options draft

The attached draft reflects revisions made pursuant to our discussions with
FERC staff. You will be receiving a hard copy of the tariff sheets
separately.

Please make sure you read the "Waivers" section towards the end of the
document as it contains some additional requests for waivers.

Also, there seems to be some confusion over whether we are going to post all
options, not just Shipper call options. My previous drafts have provided for
posting of Shipper call options only. All other types of options will be
generally available, on a nondiscriminatory basis, through our tariff. My
thinking was that it is commercially impracticable to post the specifics of
all types of options, and it's not necessary since options will be noted on
our transaction reports required by Order 637. Let me know what you think.

Let me know your comments as soon as possible. I understand that the
Commercial Group told Stan Horton this would be filed this week and Shelley
reported at staff meeting on Monday that it would be filed this week or next
week. As soon as I get everyone's comments we can get this finalized.

Thank you.