FYI, for the RCR on this.
----- Forwarded by Leslie Lawner/NA/Enron on 01/24/2001 08:56 AM -----

	MBD <MDay@GMSSR.com>
	01/23/2001 04:53 PM
		 
		 To: "'Leslie.Lawner@enron.com'" <Leslie.Lawner@enron.com>
		 cc: 
		 Subject: RE: Response to ORA/TURN petition

My estimate is $2500 or less for drafting the pleading, $1000 or less for
any reply and for monitoring the remainder of the pleadings.  If there is a
hearing or other proceeding before the Commission decides, we would have to
increase the estimate if Enron wanted to participate in those proceedings.

Tell me if you require more. Mike Day

 
-----Original Message-----
From: Leslie.Lawner@enron.com [mailto:Leslie.Lawner@enron.com]
Sent: Tuesday, January 23, 2001 1:21 PM
To: mday@gmssr.com
Cc: Phillip.K.Allen@enron.com; James.D.Steffes@enron.com;
Harry.Kingerski@enron.com; Jeff.Dasovich@enron.com;
Rebecca.W.Cantrell@enron.com; Paul.Kaufman@enron.com;
Frank.Ermis@enron.com; jshirley@enron.com; rponce@enron.com;
dblack@enron.com; Robert.Neustaedter@enron.com
Subject: Response to ORA/TURN petition


Mike - Here is the situation.  Between ENA and EES, we sell gas to core and
non-core customers, and also have gas in storage as well as in the park and
lend service.  I think we can be sympathetic to the ORA argument that the
diversion tariff penalties did not anticipate OFOs and EFOs in situations
such as we face here (shortages due to credit problems rather than lack of
supply).  Assessing extreme penalties, as the OFO/EFOs would do, on users
who are not perfectly imbalance under this situation certainly seems
unfair.  However, I think we should argue that limiting the payments to
shippers/customers whose gas is diverted to serve core customers to a
market index may not fully compensate for the diversion.  The pay back
specifically does not include interstate pipeline charges, and there may be
other costs as well to the marketer/customer who had supplies taken away.

I need an estimate of the cost to make this filing and follow it up for the
RCR process, and I would also like any feedback anyone has on what our
position should be in this matter.  The response is due Friday.