Final Draft: GPG Order 637 Rehearing Comments

See especially pages 5 & 6 of the attached doc., which include the argument
that existing ROFR should not be grandfathered. Please send any comments you
have to me. Thanks!!
---------------------- Forwarded by Susan Scott/ET&S/Enron on 03/10/2000
09:09 AM ---------------------------

Shelley Corman
03/09/2000 06:20 PM
To: Caroline Barnes/FGT/Enron@ENRON, Martha Benner/ET&S/Enron@ENRON, Lynn
Blair/ET&S/Enron@ENRON, Sharon Brown/ET&S/Enron@ENRON, Jack
Boatman/FGT/Enron@ENRON, Janet Butler/ET&S/Enron@ENRON, Deb
Cappiello/ET&S/Enron@ENRON, Alma Carrillo/ET&S/Enron@ENRON, Janet
Cones/FGT/Enron@ENRON, Bill Cordes/ET&S/Enron@ENRON, Shelley
Corman/ET&S/Enron@ENRON, Larry DeRoin/NPNG/Enron@ENRON, Rick
Dietz/ET&S/Enron@ENRON, Dari Dornan/ET&S/Enron@ENRON, John
Dushinske/ET&S/Enron@ENRON, Sharon Farrell/FGT/Enron@ENRON, Drew
Fossum/ET&S/Enron@ENRON, Donna Fulton/Corp/Enron@ENRON, Lou
Geiler/ET&S/Enron@ENRON, John Goodpasture/OTS/Enron@ENRON, Bob M
Hall/FGT/Enron@ENRON, Steven Harris/ET&S/Enron@ENRON, Glen
Hass/ET&S/Enron@ENRON, Rod Hayslett/FGT/Enron@ENRON, Bambi
Heckerman/NPNG/Enron@ENRON, Theresa Hess/ET&S/Enron, Staci
Holtzman/FGT/Enron@ENRON, Tamara Hopkins/ET&S/Enron@ENRON, Stanley
Horton/Corp/Enron@Enron, Steven January/ET&S/Enron@ENRON, Anne
Jolibois/FGT/Enron@ENRON, Steven J Kean/HOU/EES@EES, Robert
Kilmer/FGT/Enron@ENRON, Frazier King/FGT/Enron@ENRON, Steve
Kirk/ET&S/Enron@ENRON, Tim Kissner/ET&S/Enron@ENRON, Laura
Lantefield/ET&S/Enron@ENRON, Terry Lehn/FGT/Enron@Enron, Teb
Lokey/FGT/Enron@ENRON, Dorothy McCoppin/FGT/Enron@ENRON, Mike
McGowan/ET&S/Enron@ENRON, Kent Miller/ET&S/Enron@ENRON, Mary Kay
Miller/ET&S/Enron@ENRON, Michael Moran/ET&S/Enron@ENRON, Sheila
Nacey/ET&S/Enron@ENRON, Ray Neppl/NPNG/Enron@ENRON, Virginia
O'Neill/ET&S/Enron@Enron, Zelda Paschal/FGT/Enron@ENRON, Maria
Pavlou/ET&S/Enron@ENRON, Keith Petersen/ET&S/Enron@ENRON, Peggy
Phillips/FGT/Enron@ENRON, Janet Place/NPNG/Enron@ENRON, Tony
Pryor/ET&S/Enron@ENRON, Pilar Ramirez/ET&S/Enron@ENRON, Jenny
Rub/GPGFIN/Enron@Enron, Patti Rumler/ET&S/Enron@ENRON, Cynthia
Sandherr/Corp/Enron@ENRON, Dave Schafer/ET&S/Enron@ENRON, Susan
Scott/ET&S/Enron@ENRON, Emily Sellers/ET&S/Enron@ENRON, Sharon
Solon/ET&S/Enron@ENRON, Cindy Stark/Corp/Enron@Enron, Rockey
Storie/ET&S/Enron@ENRON, Dee Svatos/NPNG/Enron@ENRON, Gina
Taylor/HOU/EES@EES, Stephen Veatch/FGT/Enron@ENRON, Linda
Wehring/ET&S/Enron@ENRON, Julia White/ET&S/Enron@ENRON, Ricki
Winters/ET&S/Enron@Enron
cc:

Subject: Final Draft: GPG Order 637 Rehearing Comments

Thank you for all the comments. Here is a last draft of our GPG rehearing
comments. Please forward any additional comments no later than noon, Friday
March 10.

Significant changes from the last draft are as follows:
1. We are asking the Commission to eliminate the peak/off-peak cost &
revenue study, rather than clarify that the study applies only to excess
revenues. (p.2)
2. References to the TW Global Settlement have been removed. The reference to
existing settlements is more generic and included only to preserve our
rights. (p.4)
3. A new argument on ROFR has been added. We are asking the Commission to
immediately apply the new policy that ROFR does not apply to discount rate
agreements. (p.5-6)
4.Several reporting arguments have been deleted -- masking shipper names,
clarifying that only senior employee names have to be posted and clarifying
the Sept. 1 reporting date. With respect to these last two arguments, we
have decided that we can interpret it our way without further clarification.
5.New clarification concerning the date for which the lifting of the price
caps on capacity release is to be implemented.