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Enron Mail |
Now that two settlement proposals and a motion to extend time have been
filed, there is no telling what the CPUC will do. My recommendation is that we play it safe and assume we will need to file testimony on April 17. To that end, it's time to review some basics. In its July 8, 1999 decision, the Commission stated: "We see reason to pursue a change in protocol for receiving gas at Hector Road, even in the short term. If there are burdens that would unfairly fall upon Transwestern customers is a window was established at Hector Road, we want to hear about it in the next phase of the proceeding. In addition, we seek specific proposals as to how such an arrangement should be defined." Accordingly, the testimony we file should explain: 1. The unfair harm that could potentially befall TW customers if Hector Road were established as a formal receipt point 2. Our proposal for making Hector a formal receipt point by establishing primary and secondary receipt points 3. Why our proposal is fair and consistent with Commission policy (here we might want to draw analogies to the interstate system and explain why that works) I will also have an opportunity to make legal and policy arguments in a brief after testimony has been filed. Let's discuss how best to go about drafting the testimony. I think the best thing to do would be to outline the testimony, then decide who is going to say what. I'm available after about 2:00 today.
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