RP-2000-0110	December 15, 2000

Board Staff

SUPPLEMENTARY INTERROGATORIES

Union Gas

Trafalgar Facilities Expansion Program 2000/2001

1.	Ref: Response to Interrogatory No. 5

Please clarify your answer on the difference between a Storage and Transportation Service ("S&TS") and a Transportation Service ("TS").

a.	Is the TS strictly a west-east gas movement or an east-west gas movement or gas movement in both directions?

b.	Do the three S & TS customers physically move their gas to storage in an east west direction in summer?

c.	Do both S & TS customers and TS customers both physically move their gas a West-East direction along the Trafalgar System in winter?

2.	Ref; Response to Interrogatory No. 6

In order to put the annual throughput increases or decreases into perspective relative to the totals, please provide the actual annual throughput for in-franchise volumes for classes "General Service", "Contract" and M12 for the years 1996, 96, 97, 98, 99 for both the in-franchise volumes and the TFEP-specific volumes.

3.	Ref; Response to Interrogatory No.8

Union indicated that the release of 163,999GJ/day of TCPL throughput requirement for three years was not taken into consideration in the design flow demand. The reason given, for not considering this reduced demand, was to allow other customers the opportunity to move that amount of gas to Dawn and reduce their deliveries to Parkway. This statement appears contradictory in that it appears to confirm that additional capacity, west-to-east on the Trafalgar line is not only not needed but even encourages other customers to deliver to Dawn rather than Parkway exacerbating the additional capacity release.

Please clarify why release of the subject TCPL's capacity does not result in a reduction in the design flow demand on winter peak design.

4.	Ref: Response to Interrogatory No. 10

a.	Please confirm that the figures provided are for "Union's service area served by the Trafalgar System" and not Union's "Southern Area".

b.	Please provide 2 maps, one indicating "Union's service area served by the Trafalgar System" and the second map indicating "Union's Southern Area".

5.	Ref: Response to Interrogatory No. 11

Please confirm that the anticipated power projects contributing to 15% contract in-
franchise annual throughput increase in year 2004 are located within Union's service area served by the Trafalgar.

6.	Ref: Response to Interrogatory No.14

The Total Trafalgar System Demand is given as 5,805,835 GJ/day including (Ref: Section 4, Schedules 8 and 9) with "Design Day Supplies at Parkway"of 780,544 GJ/day included. Capacity after applied-for looping is given as 5,805,835 GJ/day including the 780,544 Design Day Supplies at Parkway.

Why is the 780,544 included as a demand on the Trafalgar system when the delivery of these volumes to Parkway is the responsibility of another transmission company ?

7.	Ref: Response to Interrogatory No. 15

The release of TCPL's 150 MMcfd of contracted capacity (158,000 GJ/day) on Union's Trafalgar line for 3 years is said to have enabled a delay in the need for additional facilities.

Why then is it necessary for the applied-for facilities to be constructed in 2001 rather than when and if TCPL will require this capacity (with presumably adequate notice)?

8.	Ref: Response to Interrogatory No. 16

Are we to interpret Winter Peaking Service to be effectively equivalent to an interruptible service offered by Union on an "as available" basis or are there any mandatory requirements for Union to deliver such volumes at the appropriate time.

9.	Ref. Response to Interrogatory No. 34

In the process of negotiating for the remaining 10 permanent outstanding easement agreements, Union is dealing with compensation for sterilized aggregate in licensed and future gravel pits.

Please describe the standard methodology and policy that Union applies to deal with landowner matters involving mineral resources within the easements.

10.	Ref Response to Interrogatory No. 35

Please highlight the differences between the Revised Letters of Understanding and the Letters of Understanding endorsed by Beachville to Bright and Owen Sound to Brantford landowners in 1994.

11.	Ref Response to Interrogatory No. 51

Please specify the proposed methods of crossing for all of the identified stream crossings along the proposed route.