Mike -- Thanks for the input...we stewed over this for a while but decided to 
respond (as briefly as possible) rather than give Norm a chance to whine to 
the judge that we were being uncooperative in this somewhat unusual exhibit 
drafting process.  Jeff's answer is consistent with what will appear in the 
exhibit (and from what one can find out about TW in numerous of our FERC 
filings, for that matter).  If Norm tries somehow to make Jeff's response 
part of the record you can bet I will object...if it's not on the record 
already, or on the face of this one late-filed exhibit, it should not be 
allowed into the record.  
Apparently Norm has also called Rich Hall with annoying questions.
I don't plan to respond if he contacts us with any follow-up, but will let 
you know if he does.
SS




MBD <MDay@GMSSR.com> on 06/15/2000 05:39:54 PM
To: "'Susan.Scott@enron.com'" <Susan.Scott@enron.com>
cc:  

Subject: RE: Late-Filed Exhibit


Susan:

 Good response.  Be advised that Norm is a little out of order asking
discovery questions like this after the record is closed.  You are not
obligated to respond to him under these circumstances.  He is still trying
to buttress his apparent belief that the EPNG and TW capacity to the
California border is completely fungible and can be delivered to either
SoCal or PG&E without any limitations.  Please let me know if he tries this
again.  Thanks, Mike

-----Original Message-----
From: Susan.Scott@enron.com [mailto:Susan.Scott@enron.com]
Sent: Thursday, June 15, 2000 2:17 PM
To: Norman A. Pedersen
Cc: 'Pocta, Robert M.'; Cherry, Brian - TPBKC; '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.'; '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'; Betonte, Robert - TP2RSB; Brill, Thomas R.;
Follett, B. David - TPDBF; Harrigan, James P. - TP1JPH; Hay, James E.;
Lorenz, Lad - TPLPL; McVay, Nancy W - TPNWM; Morrow, Rick - TP3RMM;
Purves, Ralph A.; Sakarias, Wayne P.; Schavrien, Lee; Sullivan, Glen J.;
Surak, Thomas M. - TP1TMS; Teeter, James S.; Van Lierop, Jan - TP2JXV;
Watson, Steven - TP2SAW; Wright, Gillian - TP1GXW; Barker, David -
TPDTB; 'How-Downing, Lindsey'; 'Jun, Christine'; 'Gileau, Patrick L.';
'Khoury, Dexter'; 'ack@aelaw.com'; Nelson, Eric B. - TPEBN; Suwara, J.-
TPJUS; Wright, Gillian - TP1GXW; Reed, William; 'Paul, Joe'; 'Hawiger,
Marcel'; 'Fawcett, Jeff'; 'O'Neill, Ed'; 'Power, Pat'; 'Ramirez, Jaime';
'Black, Larry'; Fair, Pam; 'Hall, Rich'; 'Eisenman, Eric'; 'Stoner,
Ron'; 'McConn, Kathy'
Subject: Late-Filed Exhibit



In response to your inquiry, Transwestern would first like to clear up the
terminology being used here.  As you know, currently SoCalGas doesn't
assign "primary rights" to deliveries off of any interconnecting pipeline.
The establishment of tradeable rights for intrastate capacity is among the
issues currently under consideration in the GIR proceeding.   However, if
what you are asking about is what has been the historical or otherwise
available receipt capacity for Transwestern deliveries at North Needles,
then let me offer the following.

Transwestern has always operated on the premise that SoCalGas could
physically accept up to a maximum of 750 MMcf/d at its North Needles
receipt point.  Consequently, Transwestern has sold firm transportation to
its interstate customers for west flow deliveries to North Needles not to
exceed the 750 MMcf/d limitation.  Our west flow mainline capacity is 1.09
Bcf/d.






"Norman A. Pedersen" <napedersen@JonesDay.com> on 06/14/2000 08:12:05 PM

To:   Susan.Scott@enron.com
cc:   "ceyap" <ceyap@earthlink.net>

Subject:  Re: Late-Filed Exhibit




_______________________________________________________________

This message and any attachments are intended for the individual or entity
named above.  If you are not the intended recipient, please do not read,
copy, use or disclose this communication to others; also please notify the
sender by replying to this message, and then delete it from your system.
Thank you.
_______________________________________________________________

To: Jeff Fawcett:

     Do Transwestern shippers to Transwestern's North Needles delivery
point have 1090 MMcfd of primary rights into ScCalGas, 750 of primary
rights. or some other number?