September 25, 2015
Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Re:

Trans-Pecos Pipeline, LLC, Docket No. CP15-500-000
Presidio Border Crossing Project
Response to Scoping Comments

Dear Ms. Bose:
On May 28, 2015, Trans-Pecos Pipeline, LLC (“Trans-Pecos”) filed with the Federal
Energy Regulatory Commission (“FERC” or “Commission”) an Application for Natural Gas Act
Section 3 Authorization and Presidential Permit to Construct Natural Gas Pipeline Facilities at
the United States – Mexico Border (“Application”).1 On July 23, 2015, the Commission issued a
Notice of Intent to Prepare an Environmental Assessment for the Proposed Presidio Border
Crossing Project, as amended by the Commission’s Notice of Extension of Time issued
August 5, 2015 (together, the “Notice”) initiating a scoping period to solicit comments regarding
the potential environmental effects associated with the Presidio Border Crossing Project (defined
below). The Notice requested that comments be filed with the Commission by September 4,
2015.
Trans-Pecos reviewed each of the comments received through the close of the scoping
period, and categorized the comments into subject matter categories based on the issues raised in
the comments. Trans-Pecos hereby responds to the comments by subject matter category below.
The majority of the comments apply to matters that Trans-Pecos has already addressed on the
docket, including whether the entirety of the Trans-Pecos Project should be subject to FERC’s
Natural Gas Act jurisdiction or whether the scope of the Commission’s National Environmental
Policy Act (“NEPA”) review of the Presidio Border Crossing Project should also include
non-jurisdictional upstream facilities or the facilities of another border crossing project.
Trans-Pecos explains below where these matters have been addressed already in the record in
this proceeding. Additionally, several scoping comments will be addressed by Trans-Pecos’
forthcoming response to the Commission’s Environmental Information Request issued to
Trans-Pecos on September 8, 2015 (“Data Request”). Trans-Pecos is working to submit its
responses to those requests on or before the Data Request deadline of October 6, 2015.
Trans-Pecos is proposing to construct and operate certain natural gas pipeline facilities at
the international boundary between the United States and Mexico to export and/or import natural
gas between the United States near the City of Presidio, in Presidio County, Texas, and Mexico
near the City of Manuel Ojinaga, State of Chihuahua (“Presidio Border Crossing Project” or
1

Trans-Pecos Pipeline, LLC, Application for Natural Gas Act Section 3 Authorization and Presidential Permit to
Construct Natural Gas Pipeline Facilities at the United States – Mexico Border, Docket No. CP15-500-000
(May 28, 2015) (“Application”).

 Ms. Kimberly D. Bose
September 25, 2015
Page 2
“Project”). The Project consists of the construction of approximately 1,093 feet of
42-inch-diameter natural gas pipeline that will commence on the north side of the Rio Grande
River in Presidio County, Texas, and terminate in the middle of the Rio Grande River bed at the
international boundary between the United States and Mexico.
As discussed in detail in the Application, in addition to the Presidio Border Crossing
Project, Trans-Pecos intends to construct approximately 143 miles of 42-inch pipeline, multiple
meter stations, and ancillary facilities wholly within the State of Texas (“Upstream Facilities”)
pursuant to the jurisdiction of the Railroad Commission of Texas (“RCT”). The Upstream
Facilities will interconnect with and supply or receive gas into or from the Presidio Border
Crossing Project facilities at the international boundary. When Trans-Pecos places its pipeline
system into service, including both the Presidio Border Crossing Project facilities and the
Upstream Facilities, Trans-Pecos will provide transportation in intrastate commerce and will be
an intrastate pipeline. Accordingly, service on the Trans-Pecos pipeline system and the
construction and operation of the Upstream Facilities are subject to the jurisdiction of the RCT.
Project Need
Several commenters discuss the need for the Project and whether the Project would
benefit the City of Presidio, Presidio County, or the State of Texas. For the reasons discussed in
this section, the Project is in the public interest. Contrary to the Big Bend Conservation
Alliance’s (“BBCA”) allegation that Trans-Pecos’s Application must satisfy the Commission’s
Certificate Policy Statement, which establishes criteria for determining whether there is a need
for a proposed project and whether the proposed project will serve the public interest,2 the
Certificate Policy Statement provides guidance for evaluating proposals to certificate new
interstate natural gas pipeline construction under Section 7 of the Natural Gas Act (“NGA”).
Although some of the analysis for the balancing of benefits against burdens is similar, the
Certificate Policy Statement does not specifically apply to facilities constructed under Section 3
of the NGA such as the Presidio Border Crossing Project.3
Section 3 of the NGA provides for the Commission’s approval of an application under
that section “unless it finds that the proposal will not be consistent with the public interest.”4
Section 3 further provides that the exportation and importation of natural gas between the United
States and “a nation with which there is in effect a free trade agreement requiring national
treatment for trade in natural gas, shall be deemed to be consistent with the public interest, and
applications for such importation and exportation shall be granted without modification or
2

