CAPX Investigation

Richard,
Attached, please find my analysis of the PX's position as stated in their
November 11 and December 21 letters. Based on my discussions with Greg
Whalley last week, he was of the opinion that we should send a short letter
with only a few points refuting the PX's position. The attached letter goes
into some detail refuting the PX's allegations. We should talk on Monday or
Tuesday to discuss the content of the final letter. Please note, I have not
included any of the recent FERC-related developments in my analysis. Based
on discussions with Ron Carrol last week it appears that we have another
avenue to pursue.

Tim Belden