Team,

I reviewed the Socal PD . Here are a couple of rough thoughts for possible
TW comments in favor of the CSA and rejecting the PD's adoption of the IS.

1) The PD adoption of the IS modified windowing procedure falls
substantially short of the objectives outlined by the Commission order(s)
etc. The CSA's adoption of firm Socal receipt point rights is the only means
to give both Socal endusers and their suppliers the "certainty" they have
long sought. While, the IS as modified in the PD may appear to be an
improvement in the allocation of receipt points on the Socal system, it is
only an improvement upon a fundamentally flawed system. A system dependent
upon a "daily" determination of receipt point access volumes and completely
dependent upon upstream priority systems without consideration of Socal
customers needs. Indeed, this Commission is on record about adverse impacts
on California customers resulting from chaotic upstream transportation
rules.(need to be careful about wording)
The CSA gives incumbent Socal endusers preference to Socal's receipt points
under the open season rules, while the PD continues the status quo.   etc,
etc Ref. p.128 pt 10

2) If we lose the battle, lets try to reopen the deal sooner. p.132 pt.37
The PD calls for waiting a 2 year period before a Market Assessment would be
published. Based upon the MA the Commission could institute another OII. The
argument could be made that this waiting period is simply to long given the
speed at which the industry does move. Therefore, TW could recommend that
these Market Assessments be made annually or not at all if the CSA were
adopted etc.

These items maybe of no use , if the bigger picture and battle for the CSA
does not have Socal and other party support. Have a great day! Mark, IGS