastern authority to hold capacity on
another pipeline in Texas Eastern Transmission Corporation, 74 FERC P 61,074
(1996), it stated that when a pipeline holds capacity on an upstream
pipeline, the downstream pipeline's customers may hold title to the gas
transported on the upstream pipeline. The Commission recognized this as one
of the limited exceptions to the shipper must have title rule. Specifically,
the Commission stated:

The downstream pipeline will not hold title to gas shipped on capacity it has
acquired on an upstream
pipeline. Rather, shippers on the downstream pipeline will hold title to the
gas on the upstream
pipeline. We will allow a pipeline to hold the upstream capacity; we will
not, however, allow the pipeline
to hold title to the gas being shipped. Thus, the downstream pipeline will
be the shipper on the upstream
pipeline, but will not hold title when the gas is being shipped. This results
in a limited exception to the rule
that a shipper must hold title to gas being shipped.

I believe that if we can address the Commission's other concerns about this
filing, they will grant a similar waiver for this transaction. You can feel
free to pass this along to your contact at PNM.