Ehron Documents 1993 S-F-1325.12 CORRESPONDENCE CONTROL FORM (11-90) OFFICE OF THE EXECLTIVE SECRETARIAT ACTIVITY ADD DO NOT DETACH FROM ORIGINAL CORRESPONDENCE 01/19/93 10:17 SOURCE CODE pM PUBLIC MAIL SPEC INT: _ CONTROL N( S93-000578 DATE CORR: 01/13/93 DATERECD: 01/19/93 DATECNTRL: 01/19/93 -DATE DUE: LETTER: MEMO: TWX: _OTHER: MOTION TO:SECY: X DEPSEC: UN SEC: OTHER: ROM:FLOWERS,G PATRICK TX O REMARKS: ENRON CORP. UB J : LEGAL -=--_- LITIGATION FOR USE fY ACT N OFFICE ONLY MOTION FOR LEAVE TO INTERVENE ACTION REFERRED TO DATE RETURN TO DUE OF NORTHERN NATURAL GAS CO., DATE TRANSWESTERN PIPELINE CO., 2 FLORIDA GAS TRANSMISSION CO... _3-_ ACTION TO: rr - TYPE ACTION: Appropriate action SIG OF: 3NCURRENCE: i NFORMATION:DS US EP FE ES1 D02 FILE CODE:PMFLOWFRS-ES930'00578 CONTROL ANALYST: B ATCHERSON 6-2255 ALL DOCUNfENTS FOR THE OFFICE OF THE SECRETARY MUST BE FORWARDED TO THE OFFICE OF THE EXECUTIVE SECRETARIAT FOR FINAL PROCESSING Vvcj-. ^. -, i IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT Virginia Electric and Power Company, § Petitioner, §-- § v. § No. 92-1644 § (Not Consolidated) Federal Energy Regulatory Commission, § Respondent. § Northern-Indiana Public § Service Company, § Petitioner, § v. § No. 93-1002 § (Not Consolidated) Federal Energy Regulatory Commission, § Respondent. Northern States Power Company § (Minnesota) and § Northern States Power Company § (Wisconsin), § Petitioners, § § v. § No. 93-1003 § (Not Consolidated) Federal Energy Regulatory § Commission, Respondent. § Midland Cogeneration Venture § Limited Partnership, § § v. § No. 93-1006 § (Not Consolidated) Federal Energy Regulatory § .Commission, § Respondent. SNR\1014.jwz MOTION FOR LEAVE TO INTERVENE OF NORTHERN NATURAL GAS COMPANY, TRANSWESTERN. PIPELINE COMPANY, FLORIDA GAS TRANSMISSION COMPANY, AND ENRON GAS MARKETING, INC. Pursuant to Rule 15(d) of the Federal Rule _f Appellate Procedure, Northern Natural Gas Company ("Northern"), Transwestern Pipeline Company ("Transwestern"), Florida Gas Transmission Company ("Florida Gas"), and Enron Gas Marketing, Inc. ("EGM") (collectively referred to herein as "Enron") each hereby move for leave to intervene in the-above-captioned proceeding. In support of its motion, Enron states as follows: I. Northern, Transwestern, and Florida Gas own and operate pipeline systems and facilities and perform natural gas transportation and sales services on behalf of numerous customers, and are each interstate pipelines subject to the jurisdiction of Respondent under the Natural Gas Act. Moreover, Northern, Transwestern, and Florida Gas participated in the Docket Nos. RM91-11-000 and RM87-34-065 proceedings and are each involved in restructuring proceedings dictated by Order Nos. 636, et seq.1 1 Northern's restructuring proceeding is Docket No. RS92- 8-000; Florida Gas' restructuring proceeding is Docket No. RS92-16-000; and Transwestern's restructuring proceeding is Docket No. RS92-87-000. SNRU014o.j,-z 2 II. EGM is a wholly-owned subsidiary of Enron Gas Services, Inc., a wholly-owned subsidiary of Enron Corp., and is affiliated with several pipelines, including Northern, Transwestern, and Florida Gas. EGM is a markete pof natural gas, selling in excess of 2 Bcf per day on both a.spot and long-term basis. EGM obtains its supplies from virtually every major producing basin in the United States, as well as from Canada, and sells gas to markets located in 37 states. In a given month, EGM moves gas on approximately 100 pipelines. EGM is a party in approximately 58 of the pipelines' restructuring proceedings required pursuant to Order Nos. 636, et seq., and EGM participated in the respective docket proceeding before the Federal Energy Regulatory Commission. III- On December 14, 1992 and January 4, 1993, January 4, 1993, and January 5, 1993, respectively, Virginia-Electric and Power Company, Northern Indiana Public Service Company, Northern States Power Company (Minnesota), et al., and Midland Cogeneration Venture Limited Partnership petitioned this Court to review of the following Order of Respondent, Federal Energy Regulatory Commission: so l4.riz 3 3 Pipeline Service Obligations and Revisions to Regulations Governing Self-Implementing Trans- portation Under Part 284 of the Commission's Regulations and Regulation of Natural Gas Pipelines After Partial Wellhead Decontrol, Docket Nos. RM91- 11-004 and RM87-34-069, Order No. 636-B, "Order Denying Rehearing and Clarifying Order Nos. 636 and 636-A", 61 FERC (CCH) 1 61,272 (November 27 192). IV. Enron has a substantial interest in this proceeding and may be directly and substantially affected by the outcome thereof and cannot be represented adequately by any other party. For these reasons, good cause exists to-grant Enron's Motion to