Spreadsheet: jane_tholt__13151__El Paso Tariff Hearings
Sheet: Sheet1

El Paso Tariff Hearings
Issues ( Major) | Explanation | Commercial Issues | Enron Response
Full Requirements Contracts | Full Requirements Customers are shippers who are obligated to transport "full requirements" solely on EPNG.  They have unlimited access to firm capacity at no additional demand charges.  Capacity rights are defined by physical capacity at any delivery point.  Growth rights are integral. | The FR service for East of California customers is a significant contributing factor to the shortfall of transportation capapcity on El Paso.  [NAME] have increased over 50% since rate case settlement. | Full Requirements customers should be converted to CD customers.  Such view is shared by all non-EOC customers including FERC staff.  Capacity on El Paso must be rationalized.  There should be an immediate request for CD turnback to fulfill any shortfall of capacity.  Requesting that [NAME] delivery points be established as receipts points to allow for interruptible back-hauls to EOC points.
Which study should be used to allocated FR customers to CD | Study1-FR load for each shipper based on non-coincidental peak day demands (NCPs) during the test period for Docket No. RP 95-363 rate case.  Study 1B-FR load for each shipper based on coincidental peak day demands (CPs) during the test period for the rate case.    Study 2-FR load for each shipper based on the BDs agreed to in rate case. Assumed west flow capacity at Window Rock and Cornudas total 4544mmcf/d.  Study 3-FR load for each shipper based on NCP's during most recent 12 calendar months.  Study 3B-FR load for each shipper based on NCPs during the most recent 12 calendar months.  [NAME] load for each shipper based on projected demand regardless of whether peak day occurs in winter or summer.  Study 4B-FR load for each shipper based on the greater of the aggregate projected demand for the FR shippers.  Study based on projected winter loads for FR customers. | The FR customer's NCPs in rate case totaled 1127 MDTH/d while CPs totaled 791 MDTH/d .  Study 1 shows that they system was never designed to supply each shipper's NCP simultaneously.  Study 1B shows El Paso had the design capapcity to handle coincidnetal peak loads on the system w/out the addition of Line 2000expansion facility. Study2-Displacement on SJ/Permian Xover required to meet obligations.  Study 3-FR NCP's for the most recent 12 months (July 2000-June 2001) totaled 1949 MDTH/d while their CP's totaled 1085 Mdth/d. The NCP's are 1161 Mdth/d greater than the BD agreed to in rate case and the CP's are 297 Mdth/d greater. The quantity of capacity sought exceeded they system capacity for both the NCP and CP based studies (by 862 MDTH/d in the study using NCPd and by 35 Mdth/d in the study using  CPs) Such studies demonstrate the impact of the growth on FR loads. Study 4-FR- loads clearly exceeds the system capacity .  Projected demands represent an increase of 1772 MDTH/d over the NCP's in rate case and an increase of 951 MDTH/d over the NCPs over last 12 months.  The quantity fo capacity sought exceeded the system capacity by 1791 MDTH/d for Study 4A and 1364 Mdth/d for Study 4b. | Allocations should be based on Study 3B.  Should not rely on any displacements to meet firm obligations because direction of flow could change over time.  After customers have had opportunity to turn back customer then El Paso should consider expanding system to meet growing needs on system.
Pooling vs. individual receipt points | El Paso is proposing to path system and eliminate system-wide receipt points.  Concurrently,  El Paso is proposing to increase the number of pools from 6 to 20.  Rights would be pathed from such receipt points. | Initial non-binding elections of receipt points showed an averaged allocation was 62% San Juan and 38% Permian. Pathing system would eliminate flexibility of all receipt point contracts.  San Juan producers could be allocated permian receipt points on their transportation contracts.  Capacity constraints should be eliminated or minimized allowing full utilization of CD if the system is pathed.   Liquidity at the smaller pools will be non-existent.  This has been proven when El Paso broke up Keystone in to plains and waha.  Those 2 pools rarely trade. If pools further subsivided, may impair ability to fully utilize primary receipt points as well-heads decline or volumes leave El Paso's system for other pipelines since most of El Paso's gas is split-connected.  Another way for El Paso to collect demand charges and not allow shippers to utilize contracts. | Support pathing system.Oppose 20 pools.  El Paso has been hiding pools as the reason for cuts on their system when in actuality the constraints exist downstream of the pools.  El Paso has provided no justification for the 20 pools citing only potential constraints which may exist.  No guarantee of gas behind the points. Breaking up pools diminishes liquidity-proven in the waha and plains pool.  May be forced to use alternate receipt points to fill transport obligations.  Another tool for El Paso to collect demand charges and not provide service.
SoCal's Request to switch receipt points among contracts | Socal asked if receipt points could be switched amongst various contracts. | Parties with numerous contracts can "stack "their transportation agreements. | Enron opposes. Would allow undesirble receipt points to be established on contracts due to terminate or eligible for potential term back or are uneconomical to flow  leaving desirable receipts points on the most desirable contracts.  Provides unfair advantage.
Demand Charge Credits if no CD turnback | Many parties are requesting immediate relief in the form of demand charge credits | Currently only 70% of firm transport is flowing | ENA supports and requests some form of compensation.
OFO Orders | Reliance on displacement ot meet firm obligations | May require parties to flow uneconomically to meet EPNG firm obligations to others. | Oppose.
Seasonal Requirements | No specific proposals as of yet.  Still in discussion. |  | CD customers should have same rights as FR to shape loads.