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Lad is such a weasel. | dev41 |
Why don't we try to talk sometime this a.m. | dev41 |
Tony, I thought there would be a case that stated that if an interstate pipeline posts the criteria under which it will evaluate capacity bids, it must stick to those criteria and not award the capacity to a bidder on some other basis. | dev41 |
It seems a simple enough extension of the principle that capacity must be awarded on a nondiscriminatory basis. | dev41 |
However, I did not find any case that stands for that exact proposition. | dev41 |
As you may be aware, the Commission made Natural Gas Pipeline Company of America (NGPL) come up with a way to ensure that it awarded capacity one a nondiscriminatory basis...because NGPL was found to have been giving preferential treatment to its shippers. | dev41 |
NGPL's solution was to come up with an auction process, and there is a whole line of cases if you're interested. | dev41 |
The underlying presumption is that if you set up a system under which all capacity is awarded and stick with that system, there is no way you could be acting discriminatorily. | dev41 |
But of course the Commission never comes out and says this even though it should be obvious. | dev41 |
Probably the best we can do is extrapolate from 1) the tariff and 2) the NGA (doesn't it also say we have to provide service on a not unduly discrim. basis?). | dev41 |
Also, in your memo I'd give an example; i.e., if we notify shippers of our auction process and set a deadline for bidding, but then award the capacity to Sempra (assuming Sempra requested capacity after the posting), we will have unduly discriminated against all the other shippers who had to participate in the auction process. | dev41 |
Maybe in future postings on Enrononline we should include a statement to the effect that the capacity posted will not be awarded except thru the Enrononline process. | dev41 |
Now for some trivia. | dev41 |
Remember we were discussing with Shelley whether we could post a different method (other than that prescribed in the tariff) for determining best bid? | dev41 |
In my Westlaw search I ran across the relevant case. | dev41 |
In Northwest Pipeline, 85 FERC P 61,335, the Commission stated: "The Commission has previously given pipelines the leeway, in open season provisions, to either include in their tariff a single non-discriminatory bid evaluation methodology, or provide themselves the flexibility of choosing different non-discriminatory bid evaulation methods for different transactions, provided that the pipeline posts the bid evaluation methodology before the bidding process begins." | dev41 |
The only problem is I am not sure we have that "flexibility" since the tariff does not expressly allow us to post a different method. | dev41 |
Maybe next time we do a tariff cleanup we could add some language allowing us to do so. | dev41 |
I have to move on to my next project but if you want me to comment on what you write I'd be happy to. | dev41 |
If I remember correctly, we'll need to paper the additional Sempra capacity, either with an amendment or a separate agreement. | dev41 |
I'll be in the office by about 9:30 and we can talk about it then. | dev41 |
Phil Richardson and Sarah Tomalty of Dynegy say that they would probably (i.e. subject to management approval) withdraw their protest if we would amend our proposed tariff language to limit the quantity of capacity we can acquire from PNM to 20,000/day. | dev41 |
Their chief concern is to prevent TW from becoming simply a broker for another pipeline's capacity (which has never been our intention). | dev41 |
Lorraine is discussing this with Steve to see whether this is something we could live with. | dev41 |
The Commission has expressed the same concern in the past, so this might make them more comfortable with our proposal too. | dev41 |
Comments? | dev41 |
let me know. | dev41 |
I know that you've already indicated that you will circulate a draft of the late-filed exhibit by Friday, but if you have a draft we could look at sooner, that would be great...TW's business people who need to look at it will be out at the beginning of next week. | dev41 |
Thanks. | dev41 |
Something's up with our e-mail, but I did receive it finally. | dev41 |
Thanks. | dev41 |
I would expect that Sarah Tomalty will attend anyway to make sure we make good on our promise. | dev41 |
Brian, Transwestern has reviewed your draft exhibit responsive to Judge Biren's inquiry on June 7. | dev41 |
We appreciate your work on it and generally agree with the exhibit and the approach taken by SoCalGas. | dev41 |
However, we think it appropriate to balance simplicity with the need to be responsive to Judge Biren's questions. | dev41 |
See the attached marked-up version of the exhibit. | dev41 |
We've attempted to streamline the data provided for "non-Wheeler" points, and to clarify the footnotes regarding Wheeler Ridge. | dev41 |
Also, we've modified the numbers regarding the TW Topock lateral to accurately reflect the lateral's 400 MMcf/d physical capability. | dev41 |
We've also made some minor formatting changes. | dev41 |
Let us know what you think. | dev41 |
Jeff Fawcett Susan Scott Transwestern Pipeline Company | dev41 |
Tony, I'd love to see our posting on EnronOnline -- do you know if there's an easy way for us "insiders" to access it? | dev41 |
You got mail from Norm! | dev41 |
In response to your inquiry, Transwestern would first like to clear up the terminology being used here. | dev41 |
As you know, currently SoCalGas doesn't assign "primary rights" to deliveries off of any interconnecting pipeline. | dev41 |
The establishment of tradeable rights for intrastate capacity is among the issues currently under consideration in the GIR proceeding. | dev41 |
However, if what you are asking about is what has been the historical or otherwise available receipt capacity for Transwestern deliveries at North Needles, then let me offer the following. | dev41 |