Intervene and to permit Enron's active participation in this proceeding. WHEREFORE, for the reasons set forth herein, Enron respectfully moves to intervene in the above-captioned SHR\IO4.jvz 4 9 proceeding, and requests that it be accorded all rights as a full party to the proceeding. Respectfully submitted, By ^i G. Patrick Flowers Attorney Sherrie N. Rutherford Assistant General Counsel Legal and Regulatory Analysis Deborah A. Macdonald Vice President and General Counsel Northern Natural Gas Company Transwestern Pipeline Company Florida Gas Transmission Company P. O. Box 1188 Houston, Texas 77251-1188 (713) 853-3136 Joseph R. Hartsoe Leslie J. Lawner Federal Regulatory Counsel Assistant General Counsel 750 17th Street, N.W. Enron Gas Marketing, Inc. Washington, D.C. 20006-4607 P. O. Box 1188 (202) 828-3369 Houston, Texas 77251-1188 (713) 853-7629 Dated: January 13, 1993 SNR\014.j-z 5 5 IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT Virginia Electric and Power S Company, S Petitioner, S~- S v. § No. 92-1644 S (Not Consolidated) Federal Energy Regulatory S Commission, § - Respondent. S Northern Indiana Public S Service Company, § Petitioner, § v. § No. 93-1002 § (Not Consolidated) Federal Energy Regulatory S Commission, § Respondent. 5 Northern States Power Company § (Minnesota) and § Northern States Power Company § (Wisconsin), § Petitioners, § § v. § No. 93-1003 § (Not Consolidated) Federal Energy Regulatory § Commission, § Respondent. § Midland Cogeneration Venture S Limited Partnership, § S v. 5 No. 93-1006 S (Not Consolidated) Federal Energy Regulatory S Commission, § Respondent. S SNRlOl 4.jr 'p CORPORATE DISCLOSURE STATEMENT OF NORTHERN NATURAL GAS COMPANY, TRANSWESTERN PIPELINE COMPANY, FLORIDA GAS TRANSMISSION COMPANY, AND ENRON GAS MARKETING, INC. Pursuant to Rule 26.1 of the Federal Rulesof Appellate Procedure and Local Rule 6A of the United States Court of Appeals for the District of Columbia Circuit, Northern Natural Gas Company ("Northern"), Transwestern Pipeline Company ("Transwesl-ern"), Florida Gas Transmission Company ("Florida Gas"), and Enron Gas Marketing, Inc. ("-EGM") (herein collectively referred to as "Enron") hereby file this corporate disclosure statement. Northern, Transwestern, and EGM are indirect wholly owned subsidiaries of Enron Corp., a publicly traded corporation. Florida Gas is a wholly owned subsidiary of Citrus Corp., which is fifty percent (50%) owned by Enron Corp. and fifty percent (50%) owned by Sonat, Inc., which is also a publicly traded corporation. Enron Corp. is affiliated with Enron Oil & Gas Company and Enron Liquids Pipeline, L.P., which are also publicly traded. Northern, Transwestern, and Florida Gas are interstate pipelines subject to the jurisdiction of the Respondent under the Natural Gas Act. Northern, Transwestern, and Florida Gas own and operate pipeline systems and facilities and perform natural gas transportation and sales services on behalf of SNHU014 j 2 7 numerous customers. Moreover, Northern, Trar-svester) and Florida Gas are impacted by Order Nos. 636, et seq. EGM is a marketer of natural gas, selling in excess of 2 Bcf per day on both a spot and long-term basis. EGM obtains its supplies from virtually every major producing-:bin in the United States, as well as from Canada, and sells gas to markets located in 37 states. In a given month, EGM moves gas on approximately 100 pipelines. EGH is a party in approximately 58 of the pipelines' restructuring proceedings required pursuant to Order Nos. 636, et sea. Respectfully submitted, G. Patrick Flowers Attorney Sherrie N. Rutherford Assistant General Counsel Legal and Regulatory Analysis Deborah A. Macdonald Vice President and General Counsel Northern Natural Gas Company Transwestern ipeline Company Florida Gas Transmission Company P. 0. Box 1188 Houston, Texas 77251-1188 (713) 853-3136 Joseph R. Hartsoe Leslie J. Lawner Federal Regulatory Counsel Assistant General Counsel 750 17th Street, N.W. Enron Gas Marketing, Inc. Washington, D.C. 20006-4607 P. 0. Box 1188 (202) 828-3369 Houston, Texas 77251-1188 (713) 853-7629 Dated: January 13, 1993 SNRM\014 .pJ 3 y CERTIFICATE OF SERVICE I hereby certify that I have this day served by first- class mail, postage prepaid,. a copy of the foregoing Motion for Leave to Intervene of Northern Natural Gas Company, Transwestern Pipeline Company, Florida Gas Transmission Company, and Enron Gas Marketing, Inc. and. -tba Corporate Disclosure Statement upon the Solicitor of the-Federal Energy Regulatory Commission, and upon all parties on the service list, which was compiled by the Secretary of the Federal Energy Regulatory Commission in Docket Nos. RM91-11-000 and RM87-34-065. Datel at Houston, Texas this 13th day of January, 1993. G. Patrick Flowers