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Enron Mail |
I'm forwarding the attached as an update. Am presently researching the issue
raised by Drew, and will let you know what I find. ---------------------- Forwarded by Susan Scott/ET&S/Enron on 03/13/2000 08:50 AM --------------------------- From: Drew Fossum 03/13/2000 07:51 AM To: Susan Scott/ET&S/Enron@ENRON cc: Mary Kay Miller/ET&S/Enron@ENRON, Mary Darveaux/ET&S/Enron@ENRON, Glen Hass/ET&S/Enron@ENRON, sstojic@gbmdc.com Subject: Re: TW acquisition of capacity on PNM I found the reference I was remembering over the weekend. Check out the order issued to TriState Pipeline at Docket CP99-61. FERC got all over CMS on the problems posed by "dual jurisdictional facilities" whatever that means. CMS tried to do something that sounds a lot like what PNM would be doing under the idea you guys had. ---------------------- Forwarded by Drew Fossum/ET&S/Enron on 03/13/2000 07:48 AM --------------------------- From: Drew Fossum 03/12/2000 08:37 PM To: Susan Scott/ET&S/Enron@ENRON, Glen Hass/ET&S/Enron@ENRON, sstojic@gbmdc.com, Mary Darveaux/ET&S/Enron@ENRON, Mary Kay Miller/ET&S/Enron@ENRON cc: Subject: Re: TW acquisition of capacity on PNM Interesting. Assuming we could satisfy the Texas Eastern criteria (which would be tough given that this is a firm service, unlike our market center service), we still need to think about PNM's situation. The letter says they are a Hinshaw. This deal would seem to blow their Hinshaw exemption. There is some new law on use of capacity on a Hinshaw for interstate service, only I think it involved a capacity lease instead of service agreements. I think it was one of the Northeast pipeline cases involving CMS. Does PNM know that we would use their service for interstate transportation? If we can crack the Hinshaw issue, this might be worth a shot. DF Mary Kay Miller 03/11/2000 11:22 AM To: Susan Scott/ET&S/Enron@ENRON cc: Drew Fossum@ENRON, Glen Hass/ET&S/Enron@ENRON, sstojic@gbmdc.com, Mary Darveaux/ET&S/Enron@ENRON Subject: Re: TW acquisition of capacity on PNM Mary, I was unable to forward the attachment-- so try to get it form Glen Susan, I don't think it is a problem to try this, however, do we have the current rates including fuel etc that we would have to pay and how much capacity would we be acquiring? Need to see this- MK From: Susan Scott 03/10/2000 04:14 PM To: Drew Fossum@ENRON, Mary Kay Miller/ET&S/Enron@ENRON, Glen Hass/ET&S/Enron@ENRON, sstojic@gbmdc.com cc: Subject: TW acquisition of capacity on PNM The Commercial Group has been discussing with PNM the possibility of entering into service agreements for firm capacity on the portion of PNM's system between Blanco and Rio Puerco. This would effectively operate as an expansion of TW's system from the San Juan Basin to the mainline. TW would acquire PNM capacity then post it as available on the EBB just like we post other capacity. Shippers could then use the capacity to transport gas from Blanco to any point on TW's system. The capacity that PNM has available at this time is seasonal (summer months) only, so it would be used to provide short-term firm capacity or LFT to TW customers. The marketers anticipate that the additional capacity would mostly be used to ship gas to points on TW's mainline besides Rio Puerco -- in other words, the total path used by shippers would be a combination of PNM's system and TW's system. Shippers wouldn't necessarily know whether PNM capacity was being used to provide service on their contract, only that their gas is being shipped from A to B. In re-reading the Texas Eastern line of cases, I believe we can distinguish TW's proposal from that in Northern's Docket No. 97-388 because it is more specific (we are asking for authority to acquire capacity on a specific pipeline) and because it is more in the nature of an expansion of TW's constrained San Juan lateral rather than a proposal to broker other pipelines' capacity. I may be overly optimistic, but I also believe we meet all the Texas Eastern criteria. I realize that I have not discussed this very extensively (or at all) with any of you, but I have gone ahead and drafted the proposal in the form of a letter to FERC. It seemed the most efficient way to provide a starting point for discussion, especially since I was able to borrow heavily from our successful Market Center Services filing. I'm not yet sure where we will include it in the tariff, but I propose tariff language along the lines of "Transporter may contract for firm transportation service on Public Service Company of New Mexico for use in providing transportation service from the Blanco receipt point on Transporter's system. The cost incurred for acquisition of any such services shall be separately recorded in Account No. ___. Transporter is at risk for recovery of costs associated with such services." After you've reviewed the attached, please let me know your overall substantive comments and let's talk about the best way to proceed. Thanks.
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