On behalf of Watson and Vernon, I strongly object to the removal of the data
on the takeaway capacity to other markets besides the SoCalGas system, as
Norman apparently proposes in his draft exhibit.  Without the data on
takeaway capacity to other markets, the exhibit suggests that all of the
upstream interstate and PG&E capacity is designed to serve just the SoCalGas
market.  This is simply not factually true, and suggests that there are
"mismatchs" of intrastate and interstate capacity where, in reality, such do
not exist or are much smaller in magnitude.  The ALJ asked for this exhibit
not to show that a mismatch exists, but to present the full data on both the
delivery and take-away capacity at the border, so that the Commission can
evaluate the extent to which any mismatches exist.

I will offer two suggestions for resolving this matter: (1) add another
column to Norman's exhibit showing the takeaway capacity to other markets
besides SoCalGas, based on the numbers in SoCalGas' draft exhibit, or (2)
let parties file their own versions of the exhibit that the ALJ requested.

Tom Beach

----- Original Message -----
From: Norman A. Pedersen <napedersen@JonesDay.com>
To: Cherry, Brian - TPBKC <BCherry@sempra.com>
Cc: 'Pocta, Robert M.' <rmp@cpuc.ca.gov>; Cherry, Brian - TPBKC
<BCherry@sempra.com>; <AlexanMS@sce.com>; <paulamirault@aec.ca>;
<david.bayless@utility.com>; <Tomb@crossborderenergy.com>; <Burkee@cts.com>;
<Craigc@calpine.com>; <Rick.Counihan@greenmountain.com>;
<Jdasovic@enron.com>; <Mday@gmssr.com>; <bdingwall@unitedgas.com>;
<Douglass@arterhadden.com>; <eke@aelaw.com>; <Jfawcet@enron.com>;
<rfoss@coral-energy.com>; 'Gileau, Patrick L.' <plg@cpuc.ca.gov>;
<johnj@bcjlaw.com>; <Johnson_Pamela@lacoe.edu>; <karpjos@sf.whitecase.com>;
<jleslie@luce.com>; <kmccrea@sablaw.com>; <jmpa@dynegy.com>;
<porterdk@sce.com>; <RochmanM@cubjpa.org>; <RochmanM@spurr.org>;
<susan.scott@enron.com>; Betonte, Robert - TP2RSB <RBetonte@socalgas.com>;
Brill, Thomas R. <TBrill@sempra.com>; Follett, B. David - TPDBF
<DFollett@sempra.com>; Harrigan,
Sent: Thursday, June 15, 2000 11:08 PM
Subject: Re: Final Late Exhibit Draft


>
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>      Your proposed draft exhibit goes substantially beyond the ALJ's
order.
> ALJ Biren specifically stated that the the late-filed exhibit "should be
> narrowly focused on the mismatch of capacity." Tr. 1021.Thus, you need to
> eliminate the column entitled "Total Take-away Capacity."  Furthermore,
the
> column is both suspect (e.g., the representation that EOR is 770 MMcfd)
and
> misleading (e.g., the inclusion of SWG or PG&E in "S. Calif Take-away
> Capacity").  Also, you need to eliminate the "Avg. Daily Market" box.  The
> following is what should be submitted to ALJ Biren:
> (See attached file: #1070989 v1 - FIRM PIPELINE CAPACITY DELIVERY (EX. TO
> I.99-07-003).doc)