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Enron Mail |
The Commission addressed the backhaul issue in Order Nos. 637-A and 637-B.
Bottom line is that backhaul and forward haul cannot overlap. However, new development is full CD forward haul and full CD backhaul can b= e delivered at same point. Here is what the Commission said in Order No. 637-A: EXAMPLE: Points: M=09A=09N=09O=09P=09Q=09R=09B=09=09=09S ___________________________________________________________________________= ____________ =09=09<<<<10,000 FORWARD<<<<<<<<<<<<<<<<<<<<<<10,000 BACKHAUL< =09"Both the releasing and replace shippers also would retain the flexibili= ty to use their capacity fully to make backhauls. Thus, the shipper could = deliver 10,000 Dth from point A to Point B using forward haul capacity and = 10,000 Dth from point S to point B using a backhaul, because there is no ov= erlap over the mainline. =09This may require a change by some pipeline with respect to their tariffs= regarding backhauls. The Commission's policy on the use of forwardhauls a= nd backhauls to the same pont in excess of contract demand has been in the = process of change. While the Commission found in 1997 that a shipper canno= t use the same delivery point for a forwardhaul and backhaul in excess of c= ontract demand, the Commission recently found that a forwardhaul and backha= ul to a series of 23 meter station considered as a single point for nominat= ion purposes did not result in a capacity overlap even though the total amo= unt received by the shipper exceeded contract demand. In order to promote = shippers' ability to use their capacity as flexibly as possible, the Commis= sion has determined that prior restrictions on shippers' use of forwardhaul= s and backhauls to the same point should not be followed. Shippers' segmen= tation right should not depend on metaphysical distinctions between deliver= y to a single point or to two points adjacent to each other. In both situa= tions, shippers should be permitted to use a forwardhaul and a backhaul to = deliver gas as long as the mainline contract demand is not exceeded and the= y can take delivery of the gas." (Footnotes omitted.) In Order No. 637-B, the Commission addressed requests of INGAA, Williams an= d the El Paso pipelines for rehearing of this very point. The Commission de= nied rehearing, repeating much of what it had said in Order No. 637-A. NOTE: Seems like there is more than a "metaphysical" difference between de= liveries to a single point versus two points. However, the Commission does= recognize that there may be a physical constraint, and maybe even a schedu= ling constraint.
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