Drew, here's an excerpt from a FERC letter order accepting for filing a 
nonconforming agreement filed 
by Dynegy Midstream...sounds a little bit like what the TW guys are trying to 
do, if I understand the 
concept of volumetric rates correctly.  Left a message for my friend at DMP 
but he (like everyone else)
is out 'til next year.  But since there were no subsequent orders issued in 
the docket I assume there were 
no problems with the filing.

I'm still leaning towards recommending the $0 demand/ $0.02 commodity + file 
as nego. rate approach.
If Steve Harris is OK with the idea of doing a deal that requires filing, I 
will draft something and send it your way.

* * *
The referenced negotiated transaction provides for a transportation service 
under DMP's Rate Schedule
FTS. Rather than paying a reservation charge, the negotiated agreement 
specifies that KGS will pay
a volumetric rate. The volumetric rate will equal DMP's maximum interruptible 
transportation service rate as
set forth in DMP's tariff. . .The contract also (a) specifies five Dth/d as 
KGS' maximum daily reservation 
quantity, (b) lists KGS' primary receipt as Meter # 9999999 and (c) 
identifies five primary delivery points for 
KGS. . . Upon filing Docket No. RP99-240-000, DMP stated that it agreed to 
the above negotiated rate so 
that KGS could serve small residential customers on DMP's system under a firm 
rate schedule.