The attached comments in FERC's rulemaking proceeding on reporting 
requirements for the California market are being filed today.   The comments 
express our opinions that (1) permanent, formal reporting requirements are 
not appropriate to address a temporary problem and that the markets are 
working as they should and responding with new pipeline proposals to address 
lack of capacity, (2) the Commission's powers under the Natural Gas Act to 
require information are for investigatory purposes only, not for formalized, 
routine reporting requirements, (3) the notice of order does not indicate how 
the Comission would protect the proprietary and competitively sensitive 
information it would collect, and (4) the requirements impose a significant 
and undue burden on sellers of natural gas who would have to radically alter 
the way they manage their business in order to provide the information in the 
manner proposed.

Please feel free to contact me at X.35840 in Houston if you have any 
questions or would like further information.