Scoping Comments of the Big Bend Conservation Alliance, p. 10 (Sept. 4, 2015) (“BBCA Comments”).

3

Certification of New Interstate Natural Gas Pipeline Facilities, Statement of Policy, 88 FERC ¶ 61,227 (1999), as
clarified by 90 FERC ¶ 61,128 (2000) and 92 FERC ¶ 61,094 (2000). See e.g. Bradwood Landing LLC, et al.,
126 FERC ¶ 61,035 at P 180 (2009) (clarifying that “the Certificate Policy Statement is applicable only to
determining the public convenience and necessity under NGA section 7 for pipeline projects”); Pacific Connector
Gas Pipeline, LP, et al., 139 FERC ¶ 61,040 at FN20 (2012) (noting that “the Certificate Policy Statement does not
apply specifically to terminal and storage facilities authorized under section 3 of the NGA”).
4

15 U.S.C. § 717b(a) (2012).

 Ms. Kimberly D. Bose
September 25, 2015
Page 3
delay.”5 The United States and Mexico are signatories to the North American Free Trade
Agreement.6 The Presidio Border Crossing Project facility is needed to export gas that is being
produced in the United States for sale to expanding electric generation and industrial markets in
Northern Mexico. Authorization for construction of the facilities will promote national economic
policy by reducing barriers to foreign trade, stimulating the flow of goods and services between
the United States and Mexico, and facilitating the transportation of natural gas imports and
exports authorized by the U.S. Department of Energy’s Office of Fossil Energy.7 In addition, and
as articulated in Trans-Pecos’ answer submitted to the Commission on July 15, 2015, in the
referenced docket (“July 15 Answer”),8 by providing access to new natural gas markets, the
Trans-Pecos system will encourage further development of natural gas production in the Permian
Basin, benefit air quality in the border region by replacing Northern Mexico’s less
environmentally-friendly fuel sources, and financially benefit local communities along the
pipeline route through increased local access to multiple natural gas markets for local
communities and, for the City of Presidio, access to natural gas where no gas service existed
previously.9
International Conservation Efforts in the Big Bend / Rio Bravo Region
Many commenters reference various international conservation efforts along the United
States-Mexico border in the Big Bend/Río Bravo region, including, for example, a May 2010
declaration by U.S. President Barack Obama and Mexico’s President Felipe Calderón that
recognized the region’s conservation value for both nations,10 the Conservation Assessment for
the Big Bend-Rio Bravo Region,11 and others.12 While these documents promote the joint
conservation efforts by the United States and Mexico in the Big Bend region, they also
encourage enhancement of the trading partnership between the two nations, reinforce efforts to
create jobs, and support economic recovery and expansion. The documents advocate for
developing the border in ways that facilitate the secure, efficient, and rapid flows of goods and
services between the United States and Mexico, and for ensuring energy security in North
America. As discussed above, contrary to the assertions in the scoping comments that TransPecos’ actions conflict with these documents, the Project in fact upholds these bi-national
objectives. The facilities will, among other things, reduce barriers to foreign trade, stimulate the
flow of goods and services between the United States and Mexico, and improve air quality in the
border region. Additionally, the Project is not located within any areas designated as a priority
5

Id.

6

Pub. L. No. 103-82, 107 Stat. 2057 (1993); Implementation of the North American Free Trade Agreement Act,
Executive Order No. 12889, 58 Fed. Reg. 69,681 (Dec. 27, 1993).
7

See, e.g., Impulsora Pipeline, LLC, 151 FERC ¶ 61,117, at P 14 (2015).

