Message-ID: <18140324.1075842428841.JavaMail.evans@thyme> Date: Mon, 8 May 2000 05:59:00 -0700 (PDT) From: drew.fossum@enron.com To: lee.huber@enron.com Subject: Notes from Meeting on OCSLA Reporting Cc: shelley.corman@enron.com Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit Bcc: shelley.corman@enron.com X-From: Drew Fossum X-To: Lee Huber X-cc: Shelley Corman X-bcc: X-Folder: \Drew_Fossum_Dec2000_June2001_1\Notes Folders\All documents X-Origin: FOSSUM-D X-FileName: dfossum.nsf I'd like you to be involved in this from the legal side. Shelley, please keep Lee in the loop on this matter. Gracias. DF ---------------------- Forwarded by Drew Fossum/ET&S/Enron on 05/08/2000 12:55 PM --------------------------- Shelley Corman 05/07/2000 10:08 PM To: Mary Kay Miller/ET&S/Enron@ENRON, Drew Fossum/ET&S/Enron@ENRON, Dari Dornan/ET&S/Enron@ENRON cc: Michele Winckowski/ET&S/Enron@ENRON, Keith Petersen/ET&S/Enron@ENRON, James Harvey/ET&S/Enron@ENRON Subject: Notes from Meeting on OCSLA Reporting Michele Winckowski, Keith Petersen, James Harvey & I met last week to discuss compliance with Order 639, the new OCS reporting requirements. NNG has 5 NGA-exempt facilities that are subject to the new reporting rules and will therefore be subject to Section 330.2. While these facilities are NGA-exempt gathering, they continue to be included in NNG's transmission rates for rate purposes and remain eligible points for TI agreements and alternate firm. While these points are currently listed as available points and on the all-points exhibits of TI agreements, these points are not currently being used. Michele and Keith have voiced concerns about having to perform separate OCS reports for these facilities. Section 330.2(a) requires a report that includes maps and a list of affiliates. Section 330.2(b) requires a description of transactions - contract number, receipt/delivery point, rates etc. We discussed two possible compliance strategies. First, NNG could seek a waiver, asking that since the facilities remain in transmission rates and valid points on jurisdictional contracts, NNG asks that it be allowed to include these points in its NGA reports. Alternatively, NNG could file the maps and list of affiliates, but with regard to transactions, simply file a statement that these points, while listed as valid on all TI and FT agreements have not been used in some time. I have read and re-read Order 639 to understand the date an initial report would be due. The rule sets out some of the most confusing effective date language that I have ever read. Generally, reports are due on the 1st of each quarter regarding the status of transactions on the first day of the previous quarter. On Page 47, the Commission purports to give more time for the initial submissions. Initial reports will be "based on conditions on the first day of the full calendar quarter that begins after the effective date of thise rule, with initial reports due on the first business day after close of the quarter." What I make of this is that NNG's first report would be due October 1, 2000 (based on the quarter commencing July 1). We may want to considering seeking a waiver on or before July 1 (i.e. before the reporting period commences).