This morning I raised a concern regarding TW's sale of excess fuel at  downstream points.
Here's the problem:  the tariff requires shippers to  tender fuel to us at their receipt points.
With rare exceptions, those  receipt points are not at the Cal.
border.
Order 636 mandates that pipelines  unbundle transportation from storage.
It also requires that pipelines that  make gas sales do so at the furthest upstream point on their pipeline.
That  latter requirement means that if a pipe buys gas at point "x", it should  resell the gas at point "x" and not haul the gas to point "y" and then sell  it there as a delivered (i.e., bundled) product.
My concern this morning was  that our receipt of fuel gas in the San Juan or Permian and shipment of that  gas to the Cal.
border for sale arguably violates the unbundling requirement  (because the Cal.
border sale is a bundled combination of the sale and the  transportation of the gas to the downstream location) or the "furthest  upstream point" requirement or both.
Susan and my recollection was that when  ECS wanted to receive the Gallup fuel deliveries at  a point other than  Permian pool, we made them sign a transport contract to move the gas to where  they wanted it.
I haven't confirmed that recollection but I am recalling  that we told Courtney that we couldn't just move our fuel gas around  whereever we wanted it--we needed someone to pay us to transport it.

TW Fuel

This morning I raised a concern regarding TW's sale of excess fuel at downstream points.
Here's the problem: the tariff requires shippers to tender fuel to us at their receipt points.
With rare exceptions, those receipt points are not at the Cal.
border.
Order <NUMBER> mandates that pipelines unbundle transportation from storage.
It also requires that pipelines that make gas sales do so at the furthest upstream point on their pipeline.
That latter requirement means that if a pipe buys gas at point "x", it should resell the gas at point "x" and not haul the gas to point "y" and then sell it there as a delivered (i.e., bundled) product.
My concern this morning was that our receipt of fuel gas in the San Juan or Permian and shipment of that gas to the Cal.
border for sale arguably violates the unbundling requirement (because the Cal.
border sale is a bundled combination of the sale and the transportation of the gas to the downstream location) or the "furthest upstream point" requirement or both.
Susan and my recollection was that when ECS wanted to receive the Gallup fuel deliveries at a point other than Permian pool, we made them sign a transport contract to move the gas to where they wanted it.
I haven't confirmed that recollection but I am recalling that we told Courtney that we couldn't just move our fuel gas around whereever we wanted it--we needed someone to pay us to transport it.
number mandates arguably violates sale bundled concern regarding tw juan permian fuel downstream points sign transport contract whereever receive gallup storage requires pipelines