8

Trans-Pecos Pipeline, LLC, Motion for Leave to Answer and Answer of Trans-Pecos Pipeline, LLC, Docket No.
CP15-500-000 (July 15, 2015) (“July 15 Answer”).
9

Id. at pp. 3-4.

10

See, e.g., Scoping Comments of Ann Daugherty (Aug. 28, 2015).

11

See, e.g., Scoping Comments of Beth Doolittle (Aug. 26, 2015).

12

See, e.g., Scoping Comments of Cheryl Frances (Aug. 24, 2015).

 Ms. Kimberly D. Bose
September 25, 2015
Page 4
conservation area in the Conservation Assessment for the Big Bend – Rio Bravo Region.13
Moreover, the Project has been designed and located to comply with all applicable laws and
regulations, and Trans-Pecos will take all appropriate measures to minimize impacts from the
Project to the environment and the Big Bend/Rio Bravo region.
Jurisdiction
Several commenters request that the Commission analyze the jurisdiction of the planned
Upstream Facilities that will connect to the Project and propose that the Commission assert
jurisdiction over the Upstream Facilities. They also request that the Commission’s review under
NEPA include both the Presidio Border Crossing Project and the Upstream Facilities.
Trans-Pecos provided a detailed explanation in its July 15 Answer explaining why the Upstream
Facilities are not subject to FERC jurisdiction and are not required to be included in the NEPA
review for the Project. Only the facilities located at the international border are
FERC-jurisdictional facilities, and upstream pipeline facilities, when used to transport gas in
intrastate commerce to the international border, are non-jurisdictional facilities subject only to
state jurisdiction.14 As a result, the Commission’s review of the Project under NEPA will only
consider potential environmental impacts associated with the FERC-jurisdictional facilities
located at the international border. Nevertheless, the Commission indicated in its Notice that it
would provide available descriptions of the Upstream Facilities and include available
environmental impact information under its analysis of cumulative impacts in the environmental
assessment (“EA”) in this proceeding.15 Furthermore, the Commission has specifically requested
this information for its EA in September 8, 2015 Data Request issued to Trans-Pecos. Because
the Upstream Facilities do not fall under the jurisdiction of the FERC, this Response only
addresses those comments relating to the Presidio Border Crossing Project facilities at the
international border. However, as noted herein, numerous comments will not be addressed
specifically in this response, but Trans-Pecos will provide detailed information in its responses to
the Commission’s September 8, 2015 Data Request.
Environmental, Health and Safety Impacts
National Environmental Policy Act
Several commenters assert that the Commission’s NEPA review for the Project must
include the Upstream Facilities. As discussed above and in detail in the July 15 Answer, the
Commission has correctly determined that its NEPA review will extend only to the Presidio
Border Crossing Project and not to the Upstream Facilities.16 Additionally, many commenters
13

See Commission on Environmental Conservation, Conservation Assessment for the Big Bend-Río Bravo Region:
A
Binational
Collaborative
Approach
to
Conservation,
p.
1
(2014),
available
at
http://www3.cec.org/islandora/en/item/11495-conservation-assessment-big-bend-r-o-bravo-region-binationalcollaborative-approach-en.pdf.
14

July 15 Answer at pp. 4-11.

15

Federal Energy Regulatory Commission, Notice of Intent to Prepare an Environmental Assessment for the
Proposed Presidio Border Crossing Project, Docket No. CP15-500-000, p. 3 (July 23, 2015) (“Notice”).
16

July 15 Answer at pp. 11-16; see also id.

