UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
 
 
 

Regulation of Short-Term Natural                       ?            Docket No. RM98-10-000

Gas Transportation Services                   ?
 
 
Regulation of Interstate Natural                       ?                Docket No. RM98-12-000
Gas Transportation Services                   ?
 
 
 
MOTION TO INTERVENE AND COMMENTS
OF THE ENRON INTERSTATE PIPELINES
 
 
            Pursuant to the March 21, 2001 Notice of Petition in the above-referenced proceedings and Rules 212, 212 and 214 of the Federal Energy Regulatory Commission's ("Commission") regulations (18 C.F.R. ? 385.211, 385.212  and 385.214 ), the Enron Interstate Pipelines hereby move to intervene and respond to the March 16, 2001 Petition of the American Gas Association ("AGA Petition").
 
I.
            All correspondence and communications with regard to this filing should be directed to:
 
Shelley A. Corman
Vice President, Government Affairs and Public Relations 
Enron Transportation Services Company
1400 Smith Street, P.O. Box 1188
Houston, TX  77251-1188
Phone:  713-853-7083
Email:  shelley.corman@enron.com
 
Nancy E. Bagot
Enron Transportation Services Company
Manager, Government Affairs
Washington, DC  20006
Phone:  202-466-9148
Email:  nancy.bagot@enron.com
 
II.
MOTION TO INTERVENE
The AGA Petition raises issues that are directly related to the operation of pipelines.
2.      Enron operates a number of interstate pipelines subject to the jurisdiction of the Commission under the Natural Gas Act.  In some cases these pipelines are wholly-owned subsidiaries, in other cases Enron is a part owner.  These interests are collectively referred to herein as the Enron Interstate Pipelines.
The Enron Interstate Pipelines have currently pending Order No. 637 compliance filings and may be affected by the outcome of this proceeding, and thus have a direct and substantial interest in this proceeding that cannot be adequately represented or protected by any other party.  Thus, the Enron Interstate Pipelines' participation is in the public interest.
III.
COMMENTS
            The Enron Interstate Pipelines wholly support the Response of the Interstate Natural Gas Association of America filed this day and incorporate the comments made therein.
            Like INGAA, the Enron Interstate Pipelines take issue with both themes of the AGA Petition.  First, the Enron Interstate Pipelines take issue with the procedural request to implement the new capacity release timeline separately from Order No. 637 proceedings or GISB compliance filings.  Second, the Enron Interstate Pipelines wish to once again voice concerns about the far-reaching impacts of the flowing day recall rights that the AGA petition advocates.   
            Rather than repeat those concerns again here, we have attached a copy of comments that were submitted to the GISB Executive Committee during the discussion of whether GISB should remove the current prohibition on partial day recall rights.  
            For the reasons set forth in both INGAA's response and the attached comments of the pipeline segment, the Enron Interstate Pipelines ask the Commission to deny the AGA Petition.


 
 
 
December 8, 2000
 
To:      Gas Industry Standards Board 
From:            Pipeline Segment
 
Re:            Business Practices Subcommittee Priority Action Items 1 and 2 and R00026 
 
 
At the scheduled December 14, 2000 GISB Executive Committee meeting, the agenda includes a discussion and vote on Recommendations and Proposed Standards.  This agenda item contains certain BPS proposals related to implementation of Order No. 637 requirements and related standards such as R00026.   Among the proposals are new or revised standards for capacity releases and recalls which include support for intraday capacity releases and would remove current GISB restrictions against partial-day recalls. 
 
Our fundamental concern with the proposed standards is that they do not fully address the far-reaching impact of flowing day recalls.  There are significant operational concerns with these standards.  We are concerned about whether the operational provisions are in place to ensure that the recalled party does not continue to flow, particularly during critical periods.  We are concerned about whether current GISB communication time frames are adequate for handling the ripple effect of flowing day recalls across the grid.   The proposed standards address only one narrow operational concern - whether gas has been scheduled on the particular contract to be recalled.  This does not begin to address the operational challenges of the recall or the potential impact to other transactions across the grid.  
 
Given these operational concerns, we do not understand the rush to adopt flowing day recall standards.  While we understand that this work is in response to R00026, we do not believe that flowing day recalls are necessary to fulfill the scheduling equality requirements of Order No. 637.   Order No. 637 requires that replacement shippers have the same nomination opportunities as shippers acquiring original capacity.  There are no existing pipeline contracting or scheduling functions that are the equivalent of the recall of capacity by a releasing shipper. Very few pipelines have received authorization to sell hourly services and most pipeline tariffs prescribe a uniform hourly flow rate throughout the day.   Further, most pipelines have not yet received approval to implement balancing provisions to address daily price fluctuations or intraday variability. 
 
In the spirit of compromise, we have worked on and concurred with revised standards that permit intraday releases.  However, under these revised standards, all capacity release options continue to be available only on Business Days to insure that the proper contractual relationships and notice provisions are supported.  Nonetheless, throughout the negotiations on this compromise approach, the pipelines have made it clear we cannot support the proposed flowing day recall standards.  
 
Aside from our opposition to the flowing day recall standards, the pipelines have agreed to other recall standards that are more liberal than are supported by the existing standards.  In this area, we have agreed to support a revised standard which will permit capacity to be recalled for transactions in the Evening Nomination Cycle.  This allows a releasing shipper to recall capacity until the afternoon of the day prior to gas flow.  While this timeline supports a shorter notice for recalls, it still preserves the application of the full-day contract entitlement and gas flow rights for both the releasing and the replacement shippers.  Flowing day recalls, though, are a separate issue.  Flowing day recalls could significantly increase the incidence of scheduling problems, overruns, imbalances and increased occurrences of Operational Flow Orders.  Because of the potentially disruptive nature of flowing day recalls, pipelines cannot support the proposed flowing day recall standards. 
 
Any move from daily increments of service to partial-day increments of service must be undertaken in the context of all services offered on each pipeline system, including firm services, interruptible services, and balancing and operational provisions. Because these developments involve changes to tariffs and customers service offerings, this is not an area that is currently ripe for GISB development.
 
The attached Pipeline Segment position paper incorporates the concepts identified above into the BPS recommendation and is offered as an alternative to the BPS recommendation.
 
 


 
April 16, 2001
 
 
 
Mr. David Boergers, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Office of the Secretary, Room 1A, East
Washington, D. C. 20426
 
Re:               Docket No. RM98-10-000
               Docket No. RM98-12-000
 
Dear Mr. Boergers:
 
               Enclosed for filing with the Commission in the captioned docket are an original and fourteen (14) copies of "Motion to Intervene and Comments of The Enron Interstate Pipelines" in the captioned proceeding.  Also enclosed are three extra copies to be file-stamped and returned to the messenger.  These comments have also been submitted electronically through the Internet e-mail.
 
Very truly yours,
 
 
 
Shelley A. Corman, Vice President
Enron Transportation Services Company
 
For the Enron Interstate Pipelines