----- Forwarded by Steven J Kean/NA/Enron on 01/02/2001 09:45 AM -----

	Phillip K Allen@ECT
	12/22/2000 03:06 PM
		 
		 To: Steven J Kean/NA/Enron@Enron
		 cc: 
		 Subject: 

Steve,


I am sending you a variety of charts with prices and operational detail.  If 
you need to call with questions my home number is 713-463-8626.









As far as recommendations, here is a short list:

 1.  Examine LDC's incentive rate program.  Current methodology rewards sales 
above monthly index without enough consideration of future 
      replacement cost.  The result is that the LDC's sell gas that should be 
injected into storage when daily prices run above the monthly index.
                    This creates a shortage in later months.

 2.  California has the storage capacity and pipeline capacity to meet 
demand.  Investigate why it wasn't maximized operationally.  
                      Specific questions should include:  

  1.  Why in March '00-May '00  weren't total system receipts higher in order 
to fill storage?

  2.  Why are there so many examples of OFO's on weekends that push away too 
much gas from Socal's system.  
       I believe Socal gas does an extremely poor job of forecasting their 
own demand.  They repeatedly estimated they would receive       more gas than 
their injection capablity, but injected far less.

 3.  Similar to the power market,  there is too much benchmarking to short 
term prices.  Not enough forward hedging is done by the major 
                    LDCs.  By design the customers are short at a floating 
rate.  This market has been long historically.  It has been a buyers market 
and the 
     consumer has benefitted.  


Call me if you need any more input.


Phillip