Ted,

Question 15 of the annual NYMEX hedge exemptions asks us to describe in 
detail:  "the system of internal controls administered in the supervision of 
the applican't risk management programs, i.e., describe the risk assessment 
policies and procedures in place for evaluation and supervision of risk 
management programs, including "stress-testing" for extraordinary price 
volatility, and state frequency supervision is conducted."

Attached is the response we have given the NYMEX in prior years.  Are there 
any changes in our procedures/control that would necessiate a change in that 
language?