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Enron Mail |
---------------------- Forwarded by Drew Fossum/ET&S/Enron on 12/29/99 10:58
AM --------------------------- From: Susan Scott 12/29/99 09:56 AM To: Drew Fossum@ENRON cc: Subject: Red Cedar update Since the 311 belt/suspenders approach didn't quite fit, I've had to try to convince Mr. Hertzberg that he ought to rely on the NGA Sec. 1 exemption for gatherers (Frank Kelly and Frazier concur with us on this, by the way). He is not convinced yet, although he is unable to cite any authority for his proposition that being a shipper on TW would subject a gathering company to FERC jurisdiction. I pointed out that Agave, the owner and operator of an extensive gathering system that interconnects with TW's system, has for many years been a shipper on TW. Also, Lindy has found that Red Cedar already has a long-term transportation contract on another interstate system, Transcolorado, so if Hertzberg's theory is right they are going to jail anyway! Red Cedar also seems to be hung up on our requirement that shippers have title to the gas they ship. At this point Lorraine and I believe they might just be looking for any excuse to get out of the deal. If anything interesting happens I'll let you know.
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