 Ms. Kimberly D. Bose
September 25, 2015
Page 5
request that the Commission develop an environmental impact statement (“EIS”) in this
proceeding. As discussed in detail in the July 15 Answer, the Commission has correctly
determined that preparation of an EA for the Presidio Border Crossing Project and not an EIS is
appropriate because approval of the Project will not constitute a major federal action
significantly affecting the quality of the human environment.17
Furthermore, several
commenters assert that Trans-Pecos improperly segmented the environmental review for the
Trans-Pecos pipeline from Comanche Trail Pipeline, LLC’s (“Comanche Trail”) proposed
pipeline and request that FERC consider the environmental impacts of the Trans-Pecos pipeline
and the Comanche Trail pipeline together. Trans-Pecos provided a detailed explanation in its
July 15 Answer as to why the Presidio Border Crossing Project is not “connected” to, and has
independent utility from, the Comanche Trail proposed pipeline.18
Environmental, Health and Safety
Many commenters request information regarding the environmental, health and safety
impacts associated with the Presidio Border Crossing Project. Trans-Pecos considered potential
environmental, health and safety impacts associated with the Project in the Environmental
Report filed as Exhibit F to its Application.19 Trans-Pecos has received approval from or filed
permit applications with numerous federal and state agencies regarding the environmental review
for the Project, including the FERC, U.S. International Boundary and Water Commission
(“IBWC”), U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, Texas Historical
Commission (“THC”), Texas Railroad Commission and Texas Parks and Wildlife Department.
As described in more detail in the Application and Environmental Report, construction of the
Project will not, individually or cumulatively, have a significant effect on the quality of human
health, the environment, or landowners.20 In addition, Trans-Pecos will comply with all
applicable state and federal environmental laws and permits and utilize proven construction
techniques and mitigation measures that will result in minimal impacts to human health, the
environment, and landowners. All stakeholders impacted by the location of the Project will
continue to have an opportunity to comment in this proceeding regarding the environmental
impacts of the Project.
Several commenters mention restoration and revegetation within the temporary work
spaces. Trans-Pecos will ensure that all construction and restoration activities for the Project
comply with the FERC’s current Upland Erosion Control, Revegetation, and Maintenance Plan,
and the FERC’s Wetland and Waterbody Construction and Mitigation Procedures issued in May
2013 (“May 2013 Plan and Procedures”). The May 2013 Plan and Procedures address restoration
of the areas temporarily disturbed by the Project and impose post-construction maintenance and

17

July 15 Answer at pp. 16-18.

18

Id. at pp. 18-20.

19

See Application at Exhibit F, Gremminger & Assoc, Inc., Environmental Report for the Presidio Border Crossing
Project (May 2015) (“Environmental Report”).
20

Id. at pp. 8-21, 26-35, 37-40.

 Ms. Kimberly D. Bose
September 25, 2015
Page 6
periodic reporting requirements until restoration is completed to the satisfaction of the state and
federal authorities with jurisdiction over the Trans-Pecos system.21
Several commenters request information regarding the potential impacts of the Project to
water resources and specific plant and animal species. As described in the Environmental Report,
the Project will not impact surface water, groundwater, or waterbodies. In addition, the water
needed for hydrostatic testing of the pipe segment will not deplete water resources in the Project
area because it will be acquired from the City of Presidio, or from an irrigation well in Pecos
County and trucked to the Project location.22 Trans-Pecos will provide additional information
with the responses to the Commission’s September 8, 2015 Data Request regarding the volume
of water needed for horizontal directional drilling (“HDD”) and hydrostatic testing of the
pipeline, the ability of the water sources to meet Project water demands without any negative
effects to the City of Presidio, private irrigation wells, or other groundwater within the water
extraction area. The Project also will have no permanent effect to vegetation, fisheries, wildlife,
migratory birds, listed species or their habitat.23 Trans-Pecos will address impacts to specific
wildlife and vegetation species raised by individual commenters in its responses to the
Commission’s September 8, 2015 Data Request. Trans-Pecos’s response to the Data Request will
also address other topics from the scoping comments, including those regarding seismic activity
in the Project area, potential air emissions associated with the Project, and noise sensitive areas.
The Texas Parks and Wildlife Department (“TPWD”) submitted several comments
regarding vegetation clearing, restoration, best management practices to mitigate potential
impacts to aquatic species, HDD setback requirements, contingency plans, and potential impacts
to state and federally listed endangered or threatened species.24 Trans-Pecos will continue to
consult with the TPWD regarding these comments and comply with all requirements for the
Project imposed by the TPWD.
Additionally, the U.S. Environmental Protection Agency (“EPA”), Region 6, filed
comments regarding potential environmental, health and safety issues associated with the
Project, including, for example, impacts to water supply and water quality, biological resources,
endangered species, air quality, cultural resources, as well as hazardous materials, alternatives,
mitigation, environmental justice, and coordination with land use planning activities and Indian
tribes. Trans-Pecos will continue to consult with the agency regarding these comments and
comply with all requirements for the Project imposed by the EPA.25

21

FERC, Wetland and Waterbody Construction and Mitigation Procedures, pp. 11-12, 17-18 (May 2013), available
at http://www.ferc.gov/industries/gas/enviro/procedures.pdf; FERC, Upland Erosion Control, Revegetation, and
Maintenance Plan, pp. 12-18 (May 2013) , available at http://www.ferc.gov/industries/gas/enviro/plan.pdf.
22

Environmental Report at pp. 10-11.

