MEMORANDUM

TO: Regulatory Affairs Committee
       Gas Issues Working Group

FROM: Jim Steffes, Regulatory Affairs Committee Chair
            John Orr, Gas Issues Working Group Chair
            Julie Simon, Vice President of Policy
            Jack Cashin, Senior Manager of Policy

DATE: June 12, 2001

RE: EPSA Draft Comments on Commission's Proposed
      Reporting Requirement on Natural Gas Sales to California
      Market
         ?Comments  to EPSA  by Friday, June 15th, 12:00 p.m.
          (EST)
         ?Filing Due June 18th

Attached are draft EPSA comments in response to the Commission's proposed 
requirements on natural gas sales to the California market.  The Commission 
is proposing that market participants (including pipelines and LDCs) submit 
quarterly reports on price and volume data on physical transactions.   EPSA's 
comments focus on four key issues:

   ?The reporting requirements represent an unnecessary burden;

   ?The information requested has proprietary and confidential aspects;

   ?Increased reporting requirements will not adequately address gas
    infrastructure needs in California; and

   ?If reporting requirements are imposed, a sunset date should provide a
    definite end to the filing obligation.

As discussed on the Gas Issues Working Group call on June 7th, members asked 
that EPSA file these comments.

Comments are due at FERC on Monday, June 18th.  In order to ensure we file on 
time, please forward any comments by noon on Friday, June 15th to Jack Cashin 
at 202-628-8200 or jcashin@epsa.org.

Attachment


 - CA NG Reporting.doc