Bill, attached is a first draft of the advice letter comments.  As noted in
my earlier email, this is due tomorrow, not today.  Please get back to me
with any comments and/or suggestions.  My apologies for the delay in getting
this to you.

Dan

Law Offices of Daniel W. Douglass
5959 Topanga Canyon Blvd.  Suite 244
Woodland Hills, CA 91367
Tel:   (818) 596-2201
Fax:  (818) 346-6502
douglass@energyattorney.com
----- Original Message -----
From: "Rapp, Bill" <Bill.Rapp@enron.com>
To: <douglass@energyattorney.com>
Sent: Friday, November 16, 2001 2:12 PM
Subject: FW: SCG Advice 2837-A



Dan,

This is a follow up to our telephone conversation of this
afternoon. The attachment, which apparently originated with you, is what
we will talk about during our conference call at 8:00 a.m. (California
time) on Monday. Thanks.

>  -----Original Message-----
> From: Donoho, Lindy
> Sent: Friday, November 16, 2001 4:01 PM
> To: Rapp, Bill; Hass, Glen; Blair, Lynn; Harris, Steven; Kowalke,
> Terry; Lokey, Teb; Kilmer III, Robert; #99 Tech Support,; Watson,
> Kimberly; Lindberg, Lorraine; Lohman, TK
> Subject: FW: SCG Advice 2837-A
>
> After discussing with Lynn and Glen, we think that we would like to
> file comments in this proceeding concerning an issue we have had since
> this has been implemented on Nov 1.  In instances where SoCal happens
> to call their OFO in the Intraday 2 cycle, it can cause Transwestern
> to have Shipper imbalances because we do not have an opportunity to
> pass-along these reductions to our upstream parties.  We think we
> would like to file a letter that may mention our general support of
> the "direction" of SoCal's changes, but that we do have an issue that
> has developed since actual implementation that we are currently
> working on with them.  Lynn & I worked on this rough general
> description we thought could be incorporated into a brief letter.
>
> "If SoCal calls an OFO in the Intraday 2 Cycle, an
> allocation is passed to Transwestern through the confirmation process
> with SoCal.  Due to the timing of these OFO's, Transwestern is unable
> to confirm such reductions with Transwestern's upstream parties."
>
> Lynn thinks if we are unable to resolve this issue with SoCal, TW
> could have high Shipper imbalance exposure.
>
>  -----Original Message-----
> From: Harris, Steven
> Sent: Wednesday, November 14, 2001 9:50 AM
> To: Donoho, Lindy
> Subject: FW: SCG Advice 2837-A
>
> Lindy , can you please take a look at this and let me know if we
> should file comments. Thanks. You might see if Glen has looked at it
> yet.
>
> Steve
>
>  -----Original Message-----
> From: "Dan Douglass" <douglass@energyattorney.com>@ENRON
> Sent: Friday, November 09, 2001 5:02 PM
> To: Hass, Glen; Harris, Steven
> Cc: Gregg Klatt
> Subject: SCG Advice 2837-A
>
>
> Glen and Steve:
>
> The attached supplemental advice filing by SoCalGas replaces the
> changes to Rule 30, Transportation of Customer-Owned Gas, proposed by
> AL2837.   The purpose of this filing is to  describe the new internal
> receipt point operating procedures that SoCalGas is  implementing, and
> to request Commission authorization to include the revised  operating
> procedures in Rule 30. SoCalGas says this step is being taken in
> anticipation that it will be replaced with a system of firm tradable
> intrastate  transmission rights in Gas Industry Restructuring (GIR)
> proceeding, I.99-07-003.
> During  the GIR panel hearings, several parties requested that
> SoCalGas publish its  windowing criteria in tariffs to facilitate a
> better understanding of the method  used to allocate receipt point
> capacity.  SoCalGas agreed to make  such a filing, and D.99-07-015
> directed SoCalGas to file an advice letter adding  windowing
> information to its tariffs.  To comply with this directive, on August
> 6, 1999, SoCalGas filed AL2837, which has not been acted on by the
> Commission.
> Customer complaints about SoCalGas' windowing  procedures have
> convinced SoCalGas that it should replace its internal  windowing
> operating procedures with a system that is open to the maximum
> operating capacity at each SoCalGas receipt point.  SoCalGas is making
> these internal  operating changes effective November 1, 2001.
> SoCalGas held meetings with upstream  pipelines on October 17, and
> with interested customers and stakeholders on  October 18, regarding
> the upcoming changes.  They were invited to ask any questions in  the
> days leading up to the meetings.
> Comments and/or protests are due on November 21.  Have a good
> weekend!
> Dan
>
> Law Offices of Daniel W. Douglass
> 5959 Topanga Canyon Blvd.  Suite  244
> Woodland Hills, CA 91367
> Tel:   (818) 596-2201
> Fax:   (818) 346-6502douglass@energyattorney.com
> <<mailto:douglass@energyattorney.com>>
>
>  - AL2837-A.PDF <<AL2837-A.PDF>>


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