After discussing with Lynn and Glen, we think that we would like to file comments in this proceeding concerning an issue we have had since this has been implemented on Nov 1.  In instances where SoCal happens to call their OFO in the Intraday 2 cycle, it can cause Transwestern to have Shipper imbalances because we do not have an opportunity to pass-along these reductions to our upstream parties.  We think we would like to file a letter that may mention our general support of the "direction" of SoCal's changes, but that we do have an issue that has developed since actual implementation that we are currently working on with them.  Lynn & I worked on this rough general description we thought could be incorporated into a brief letter.
	
		"If SoCal calls an OFO in the Intraday 2 Cycle, an allocation is passed to Transwestern through the confirmation process with SoCal.  Due to the timing of these OFO's, Transwestern is unable to confirm such reductions with Transwestern's upstream parties."

Lynn thinks if we are unable to resolve this issue with SoCal, TW could have high Shipper imbalance exposure.

 -----Original Message-----
From: 	Harris, Steven  
Sent:	Wednesday, November 14, 2001 9:50 AM
To:	Donoho, Lindy
Subject:	FW: SCG Advice 2837-A

Lindy , can you please take a look at this and let me know if we should file comments. Thanks. You might see if Glen has looked at it yet.

	Steve

 -----Original Message-----
From: 	"Dan Douglass" <douglass@energyattorney.com>@ENRON  
Sent:	Friday, November 09, 2001 5:02 PM
To:	Hass, Glen; Harris, Steven
Cc:	Gregg Klatt
Subject:	SCG Advice 2837-A


Glen and Steve:
 
The attached supplemental advice filing by SoCalGas replaces the  changes to Rule 30, Transportation of Customer-Owned Gas, proposed by AL2837.   The purpose of this filing is to  describe the new internal receipt point operating procedures that SoCalGas is  implementing, and to request Commission authorization to include the revised  operating procedures in Rule 30. SoCalGas says this step is being taken in  anticipation that it will be replaced with a system of firm tradable intrastate  transmission rights in Gas Industry Restructuring (GIR) proceeding, I.99-07-003.  
During  the GIR panel hearings, several parties requested that SoCalGas publish its  windowing criteria in tariffs to facilitate a better understanding of the method  used to allocate receipt point  capacity.  SoCalGas agreed to make  such a filing, and D.99-07-015 directed SoCalGas to file an advice letter adding  windowing information to its tariffs.  To comply with this directive, on August  6, 1999, SoCalGas filed AL2837, which has not been acted on by the Commission.  
Customer complaints about SoCalGas' windowing  procedures have convinced SoCalGas that it should replace its internal  windowing operating procedures with a system that is open to the maximum  operating capacity at each SoCalGas receipt point.  SoCalGas is making these internal  operating changes effective November 1, 2001.  SoCalGas held meetings with upstream  pipelines on October 17, and with interested customers and stakeholders on  October 18, regarding the upcoming changes.  They were invited to ask any questions in  the days leading up to the meetings. 
Comments and/or protests are due on November 21.  Have a good  weekend!
Dan
 
Law Offices of Daniel W. Douglass
5959 Topanga Canyon Blvd.  Suite  244
Woodland Hills, CA 91367
Tel:   (818) 596-2201
Fax:   (818) 346-6502douglass@energyattorney.com 
 
 - AL2837-A.PDF