Re: MMS meeting sheduled for Friday afternoon Feb 9th.

The Mineral Leasing Act may be the statute that governs--at least I'm
familiar with it as the statute governing the MMS onshore oil and gas royalty
program. There are also statutes that cover hard rock mining rights and
surface (i.e., grazing) rights. I'm not sure which one is the basis for
Greg's theories. What you guys need is a real dirt lawyer. Don't we have
any ex-EOG lawyers around? There aren't any in ETS that I'm aware of that
know this stuff. As to the RFP process, I have even less of an idea. I hear
you on your instinct to give him the answer, but one of my goals is to hear
what MMS thinks its legal basis is for going after storage and forming my own
view of whether they are right or just blowing smoke. DF

Enron North America Corp.

From: Paul Bieniawski 02/01/2001 10:43 AM

To: Mark Whitt/NA/Enron@Enron
cc: Drew Fossum/ET&S/Enron@ENRON, Miguel Vasquez/HOU/ECT@ECT

Subject: Re: MMS meeting sheduled for Friday afternoon Feb 9th.

I am doing some research on statutory authority to try to understand where
the 12.5% comes from.

Drew,

Any thoughts on where I might go to find out more about the MMS RFP process
because , if we understand it, we may be able to find a loophole.

I figure if we tell Greg what the answer is, he may be willing to accept it
as opposed to us asking him to find the answer and relying on his
interpretation