Transwestern has always operated on the premise that SoCalGas could physically accept up to a maximum of 750 MMcf/d at its North Needles receipt point. | dev41 |
Consequently, Transwestern has sold firm transportation to its interstate customers for west flow deliveries to North Needles not to exceed the 750 MMcf/d limitation. | dev41 |
Our west flow mainline capacity is 1.09 Bcf/d. | dev41 |
Mike -- Thanks for the input...we stewed over this for a while but decided to respond (as briefly as possible) rather than give Norm a chance to whine to the judge that we were being uncooperative in this somewhat unusual exhibit drafting process. | dev41 |
Jeff's answer is consistent with what will appear in the exhibit (and from what one can find out about TW in numerous of our FERC filings, for that matter). | dev41 |
If Norm tries somehow to make Jeff's response part of the record you can bet I will object...if it's not on the record already, or on the face of this one late-filed exhibit, it should not be allowed into the record. | dev41 |
Apparently Norm has also called Rich Hall with annoying questions. | dev41 |
I don't plan to respond if he contacts us with any follow-up, but will let you know if he does. | dev41 |
WRONG!! | dev41 |
Mike, obviously this is unacceptable. | dev41 |
Norm's exhibit contains factual inaccuracies we cannot live with. | dev41 |
I'm assuming the rest of the group will react similarly and Norm will be stuck filing his own exhibit. | dev41 |
Your thoughts? | dev41 |
Brian, just so you know Transwestern's reaction, Pedersen's exhibit contains factual inaccuracies we cannot live with (e.g., footnote 4). | dev41 |
If he wants to file his own exhibit he is certainly free to do so. | dev41 |
We don't plan to offer any comments to Norm regarding his exhibit at this time. | dev41 |
With regard to the exhibit you sent us yesterday, while Transwestern feels there are many different ways to characterize delivery capacity to the border, and we probably would have drafted the document differently, we would support SoCal's filing of the exhibit with the Commission as it is currently drafted for purposes of this proceeding. | dev41 |
Any questions or comments -- let me know. | dev41 |
I'm planning to be out August 28 - Sept 1. | dev41 |
Read the very bottom.... | dev41 |
Compliments of your minion. | dev41 |
(just so you know where we ended up last Fri.) | dev41 |
Brian -- TW does not agree with the changes proposed by El Paso. | dev41 |
If we need to discuss this further please e-mail or call. | dev41 |
Thanks. | dev41 |
Susan Scott Transwestern Pipeline Company | dev41 |
Amazing that TW has not one but TWO people doing this job. | dev41 |
Your tree-saving efforts are admirable. | dev41 |
Attached is a preliminary draft of a filing for capacity options on Transwestern. | dev41 |
The attachments include a filing letter, proposed tariff language and a proposed form agreement. | dev41 |
Obviously there are still quite a few details to be worked out. | dev41 |
I am distributing a draft at this early stage in hopes of initiating a dialogue about the larger issues first. | dev41 |
A few that come to mind are whether we want to commit to selling options online, how best to explain or justify the option fee, and what specifically in the industry has changed such that FERC should depart from existing policy and allow TW to essentially reserve future capacity for shippers. | dev41 |
Please let me know your thoughts on these and any other issues. | dev41 |
I would prefer to wait to discuss comments on wording, other conforming changes to the tariff, and other comments concerning form until after we have resolved the substantive issues. | dev41 |
Thanks. | dev41 |
With regard to capacity release I think we will have to give the replacement shipper the cash-for-fuel option, because what if we have sold capacity that was created by the releasing shipper's buying fuel from us? | dev41 |
If the replacement shipper suddenly starts shipping fuel, that capacity goes away. | dev41 |
(It's sort of like the EFBH/resulting forward haul problem). | dev41 |
Probably we should require that the cash for fuel election automatically transfer to the replacement shipper. | dev41 |
This would probably have to go into our tariff someplace when we make our FERC filing; otherwise it might run contrary to our current tariff provisions and practice. | dev41 |
Another solution might be to just sell resulting capacity as LFT, daily FTS-1 or even FTS-3 capacity (with some modifications to the FTS-3 Rate Schedule, of course), which would allow us the flexibility not to schedule on certain days. | dev41 |
For longer-term deals this might not be practicable, though. | dev41 |
Further questions...let me know. | dev41 |
Ramona, "total cost commitment" in TW's tariff generally means total revenue to be received from a transaction, taking into account reservation rate, the term of the commitment, and the commodity revenues associated with any minimum throughput commitment the shipper may make. | dev41 |
Obviously some of these items aren't applicable in the PNR context; the language must have just been lifted from another part of the tariff. | dev41 |
For PNR we would just multiply rate times number of days the service will be used. | dev41 |
Practically speaking, I'm not sure how this is done if you have an interruptible service with no throughput commitment, but I think you should just be able to use the number of days in the contract term. | dev41 |
If there's a tie (i.e. more than one shipper willing to pay at or above max rate), we just allocate the capacity pro-rata. | dev41 |
We do not have to offer a right to match. | dev41 |
This may appear to be somewhat of a random email, but I assure you there exist some semblence of reason. | dev41 |
I remembered you mentioning that neither you nor Pat have ever made a pilgramige to Blanco's. | dev41 |
So...I thought I should let you know that there is live music and cold beer on tap tonigt at the Big B. Anyway it should be pretty good. | dev41 |
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