Have you guys met/discussed this with Michele?  Please get me up to speed.  
Thanks DF  
---------------------- Forwarded by Drew Fossum/ET&S/Enron on 08/24/2000 
09:54 AM ---------------------------
   Michele Winckowski                08/17/2000 01:39 PM

To: Drew Fossum/ET&S/Enron@ENRON, Mary Kay Miller/ET&S/Enron@Enron, Maria 
Pavlou/ET&S/Enron@ENRON, Dari Dornan/ET&S/Enron@Enron, Glen 
Hass/ET&S/Enron@Enron
cc: Keith Petersen/ET&S/Enron@ENRON, Jeffery Fawcett/ET&S/Enron@ENRON, Susan 
Scott/ET&S/Enron@ENRON 

Subject: Re: Caithness Big Sandy, LLC. Project  

As you are aware, Transwestern is working with a shipper to potentially 
provide service to a new power plant located approximately 40 miles off the 
mainline in Arizona.  Although, the final negotiation are not complete 
certain options are being evaluated, I need some assistance in interpreting 
the regulations regarding the authority we should use for approval of this 
project.  

The facilities that would be constructed include a delivery point and 
approximately 40 miles of pipe.  As these facilities are non-mainline, it may 
be possible to construct the proposed facilities under the prior notice 
provisions of TW's blanket certificate, provided the project satisfies the 
blanket criteria (generally costs and environmental).

With this in mind, I have the following issues and questions:

Preliminarily, marketing is thinking that we may want to develop an 
incremental rate  to recover the cost of the project.

Would a new incremental rate for this service impact our ability to file for 
approval under the prior notice provisions?  Note: Generally, Subpart F of 
Part 157 (blanket regulations) does not address service issues as 
transportation service is provided under Part 284 of the Commission's 
regulations.  However, the regulations (o157.204)  set forth Who may apply 
for a blanket certificate.   The criteria includes, among other things, any 
interstate pipeline that has rates accepted by the Commission.  Therefore, 
would an incremental rate have to be approved by the Commission before the 
proposed facilities would be blanket eligible?

Can a new incremental rate be established through a limit-section 4 rate 
filing or is a case-specific certificate required?

As the facilities will not include any mainline expansion - Is an open season 
required for the project?  My opinion is "NO".  Do you agree?

Your thoughts and assistance in this matter would be greatly appreciated.  
Thanks MW
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