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Enron Mail |
As you know, we recently did an east-to-east deal with USGT for 400,000
MMBtu/day with alternate rights to California at a higher rate. SoCal filed a protest and I'm working on the response. In part, they are alleging that TW is "attempting to exploit a weakness" in the GISB procedures to the detriment of existing customers. For example, under TW's tariff (which they concede is GISB compliant), primary firm cannot bump alt. firm in cycle 2. SoCal says this means that any primary shipper attempting to deliever to an in-path alt. point will be unable to re-nominate to its primary point once this "alternate" capacity [I assume they mean USGT's] is confirmed. According to SoCal this will substantially limit shippers' flexibility, including the ability to use market area pooling. Once gas is nominated thru a pool its subsequent movement to a delivery point is defined as an al. delivery regardless of the rights of the capacity under which it moves. Thus by manipulating the GISB cycle process, TW and USGT will bump firm shippers. I could really use your help in responding to this argument. (First of all, I'm not sure I even understand it!) If either of you have a few minutes today or tomorrow when we could get together, that would be great. Also -- you two were the first to come to mind, but feel free to refer me to someone else in your group if you are swamped. Please e-mail or call when you get a chance... Thanks! Susan (x30596)
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