Christine -- Here's a brief answer to your questions.

With regard to segmentation, Order 637 is completely silent with regard to 
rates to be charged for segmented capacity, so we would have considerable 
leeway here.  The order is also silent with respect to the effective 
restriction of segmented capacity by making discounts inapplicable to certain 
alternate (or primary) points.  Hopefully TW will be able to avoid the 
segmentation issue altogether by invoking the Global Settlement, as we plan 
to do in our rehearing request and compliance filing.  (Our Global Settlement 
argument is that we should be able to rely on tariff provisions, including 
our current restriction on changing primary points, that were implemented to 
mitigate the effects of turnback on TW).

On hourly service, I believe that we could put an hourly service into place 
on TW without  running afoul of the Peak and Off-Peak Rates (i.e., seasonal 
rates) provisions of the order.  In other words, I think the Commission would 
see them as two separate kinds of service.

As for how to communicate with our customers, I believe Regulatory has 
offered to have a meeting with TW customers in early April to make a 
presentation on Order 637 and provide a forum for discussion.  I realize the 
order becomes effective March 27; however, compliance filings are not due 
until May 1, and some requirements do not even become effective until 
September 1.  Before the beginning of April, the GPG pipelines will simply 
not have their positions fully formed enough to make a very well-organized 
presentation to persons outside the company.  The meeting is still in the 
planning stages and I will fill you in on details as they are available.  In 
the meantime, if your customers have questions, I'll be happy to help answer 
them.




Christine Stokes
03/02/2000 10:32 AM
To: Susan Scott/ET&S/Enron@ENRON
cc: Steven Harris/ET&S/Enron@ENRON, Kevin Hyatt/ET&S/Enron@Enron, Jeffery 
Fawcett/ET&S/Enron@ENRON, Lorraine Lindberg, Lindy Donoho/ET&S/Enron@ENRON, 
TK Lohman/ET&S/Enron@ENRON 

Subject: 637 Summary Items

Thanks Susan for the 637 summary.  Here are a couple of items that I need 
additional clarification on:

1)  Segmentation -  You summarized " Pipelines must allow segmentation to the 
extend operationally feasible and cannot hide behind current tariff 
provisions ...  "    Does this mean, for example, an Ignacio to California 
contract (i.e. 40,000 Dth/d at a $.20 total path rate) could be segmented by 
the shipper such that on any single day they could nom 40 MM/d from Ignacio 
to El Paso Blanco as well as 40 MM/d from Blanco to California?  If they 
could, would the $.20 apply to each segment such that we could bill them 80 
MM/d ($.20) for the time period that they flowed on a segmented basis or 
would they only pay the $.20 applied to the contract's 40 MM/d MDQ?      
Another scenario would be if the shipper is allowed to flow based on this 
segmented basis, but unless the discount letter providing the $.20 
specifically provides for a negotiated segmented transport rate the shipper 
will be billed MAX rate for some or both of the segmentated paths (?) if 
these paths are not already provided as "alternate" receipt or delivery 
paths?  

2)  Peak & OFF-Peak Rates. - You summarized " The policy does not apply to 
long-term shippers with contracts for 12 or more consective months of 
service."   

 TW will eventually file for hourly rates, however, the parties most 
interested in this service will be marketers serving a generation station, or 
the generation station's own gas supply manager/purchaser.  Most likely these 
contracts WILL BE of a longer term nature than month to month or even 
seasonal.  I need to reconcile your summarized comment to what we will expect 
from the marketplace.

Thanks for your feedback.  Since 637 is effective March 27th, I am eager to 
be able to speak intelligently to my customers regarding some of these more 
critical issues.  Thanks.