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Enron Mail |
Christine -- Here's a brief answer to your questions.
With regard to segmentation, Order 637 is completely silent with regard to rates to be charged for segmented capacity, so we would have considerable leeway here. The order is also silent with respect to the effective restriction of segmented capacity by making discounts inapplicable to certain alternate (or primary) points. Hopefully TW will be able to avoid the segmentation issue altogether by invoking the Global Settlement, as we plan to do in our rehearing request and compliance filing. (Our Global Settlement argument is that we should be able to rely on tariff provisions, including our current restriction on changing primary points, that were implemented to mitigate the effects of turnback on TW). On hourly service, I believe that we could put an hourly service into place on TW without running afoul of the Peak and Off-Peak Rates (i.e., seasonal rates) provisions of the order. In other words, I think the Commission would see them as two separate kinds of service. As for how to communicate with our customers, I believe Regulatory has offered to have a meeting with TW customers in early April to make a presentation on Order 637 and provide a forum for discussion. I realize the order becomes effective March 27; however, compliance filings are not due until May 1, and some requirements do not even become effective until September 1. Before the beginning of April, the GPG pipelines will simply not have their positions fully formed enough to make a very well-organized presentation to persons outside the company. The meeting is still in the planning stages and I will fill you in on details as they are available. In the meantime, if your customers have questions, I'll be happy to help answer them. Christine Stokes 03/02/2000 10:32 AM To: Susan Scott/ET&S/Enron@ENRON cc: Steven Harris/ET&S/Enron@ENRON, Kevin Hyatt/ET&S/Enron@Enron, Jeffery Fawcett/ET&S/Enron@ENRON, Lorraine Lindberg, Lindy Donoho/ET&S/Enron@ENRON, TK Lohman/ET&S/Enron@ENRON Subject: 637 Summary Items Thanks Susan for the 637 summary. Here are a couple of items that I need additional clarification on: 1) Segmentation - You summarized " Pipelines must allow segmentation to the extend operationally feasible and cannot hide behind current tariff provisions ... " Does this mean, for example, an Ignacio to California contract (i.e. 40,000 Dth/d at a $.20 total path rate) could be segmented by the shipper such that on any single day they could nom 40 MM/d from Ignacio to El Paso Blanco as well as 40 MM/d from Blanco to California? If they could, would the $.20 apply to each segment such that we could bill them 80 MM/d ($.20) for the time period that they flowed on a segmented basis or would they only pay the $.20 applied to the contract's 40 MM/d MDQ? Another scenario would be if the shipper is allowed to flow based on this segmented basis, but unless the discount letter providing the $.20 specifically provides for a negotiated segmented transport rate the shipper will be billed MAX rate for some or both of the segmentated paths (?) if these paths are not already provided as "alternate" receipt or delivery paths? 2) Peak & OFF-Peak Rates. - You summarized " The policy does not apply to long-term shippers with contracts for 12 or more consective months of service." TW will eventually file for hourly rates, however, the parties most interested in this service will be marketers serving a generation station, or the generation station's own gas supply manager/purchaser. Most likely these contracts WILL BE of a longer term nature than month to month or even seasonal. I need to reconcile your summarized comment to what we will expect from the marketplace. Thanks for your feedback. Since 637 is effective March 27th, I am eager to be able to speak intelligently to my customers regarding some of these more critical issues. Thanks.
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