April 10, 2015 Ms. Kimberly D. Bose, Secretary Federal Energy

P.O. Box 21734
Shreveport, LA 71151
T 318-429-3708
April 10, 2015
Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Re:
877-000
Docket No. RP15-_____
Enable Mississippi River Transmission, LLC
Filing for Negotiated Rate
Dear Ms. Bose:
I.
Introduction
Enable Mississippi River Transmission, LLC (“MRT”) hereby submits to the Federal
Energy Regulatory Commission (“Commission”) for filing and approval an executed Attachment
A to a negotiated rate Transportation Service Agreement (“TSA”) between MRT and Laclede
Energy Resources, Inc. (“LER”), TSA No. 5680 (“RS PALS”), as Appendix A to be included in
MRT’s Second Revised Volume Negotiated Rates and Non-Conforming Agreements
(“NRNCA”) as Section 2.3.1. MRT proposes the following change to be effective April 10,
2015:
Section 2.3.1, Laclede Energy Resources, Inc. TSA No. 5680 (RS PALS) Attachment A, Version 8.0.0
II.
Background
On June 30, 2000, the Commission approved Section 19.2 of the General Terms and
Conditions (“GT&C”) of MRT’s FERC Gas Tariff (“Tariff”) in Mississippi River Transmission
Corporation, 91 FERC ¶ 61,342 (2000), which provides MRT and its Customers the ability to
negotiate rates as provided for in the Commission’s Policy Statement issued February 31, 19961.
The Commission subsequently modified this policy.2 The Commission has advised that the
electronic filing rules promulgated in Order No. 7143 require all tariffs, rate schedules and
1
“Statement of Policy and Request for Comments” in Alternatives to Traditional Cost-of-Service
Ratemaking for Natural Gas Pipelines, and Regulation of Negotiated Transportation Services of Natural Gas
Pipelines, 74 FERC ¶ 61,076 (1996), order on clarification, 74 FERC ¶ 61,194 (1996), order on rehearing, 75
FERC ¶ 61,024 (1996).
2
Natural Gas Pipeline Negotiated Rate Policies and Practices, 104 FERC ¶ 61,134 (2003), as modified on
rehearing and clarification, 114 FERC ¶61,042 (2006).
3
Electronic Tariff Filings, FERC Stats & Regs ¶ 31,276 (2008).
Kimberly D. Bose
April 10, 2015
Page 2
jurisdictional contracts, including service agreements, to be filed as “tariff records” which are to be
included as part of the pipeline’s database.4
III.
Statement of the Nature, the Reasons, and the Basis for the Proposed Changes
On May 1, 2014, MRT filed for approval in Docket No. RP14-836-000 a negotiated rate
agreement, TSA No. 5680, providing parking transportation service to LER under Rate Schedule
PALS. On May 22, 2014, the Commission issued a delegated letter order accepting the filing. As
described in the May 1 transmittal letter, the parties have agreed on a rate structure which
includes a potential incremental payment which can be determined only following the close of
the Service Month based on that prior month’s activities. An incremental payment has been
calculated for the month of March 2015, in the amount of $3,538.00. Accordingly, the executed
Attachment A, attached as Appendix A,5 documents the amount of the incremental payment for
the month of March 2015, which will replace the Attachment A previously submitted at Section
2.3.1 by MRT in Docket No. RP15-614-000. MRT hereby confirms the TSA, as supplemented
herein, does not deviate in any material aspect from the applicable Rate Schedule PALS Form of
Service Agreement in the Tariff.
MRT requests that the Commission grant MRT any waivers of the Commission’s
Regulations (including the 30-day notice period prescribed in 18 C.F.R. §154.207) which are
necessary to place the tariff record into effect April 10, 2015. Additionally, MRT requests all
such further relief and waivers as may be appropriate to permit the parties to implement the
transaction as contemplated.
IV.
Components of the Filing.
