Richard,
Attached, please find my analysis of the PX's position as stated in their 
November 11 and December 21 letters.  Based on my discussions with Greg 
Whalley last week, he was of the opinion that we should send a short letter 
with only a few points refuting the PX's position.  The attached letter goes 
into some detail refuting the PX's allegations.  We should talk on Monday or 
Tuesday to discuss the content of the final letter.  Please note, I have not 
included any of the recent FERC-related developments in my analysis.  Based 
on discussions with Ron Carrol last week it appears that we have another 
avenue to pursue.

Tim Belden