23

Id. at pp. 13-20.

24

Scoping Comments of the Texas Parks and Wildlife Department (Aug. 17, 2015).

25

Scoping Comments of the U.S. Environmental Protection Agency, Region 6 (Aug. 31, 2015).

 Ms. Kimberly D. Bose
September 25, 2015
Page 7
Cultural Resources
Contrary to several commenters statements that the Project will result in adverse impacts
to cultural and archaeological resources near the Rio Grande, Trans-Pecos considered the
potential impacts of the Presidio Border Crossing Project to cultural resources in Resource
Report No. 4, included within the Environmental Report,26 and found that no existing or
previously unknown cultural resources existed within the proposed temporary workspace for the
Project.27 Trans-Pecos has submitted the cultural resources assessment and “no effect”
determination to the THC for its concurrence, and the THC issued a concurrence letter on
June 1, 2015. In addition, some commenters request notification in the event that cultural
artifacts are observed during Project construction. Trans-Pecos has prepared an Unanticipated
Discovery Plan, included as Appendix F to the Environmental Report, which will govern proper
procedures in such circumstances. Trans-Pecos will address impacts to specific cultural resources
and archaeological sites raised by individual commenters in its responses to the Commission’s
September 8, 2015 Data Request.
Safety and Contingency Planning
Many commenters discuss the safety and reliability of the Presidio Border Crossing
Project and request that an emergency response plan be prepared for the Project in the event of a
significant pipeline emergency. As discussed in more detail in the July 15 Answer, Trans-Pecos
is committed to designing, constructing, operating and maintaining the Presidio Border Crossing
Project in accordance with, and in many instances above, the required industry and regulatory
standards.28 In addition, Trans-Pecos has provided detailed information regarding its emergency
response plan for the Project in Resource Report No. 11 in the Environmental Report.29
Trans-Pecos will coordinate the emergency response plan with local officials prior to
commencing operations in accordance with federal requirements.
Rio Grande River – Horizontal Directional Drilling
Several commenters discuss potential environmental impacts associated with the HDD
process that will be used to install the segment of pipeline under the Rio Grande River, including
potential damage to local aquifers from the HDD bore.30 Trans-Pecos considered potential
environmental impacts associated with the HDD process in Resource Report No. 2 (water use
and quality) and Resource Report No. 3 (vegetation and wildlife) in the Environmental Report.31
As discussed in more detail in Resource Report Nos. 2 and 3, Trans-Pecos will follow the
26

Environmental Report at pp. 17-18.

27

See Environmental Report at Resource Report No. 4, Section 4.1 (citing a May 2015 cultural resources
assessment).
28

July 15 Answer at pp. 22-23.

29

Environmental Report at pp. 37-39.

30

See, e.g., Scoping Comments of Coyne A. Gibson (Aug. 10, 2015).

31

Environmental Report at pp. 8-20.

 Ms. Kimberly D. Bose
September 25, 2015
Page 8
FERC’s May 2013 Plan and Procedures and the Project’s Spill Prevention, Containment, and
Countermeasures Plan, and, as such, construction of the Project should not result in any adverse
impacts to the Rio Grande River, plant, animal or fish species, or habitat.32 With respect to
impacts to groundwater resources in particular, the Project will not affect groundwater resources
in the Project area, and the HDD activity is not expected to result in contamination of any aquifer
resource.33
The FERC’s September 8, 2015 Data Request specifically requested more information
related to the HDD feasibility, including a frac-out analysis with drill path calculations and
predicted annular pressures and formation pressures along drill path. Additionally, Trans-Pecos
also intends to revise its Directional Drilling Contingency Plan to include procedures to capture,
clean and respond to an inadvertent release into the Rio Grande River.
Alternatives
Many commenters request that the Commission consider alternative locations for the
Project and related facilities. Trans-Pecos provided a description of the “no-action” alternative
and whether other alternative crossing locations existed in Resource Report No. 10 in the
Environmental Report.34 As discussed in Resource Report No. 10, the “no-action” alternative
would result in the loss of new infrastructure to market and export natural gas supplies produced
in the United States and would result in fewer gas supplies for electric generation plants in
Mexico. Trans-Pecos is not aware of another border crossing facility that could accommodate on
a firm basis the volume of gas associated with this Project. Additionally, no alternative crossing
locations exist because the location of the Project is dictated by the preferred alignment for the
pipeline inside Mexico. Moreover, the proposed Project location was deemed to be
environmentally benign and lacks any issues that would prompt consideration of alternative
crossing locations. Thus, the “no-action” alternative and any potential alternative crossing
locations were incompatible with the purpose and need of the Project to connect the pipeline on
the Mexican side of the border and, thus, not in the best interest of the public.35
BBCA asserts that Council on Environmental Quality (“CEQ”) regulations require the
Commission to prepare a comprehensive cost-benefit analysis of alternatives for the Trans-Pecos
system.36 However, the CEQ regulations governing cost-benefit analyses do not require such
assessments and, in any event, the regulations pertain to alternatives analyses in an EIS, not an
EA.37 As discussed above and in the July 15 Answer, the Commission has correctly determined

32

Id.

33

Id. at p. 10.

34

Id. at p. 36.

35

Id.

36

BBCA Comments at p. 24.

37

40 C.F.R. § 1502.23 (2015).

 Ms. Kimberly D. Bose
September 25, 2015
Page 9
that preparation of an EA for the Presidio Border Crossing Project and not an EIS is
appropriate.38
Finally, some commenters assert that Trans-Pecos has not provided sufficient information
regarding the location of the proposed facilities.39 Trans-Pecos provided detailed figures attached
as Exhibit G to its Application showing the physical location of facilities to be constructed.
Socioeconomic Impacts
Several commenters assert that the Project will result in negative socioeconomic impacts
to the Big Bend region. As described in Resource Report No. 5 in the Environmental Report, the
Project is not expected to have a substantial effect, either positively or negatively, on
socioeconomics of the area.40
National Security
Some commenters state that the Project will increase threats to national security and
facilitate illegal immigration. However, as explained in Section 1.9 of the Environmental Report,
Trans-Pecos will coordinate with the U.S. Department of Homeland Security (“DHS”) and the
Big Bend Sector of the Customs and Border Patrol (“CBP”) to address threats to national
security during construction and operation of the Project.41 Trans-Pecos will comply with all
DHS and CBP programs and regulations, and Trans-Pecos will discuss and coordinate the
security plan with the relevant state and local emergency responders, agencies, and other
personnel with the required security clearances. In addition, Trans-Pecos has an emergency
response plan that is discussed in Resource Report No. 11 in the Environmental Report.42
Trans-Pecos will also address its ongoing consultation with the CBP in its response to the
Commission’s September 8, 2015 Data Request.

38

July 15 Answer at pp. 16-18.

39

See, e.g., Scoping Comments of Beth Doolittle (Aug. 26, 2015).

40

Environmental Report at p. 24.

41

Id. at p. 6.

42

Id. at pp. 38-39.

 Ms. Kimberly D. Bose
September 25, 2015
Page 10
Trans-Pecos is committed to addressing concerns raised by landowners and other
stakeholders in this proceeding. All such stakeholders impacted by the location of the Presidio
Border Crossing Project will continue to have an opportunity to participate in the process as the
Commission’s NEPA review process continues in this proceeding.
If you have any questions regarding this filing, please contact the undersigned at
(713) 989-2606.
Respectfully submitted,
Trans-Pecos Pipeline, LLC
/s/ Kelly Allen
Mr. Kelly Allen, Manager
Regulatory Affairs Department

cc:

Mr. Anthony J. Rana, Office of Energy Projects

 CERTIFICATE OF SERVICE

In accordance with the requirements of Section 385.2010 of the Commission’s Rules of
Practice and Procedures, I hereby certify that I have this day caused a copy of the foregoing
document to be served upon each person designated on the official service list compiled by the
Commission’s Secretary in this proceeding.

/s/ Kelly Allen
Mr. Kelly Allen
Regulatory Affairs Department
Trans-Pecos Pipeline, LLC
(713) 989-2606