UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Columbia Gulf Transmission Company, ) Docket No. RP04-413-000
Complainant, )
)
v. )
)
Tennessee Gas Pipeline Company, )
Respondent. )
PROPOSED JOINT FINDINGS OF FACT BY
COLUMBIA GULF TRANSMISSION COMPANY,
TENNESSEE GAS PIPELINE COMPANY, DYNEGY MIDSTREAM
SERVICES LIMITED PARTNERSHIP AND COMMISSION TRIAL STAFF
To: The Honorable Edward M. Silverstein
Presiding Administrative Law Judge
Pursuant to Rule 706 of the Federal Energy Regulatory Commissions (Commission)
Rules of Practice and Procedure, 18 C.F.R. 385.706 (2004), and the Order Establishing Post
Hearing Procedural Schedule, issued July 11, 2005, Columbia Gulf Transmission Company
(Columbia Gulf), Tennessee Gas Pipeline Company, (Tennessee), Dynegy Midstream
Services Limited Partnership (Dynegy) and Commission Trial Staff (Staff) hereby submit
the following Proposed Joint Findings of Fact, and respectfully request that the Presiding
Administrative Law Judge accept and enter those findings.
A. Parties
1. Columbia Gulf Transmission Company (CGT or Columbia Gulf) is an
interstate natural gas pipeline. (Ex. CGT-1 at 1; CGT-9 at 1.)
2. Tennessee Gas Pipeline Company (Tennessee) is a jurisdictional natural gas
transmission company engaged primarily in the business of transporting natural
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gas in interstate commerce. Tennessees main transmission system extends in a
northeasterly direction from its primary sources of supply in south Texas,
Louisiana, and the Gulf of Mexico, through fifteen states to the northeastern
United States, terminating in New Hampshire. Tennessee offers numerous
transportation and transportation-related services such as firm and interruptible
transportation, firm and interruptible storage, park and loan, and load
management services. (TGP-1, p 3, lines 12-19.)
3. Dynegy Midstream Services (DMS or Dynegy) is the operator and an owner
of the Yscloskey gas processing plant. DMS does not own any natural gas
interstate pipelines and is not a gas producer. (Tr. at 841-42.)
4. Dynegy is a gas gatherer, processor and NGL marketer. Tr. 841.
5. Dynegy enters into plant wide processing agreements on behalf of the Yscloskey
plant owners for gas determined to be in excess of quality standards enforced by
Tennessee and CGT. (Tr. 842.)
6. CGT and TGP compete to provide transportation services on the South Pass
System. (Tr. at 240, 317, 418, 1066.)
7. Tennessee and Columbia Gulf are direct competitors on the South Pass system.
(Tr. 240, lines 16-19; Tr. 317, lines 8-10.)
8. Dynegy does not compete with Tennessee or CGT. (Tr. 857.)
B. The South Pass System
9. The South Pass 77 system is a natural gas pipeline extending from offshore
Louisiana, and terminating onshore in Plaquemines Parish, Louisiana.
Specifically, the South Pass 77 system consists of: (1) 10.8 miles of 26-inch
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pipeline extending from a platform in ...
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