My comments pertain to page 2 of the chart under section C.4
referring to increasing the cashout prices to 75% and 125%.  I recommend a
few changes.  First the chart makes a reference to increasing Tier II
cashout prices under the Content Column.  This should be changed to Tier I
cashout prices consistent with the OFO settlement.  Second, it may be
appropriate to provide some additional details on this issue in the Change
to Gas Accord column.  One option is something along the following lines:
"None.  This change is consistent with the Gas Accord provision which allows
PG&E to file to revise imbalance charges and cash-out options.  The current
Tier I cashout prices do not provide an economic disincentive for incurring
cash-out imbalances in all months as intended in the Gas Accord.  This can
serve as a factor contributing to pipeline OFOs.  The change to the Tier I
cash-out prices is consistent with the intent of the Gas Accord, and the
objective to reduce pipeline OFO's."

-----Original Message-----
From: Yoo, Salle [mailto:salleyoo@dwt.com]
Sent: Wednesday, November 17, 1999 2:32 PM
To: 'Amirault, Paul'; 'Craig Chancellor'; 'Gerald Worster'; 'Grant
Kolling'; 'James Weil'; 'Jeff Dasovich'; 'John Leslie'; 'Marcel
Hawiger'; 'Mark Baldwin'; 'Mark Pocta'; 'Michael Rochman'; 'Raveen
Maan'; 'Rich Hall'; 'Ron Oechsler'; 'Tom Solberg'; 'Timothy J Hamilton';
'plg@cpuc.ca.gov'; 'mark.c.moench@wgp.twc.com'; 'mday@gmssr.com';
'jmct@gmssr.com'
Cc: How-Downing, Lindsey
Subject: FW: Comments on OFO Settlement


Enclosed is a copy of the proposed Comments of the Settlement Parties in
Support of the OFO Settlement.  ("Comments")  The Comments address the
specific issues raised by ALJ Biren at the last prehearing conference as
laid out below in our previous email.

I am also attaching a copy of the Declaration of Dan Thomas (addressing how
the Settlement is in the public interest) and the matrix developed by PG&E
that compares the terms of the OFO Settlement to those in the Gas Accord.

In order to expedite the process, PG&E has suggested that it, as a
representative of all settlement parties, be the sole signatory to the
Comments.  Therefore, please review the enclosed documents, provide any
revisions and an indication of your assent/dissent to having PG&E sign the
document on your behalf by end of business tomorrow (Thursday, November 18).
The deadline for filing the Comments in Monday, November 22.

If you have any questions, please do not hesitate to call.

Salle E. Yoo
Davis Wright Tremaine
One Embarcadero Center, Suite 600
San Francisco, CA 94111
Tel. 415 276-6564; Fax 415 276-6599
salleyoo@dwt.com

 <<Comments_OFO.doc>>  <<dft-dec.doc>>  <<chart.doc>>
> -----Original Message-----
> From: Yoo, Salle
> Sent: Monday, November 15, 1999 11:16 AM
> To: 'Amirault, Paul'; 'Ben Ledene'; 'Craig Chancellor'; 'Grant Kolling';
> 'Jeff Dasovich'; 'John Leslie'; 'Marcel Hawiger'; 'Mark Pocta'; 'Michael
> Rochman'; 'Raveen Maan'; 'Ron Oechsler'; 'Tom Solberg'; 'Rich Hall'; 'Mark
> Baldwin'; 'Timothy J Hamilton'; 'pgg4@pge.com'
> Cc: 'Katie Elder'; How-Downing, Lindsey
> Subject: Comments on OFO Settlement
>
> CONFIDENTIAL AND PRIVILEGED COMMUNICATION SUBJECT TO CPUC RULE 51
>
>
>  As you recall, at the prehearing conference, Judge Biren directed
> the OFO settlement parties to provide her with additional information
> regarding the OFO settlement.  Friday, Nov.12, Patrick Golden and I had a
> follow-up conversation with Judge Biren to confirm the procedure by which
> she desires to receive the information.
>
>  As a result of the call, Patrick and I suggest that the OFO
> settlement parties file joint "Comments Supporting Settlement" on Nov 22,
> along with any other party which may file comments on the settlement.  Our
> comments would encompass the following:
>
> 1) The settlement is in the public interest as attested by an attached
> declaration.
>
> 2) The settlement does not constitute a change in the basic Gas Accord
> settlement; it merely refines implementation details on the Gas Accord.
> As a result, no hearings are necessary on the settlement.
>
> 3) Neither SB1602 nor 1421 impact immediate Commission approval of the
> settlement.
>
> 4) The settlement is intended to be a final, not an interim, settlement.
>
>  With respect to Judge Biren's request for declarations (which she
> reconfirmed despite agreeing that Rule 51 does not require declarations),
> Patrick and I discussed having the settling parties provide one
> declaration from PG&E outlining the reasons why the settlement is in the
> public interest, and having the PG&E declarant be authorized to state that
> the following parties authorize him to state that they support his
> declaration.
>
>  Judge Biren confirmed that any replies to our comments would be due
> along with all other reply comments on the settlement.
>
>  If you have any comments or suggestions on this approach, please let
> either Salle Yoo or me know ASAP.
>
>
> Lindsey How-Downing
> Davis Wright Tremaine LLP
> One Embarcadero, Suite 600
> San Francisco, California 94111
> Phone 415-276-6512
> Fax     415-276-6599
> Email  lindseyhowdowning@dwt.com

 - att1.htm