As you know, we recently did an east-to-east deal with USGT for 400,000 
MMBtu/day with alternate rights to California 
at a higher rate.  SoCal filed a protest and I'm working on the response.  In 
part, they are alleging that TW is "attempting to exploit a weakness" in the 
GISB procedures to the detriment of existing customers.  For example, under 
TW's tariff (which they concede is GISB compliant), primary firm cannot bump 
alt. firm in cycle 2.  SoCal says this means that any primary shipper 
attempting to deliever to an in-path alt. point will be unable to re-nominate 
to its primary point once this "alternate" capacity [I assume they mean 
USGT's] is confirmed.  According to SoCal this will substantially limit 
shippers' flexibility, including the ability to use market area pooling.  
Once gas is nominated thru a pool its subsequent movement to a delivery point 
is defined as an al. delivery regardless of the rights of the capacity under 
which it moves.  Thus by manipulating the GISB cycle process, TW and USGT 
will bump firm shippers.

I could really use your help in responding to this argument.  (First of all, 
I'm not sure I even understand it!)  If either of you have a few minutes 
today or tomorrow when we could get together, that would be great.  Also -- 
you two were the first to come to mind, but feel free to refer me to someone 
else in your group if you are swamped.  Please e-mail or call when you get a 
chance...
Thanks!
Susan (x30596)