I read the same.  It was crazy.  Their solution is to tell us to do what we said didn't make sense.  We won't give the FERC made up information.

Jim

 -----Original Message-----
From: 	Lawner, Leslie  
Sent:	Friday, October 12, 2001 12:13 PM
To:	Shapiro, Richard; Steffes, James D.; Kean, Steven J.; Kingerski, Harry; Cantrell, Rebecca W.; Calcagno, Suzanne; Fulton, Donna
Cc:	Pharms, Melinda
Subject:	FERC rehearing of the California monthly gas sales reporting requirement, RM01-9

This is not intended to be summary of the FERC rehearing just issued on the Monthly Marketers' Report of Gas Sales to California, but just a heads-up on one issue.  We argued that since we manage our business on an aggregated basis, we cannot report the sales, purchases and transportation on the back-to-back basis contemplated in the rule.  FERC's response was that did not relieve us of the need to report and that since everything is aggregated, then all purchases and transportation should be allocated pro rate to the sales made into CA.  This interpretation is as arbitrary and meaningless as the after-the-fact allocations of supply and transport to specific sales woud have been, that we argued against.  And it is probably just as labor intensive.  When Becky gets back we will look into the burden of compliance, but we have the option to seek further rehearing on this issue.