FYI.  I'll keep all of you posted as we complete our analysis and respond to 
Larcamp's thoughts.

Jim


---------------------- Forwarded by James D Steffes/HOU/EES on 07/30/2000 
12:02 AM ---------------------------


Shelley Corman@ENRON
07/27/2000 03:01 PM
To: Stanley Horton/Corp/Enron@Enron, Bill Cordes/ET&S/Enron@ENRON, Rockford 
Meyer/FGT/Enron@ENRON, Mary Kay Miller/ET&S/Enron@ENRON, rkilmer@enron.com, 
Ray Neppl/NPNG/Enron@ENRON, Drew Fossum/ET&S/Enron@ENRON, Teb 
Lokey/FGT/Enron@ENRON, Julia White/ET&S/Enron@ENRON, Steven 
Harris/ET&S/Enron@ENRON, Susan Scott/ET&S/Enron@ENRON
cc: James D Steffes/HOU/EES@EES, Christi L Nicolay/HOU/ECT@ECT 
Subject: Follow-up on Larcamp Visit: Comparing Gas /Electric Positions


When Dan Larcamp recently visited he commented that pipelines need to take a 
look at differences between gas and electric positions and practices.  In 
fact, his main concern about pipeline marketing affiliate practices relate to 
the fact that they differ from practices on the electric side.

I am working with Jim Steffes and Christi Nicolay on a comparison of gas and 
electric practices in the following areas mentioned by Dan Larcamp.  Here is 
a quick look at the areas that we are comparing:
Contracting for transportation/transmission capacity.  Pipelines currently 
have a form of service agreement in their tariffs, but they also enter into 
non-conforming agreements and discount agreements with shippers.  In 
contrast, transmission customers enter a two-page standardized blanket 
transmission agreement.  Then they reserve specific quantities and points 
on-line via OASIS.   This is probably the area that we'll have the most 
difficult time arguing why we are different than the electric side.
Negotiating discounts.  Customers may call or fax pipeline staff to negotiate 
discounts, although sometimes a pipeline may post a generally available 
discount on the website.  On the electric side, discounts are rarely granted, 
but if discounts are granted it is handled through OASIS.
Functionality of OASIS vs. pipeline websites.  Its true that the OASIS system 
facilitates the reservation of transmission space  (i.e. contracting) and 
discounts, but it doesn't accommodate nominations, invoices, and index of 
customers or many of the other features available on pipeline web sites.  
Marketing affiliate rules.  I plan to lay out a side by side comparison of  
Sec. 37 (electric rules) and 161 (gas marketing affiliate rules).  One 
difference, the posting of organization charts, will be gone after September, 
as pipelines will add this information to the web site.  
Content of Form 1 vs. Form 2.  Dan Larcamp mentioned that he feels like 
electric form 1s have more useful market data.  I'm not sure we're comparing 
apples and apples, as the electrics are still integrated utilities and thus 
the form 1 includes sales data. But, we'll put together a comparison 
nonetheless.

Hopefully, the detailed comparison can be completed in the next month.  Also, 
FYI Enron Government Affairs is currently working on their comments to the 
latest OASIS rulemaking and plan to use the comparison work to suggest best 
pipeline website practices that could be a model for OASIS.  I'll keep you 
posted.