Transwestern had 11 releases during the period 11/15-12/15/00.  None were 
above max. rate.  All were at max. rate.

El Paso had several dozen releases during this period in the CA zone.  All 
but 5 are listed as straight max rate deals.  Five have a fixed rate which 
are also within +/- 1 cent of the max rate (assumably for surcharge related 
reasons).

---------------------- Forwarded by Shelley Corman/ET&S/Enron on 12/13/2000 
12:34 PM ---------------------------


Shelley Corman
12/13/2000 11:23 AM
To: S

Subject: Additional Arguments for Enron's Gas Cap Response



Premise: FERC should investigate the utility decisionmaking that led the 
Califonia market to the point of excess gas demand, rather than rush to 
impose gas price caps.

Utilities had ample opportunity to fill up storage last summer, but most 
likely choose not to for price reasons.

Transwestern had at least a 100 M/D of available capacity to Califonia and to 
the SoCal Needles delivery point through July 2000.  
 
 Avg. Scheduled (compared to 1.1 Bcf/D capacity): April  780 
        May  820
        Jun-Jul  980
        Aug  1050
        Oct-Dec 1080 (essentially full)

During the period April-Jul, TW was able to deliver up to the full 750 M/D at 
Needles, but on many days SoCal gas instituted "windowing," lowering the 
ability to take at Needles to 680-720 M/D.  SoCal's argument was that they 
didn't believe that there was sufficient demand to run at the 750 M/D level 
(even when TW had nominations of 750 M/D).

El Paso was also not full to Califonia until the last month.   At all times 
El Paso  had available capacity at PG&E delivery points.  During the pipeline 
outage El Paso was limited in their ability to fully deliver to the North 
SoCal delivery point.  However, they were not full for deliveries to SoCal at 
the south system delivery point.


2.    Utilities have opposed pipeline expansions to California

Sempra protested Transwestern's 140 M/D Gallup expansion, arguing that there 
is no need for new capacity (CP99-522).

Sempra has also protested Questar's application to convert an oil line to new 
gas pipeline service to California (S. Trails Expansion).