In accordance with Section 154.7(a)(1) of the Commission’s Regulations, MRT submits
herewith an eTariff XML filing package containing this transmittal letter and all components of
the filing, filed as a zip (compressed) file, as listed below:
Appendix A – Clean version of Section 2.3.1; and
Appendix B – Marked version of Section 2.3.1
V.
Communications
MRT requests that all correspondence and communications concerning this filing be sent
to each of the following persons and that each be included on the Commission’s official service
list for this filing:
4
18 C.F.R. § 154(a) and (c) (2013); see Dominion Transmission, Inc., 132 FERC ¶ 61,179 at P. 13-14
(2010).
5
Pursuant to Section 154.201(a) of the Commission’s Regulations, MRT is attaching, as Appendix B, a
marked version of the tendered tariff record showing changes from the previously filed version.
Kimberly D. Bose
April 10, 2015
Page 3
B. Michelle Willis
Director - Rate, Regulatory & FERC Compliance
Enable Mississippi River Transmission, LLC
P. O. Box 21734
Shreveport, LA 71151
(318) 429-3708
Michelle.Willis@enablemidstream.com
Cecil W. Talley
Blanchard, Walker, O'Quin & Roberts, PLC
P.O. Drawer 1126
Shreveport, LA 71163-1126
(318) 934-0258
ctalley@bwor.com
VI.
Subscription, Posting and Certification of Service.
In accordance with Sections 385.2005 and 385.2011(c)(5) of the Regulations,6 the
undersigned states that she has read this filing and knows its contents and to her best knowledge and
belief the statements and information contained in the tariff records attached hereto are true and the
electronic media accompanying this filing contains the same information as that available for public
inspection.
Pursuant to Sections 154.2(d), 154.7(b) and 154.208(b) of the Commission’s Regulations,
a copy of this tariff filing is being sent by electronic mail to each of MRT’s customers and
interested State Commissions. This tariff filing is also available for public inspection during
regular business hours in a convenient form and place at MRT’s offices at 525 Milam Street,
Shreveport, Louisiana 71101, and on its website at http://pipelines.enablemidstream.com.
If there are any questions concerning this filing, please contact the undersigned at
(318)429-3708.
Respectfully submitted,
ENABLE MISSISSIPPI RIVER
TRANSMISSION, LLC
/s/ B. Michelle Willis/cd
B. Michelle Willis
Director - Rate, Regulatory & FERC Compliance
Enclosure
6
18 C.F.R. §§ 385.2005, 385.2011(c)(5) (2014).
Appendix A
Enable Mississippi River Transmission, LLC
FERC NGA Gas Tariff
Second Revised Volume Negotiated Rates and Non-Conforming Agreements
Section 2.3.1, Version 8.0.0
Effective April 10, 2015
Laclede Energy Resources, Inc. TSA No. 5680 (RS PALS) Attachment A
Option Code “A”
Appendix B
Enable Mississippi River Transmission, LLC
FERC NGA Gas Tariff
Second Revised Volume Negotiated Rates and Non-Conforming Agreements
Section 2.3.1, Version 87.0.0
Effective March 4April 10, 2015
Laclede Energy Resources, Inc. TSA No. 5680 (RS PALS) Attachment A
Option Code “A”
Contract # 5680
PARK AND LOAN SERVICE AGREEMENT
FOR RATE SCHEDULE PALS
ATTACHMENT A
1) SHIPPER INFORMATION
Laclede Energy Resources, Inc.
2) QUANTITIES, POINTS, SERVICE AND RATE:
Rates and Clarifications:
61% of Monthly Monetary Gain for Month of Feb March 2015: $_3,489.203538.00__
Executed by a duly authorized representative of each party hereto, in the space provided below:
ENABLE MISSISSIPPI RIVER
TRANSMISSION, LLC
LACLEDE ENERGY RESOURCES, INC.
By:
Name:
Title:
Date:
By:
Name:
Title:
Date: