pls print.  thanks df
---------------------- Forwarded by Drew Fossum/ET&S/Enron on 04/12/2000 
03:10 PM ---------------------------


Janet Butler
04/12/2000 02:50 PM
To: Tim Aron/ET&S/Enron@ENRON, John Ballentine/FGT/Enron@ENRON, Martha 
Benner/ET&S/Enron@ENRON, Eric Benson/ET&S/Enron@ENRON, Donna 
Bily/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Lynn Blair/ET&S/Enron@ENRON, Jack 
Boatman/FGT/Enron@ENRON, Rob Bradley/Corp/Enron@ENRON, Lorna 
Brennan/ET&S/Enron@ENRON, Bob Chandler/ET&S/Enron@ENRON, Bill 
Cordes/ET&S/Enron@ENRON, Shelley Corman/ET&S/Enron@Enron, Christi 
Culwell/FGT/Enron@ENRON, Mary Darveaux/ET&S/Enron@ENRON, Larry 
DeRoin/NPNG/Enron@ENRON, Rick Dietz/ET&S/Enron@ENRON, Dari 
Dornan/ET&S/Enron@ENRON, John Dushinske/ET&S/Enron@ENRON, Sharon 
Farrell/FGT/Enron@ENRON, Drew Fossum/ET&S/Enron@ENRON, Donna 
Fulton/Corp/Enron, Lou Geiler/ET&S/Enron@ENRON, John 
Goodpasture/OTS/Enron@ENRON, Mary Hain/HOU/ECT@ECT, Bob M 
Hall/FGT/Enron@ENRON, Steven Harris/ET&S/Enron@ENRON, Joe 
Hartsoe/Corp/Enron@ENRON, Glen Hass/ET&S/Enron@Enron, Robert 
Hayes/FGT/Enron@ENRON, Rod Hayslett/FGT/Enron@ENRON, Bambi 
Heckerman/NPNG/Enron@ENRON, Theresa Hess/ET&S/Enron@ENRON, Robert 
Hill/NPNG/Enron@ENRON, Staci Holtzman/FGT/Enron@ENRON, Tamara 
Hopkins/ET&S/Enron@Enron, Stanley Horton/Corp/Enron@Enron, Lee 
Huber/ET&S/Enron@ENRON, Martha Janousek/ET&S/Enron@ENRON, Steven 
January/ET&S/Enron@ENRON, Anne Jolibois/FGT/Enron@ENRON, Steven J 
Kean/HOU/EES@EES, Jeffrey Keeler/Corp/Enron@ENRON, Robert 
Kilmer/FGT/Enron@ENRON, Frazier King/FGT/Enron@ENRON, Steve 
Kirk/ET&S/Enron@ENRON, Tim Kissner/ET&S/Enron@ENRON, Laura 
Lantefield/ET&S/Enron@ENRON, Linda L Lawrence/HOU/EES@EES, Blair 
Lichtenwalter/FGT/Enron@ENRON, Elizabeth Linnell/HOU/EES@EES, Teb 
Lokey/FGT/Enron@ENRON, Phil Lowry/OTS/Enron@ENRON, Susan J Mara/SFO/EES@EES, 
Donna Martens/ET&S/Enron@ENRON, Dorothy McCoppin/FGT/Enron@ENRON, Mike 
McGowan/ET&S/Enron@ENRON, Rockford Meyer/FGT/Enron@ENRON, Mary Kay 
Miller/ET&S/Enron@ENRON, Michael Moran/ET&S/Enron@ENRON, Sheila 
Nacey/ET&S/Enron@ENRON, Michel Nelson/ET&S/Enron@ENRON, Ray 
Neppl/NPNG/Enron@ENRON, Robert 
Neustaedter/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Christi L 
Nicolay/HOU/ECT@ECT, Sarah Novosel/Corp/Enron@ENRON, Maureen 
Palmer/HOU/EES@EES, Zelda Paschal/FGT/Enron@ENRON, Geneva 
Patterson/NPNG/Enron@ENRON, Maria Pavlou/ET&S/Enron@ENRON, Eileen 
Peebles/ET&S/Enron@ENRON, Keith Petersen/ET&S/Enron@ENRON, Peggy 
Phillips/FGT/Enron@ENRON, Janet Place/NPNG/Enron@ENRON, Tony 
Pryor/ET&S/Enron@ENRON, Colleen Raker/ET&S/Enron@ENRON, Bret 
Reich/ET&S/Enron@ENRON, Kathy Ringblom/ET&S/Enron@ENRON, Jenny 
Rub/GPGFIN/Enron@Enron, Cynthia Sandherr/Corp/Enron@ENRON, James 
Saunders/FGT/Enron@ENRON, Donna Scott/FGT/Enron@ENRON, Susan 
Scott/ET&S/Enron@ENRON, Richard Shapiro/HOU/EES@EES, Dave 
Schafer/ET&S/Enron@ENRON, Mike G Smith/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, 
Louis Soldano/ET&S/Enron@ENRON, Lon Stanton/ET&S/Enron@ENRON, James D 
Steffes/HOU/EES@EES, James Studebaker/FGT/Enron@ENRON, Jim 
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Debbie Thompson/FGT/Enron@ENRON, Melinda Tosoni/ET&S/Enron@ENRON, Denis 
Tu/FGT/Enron@ENRON, Michael Van Norden/Corp/Enron@ENRON, Stephen 
Veatch/FGT/Enron@ENRON, Donald Vignaroli/ET&S/Enron@ENRON, Jody 
Warner/NPNG/Enron@ENRON, Kimberly Watson/ET&S/Enron@ENRON, Amber 
White/HR/Corp/Enron@Enron, Julia White/ET&S/Enron@ENRON, Kim 
Wilkie/ET&S/Enron@ENRON, Jane Wilson/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, 
Michele Winckowski/ET&S/Enron@ENRON
cc:  

Subject: OCS Final Rule, Order 639


Regulations Under the Outer Continental Shelf Lands Act Governing the 
Movement of Natural Gas on Facilities on the Outer Continental Shelf, RM99-5 

The final rule is attached - 84 pages      



Executive Summary
The Final Rule was issued April 10, 2000 and becomes effective 30 days after 
publication in the Federal Register.

The purpose of the final rule is to establish a data base as a foundation for 
identifying discrimination with OCS gas service providers.  The reporting 
will include affiliations and conditions of service.  This is a procedural 
rule - reporting only.  The rule only applies to gas pipelines - FERC found 
transportation for oil pipelines to be just and reasonable.  The Commission 
is acting in part as a response to the ruling in Sea Robin in which the court 
directed FERC to reconsider the manner in which it applied its primary 
function test to Sea Robin's predominantly offshore system.  

NOPR was issued on June 30, 1999.  The Commission believes that the new OCSLA 
reporting requirements mirror certain existing NGA reporting requirements.  
Salient points of the final rule are:

Exemptions
Service providers that confine their operations to moving their own gas or 
that of a single shipper are exempt from reporting; add new section 
330.0(a)(1) and (2)   Note:  reporting exemption turns on identity of service 
provider and its shippers - not type of service provided.
Gas service providers that are regulated by FERC under NGA are exempt from 
OCSLA reporting; add new section (330.3(a)(4)
Exempts lines that feed into a facility where gas is first collected, 
separated, dehydrated or processed from OCSLA reporting requirements; add new 
section 330.3(a)(3).

Reporting Requirements
If an NGA-regulated company's system includes OCS facilities that are not 
subject to NGA (gathering/production lines), the company must submit an OCSLA 
report covering its non-NGA facilities
Reclassified facilities will no longer be subject to NGA reporting 
requirements but will be subject to OCSLA requirements. (Shippers  no longer 
have protection against the exercise of market power afforded by the NGA). 
Service provider must list all of its affiliates defined as engaged in the 
exploration, development, production, processing, transportation, marketing, 
consumption or sale of gas need be identified in the report; new section 
330.2(a)(6)
Reporting Updates restricted to four times per year.  
Reports will be based on conditions on the first day of the first full 
calendar quarter that begins after the effective date of this rule; reports 
due on the first business day after the close of the quarter.  Providers will 
have more than one full quarter in which to prepare their initial OSCLA report
Providers will be required to submit a description of their operations as 
they stand on the first day of each calendar quarter, e.g. describing the 
provider's status on one particular day; report due on first business day of 
the subsequent quarter (e.g. filing due April 1 will describe operations as 
they stood on January 1).  If the operations are identical on the first and 
last days of any given quarter, provider need not submit an update the 
following quarter
Not necessary to file contracts but must provide table of shippers and 
services; new section 330.2(b)
Retaining requirement for alternative reporting for OCS companies who do not 
provide service under formal contracts, must provide information sufficient 
to derive rates charged and conditions applicable for service between two 
points; new section 330.2(b)(9)
OCSLA Reporting Form available via Internet  http://www.ferc.fed.us or the 
public reference room
Providers new to provisions have 90 days to prepare and submit OCSLA report 
(NOPR had stipulated 60 days).