STEPHENS ENERGY CORP. - The Railroad Commission of Texas
STEPHENS ENERGY CORP. - The Railroad Commission of Texas
STEPHENS ENERGY CORP. - The Railroad Commission of Texas
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TTEPHE~~S<br />
<strong>ENERGY</strong> <strong>CORP</strong>,<br />
RANDAL M. <strong>STEPHENS</strong><br />
Pruiden~ -<br />
Re: Request for RRC Investigation <strong>of</strong> Enbridge Lost and Unaccounted Gas<br />
Dear Mr.<br />
March 7.2005<br />
In case you have not received this slrrady, I am attaching a copy <strong>of</strong> the 02/28/2005<br />
letter I received from-, Director <strong>of</strong> Enbridge Gathering (North <strong>Texas</strong>) L.P.<br />
In my opinion, Enbridge has dirstly challenged the authority, wmpetence, and<br />
determination <strong>of</strong> the Railmad <strong>Commission</strong> <strong>of</strong> Tcxas. If you will recall, I testified before the<br />
House Energy Resouras Committee on 03/02n005 concaning HB 821. In my testimony<br />
and in my previous lettm to Enbridge, I have said that 25% <strong>of</strong> my gas is going unpaid for<br />
because Enbridge is deducting 25% <strong>of</strong> my gas for fuel and Lost and Unaccounted Gar<br />
(LUG). I doubted that these huge gas losses were real, but instead suspected they were the<br />
result <strong>of</strong> creative allocation <strong>of</strong> both residue gas and lost gas by Enbridge for their financial<br />
advantage.<br />
You will note that some <strong>of</strong> the language explaining these mysterious gas losses by<br />
Mr. i r r o r s the language used by one <strong>of</strong> the gas lobbyists at the hearing. I<br />
suspect there has been a strategy session by the gathering companies because this issue cuts<br />
directly to their bottom line.<br />
I suspect that Enbridge and other gatherers have concluded that thcy have been<br />
painted into a wrner. If they admit that the 25% missing gas is fictitious, a result <strong>of</strong> their<br />
bookkeeping, they are liable for lriple damages and possibly criminal palties. So thcy are<br />
forced to take the position that they are indeed mysteriously losing 25% <strong>of</strong> the gas in their<br />
gathering systm.<br />
Mr.- is so confident that Enbridge can m~euvcr<br />
their way out <strong>of</strong> this tight<br />
spot, that he actually lays out their strategy for all to see. He clearly states that these<br />
mysterious huge gas losses cannot be measured and therefore will not be explained to<br />
anyone, including the RRC. He then states that Enbridge will in the near fuhlre make<br />
expensive, unspecified fixes. At that point, the huge mysterious gas losses will go away and<br />
Enbridge will begin charging us producers a fee to pay for these expensive fixes.