As an FYI, our DC office heard today that FERC may issue a Notice of Proposed Rulemaking (NOPR) potentially strengthening affiliate codes of conduct in the natural gas industry on June 25.  The range of outcomes could go from anywhere from simply rationalizing 497 (natural gas code of conduct) and 889 (electric code of conduct) through full divestiture (although this is highly unlikely).

If this happens, it is most directly the result of the on-going litigation at FERC surrounding El Paso Merchant's use of capacity into California.

As soon as we hear anything additional, we'll let you know.

Jim