Response to LADWP Complaint

At about the same time the National Association of Gas Consumers filed their
complaint calling for a nationwide benchmark price for natural gas sales, the
Los Angeles Department of Water and Power filed a petition for reimposition
of the price cap on short-term capacity release and pipeline capacity
transactions. LADWP's petition was basically the same as the request for
emergency relief filed by San Diego Gas & Electric in December, which FERC is
still considering. We have answered LADWP's petition incorporating our
comments in San Diego and have asked that the two proceedings be consolidated
since the issues are the same and parties have already expended a lot of time
and effort in providing data to FERC in San Diego.

We did not receive FERC's notice on the LADWP petition that was issued Monday
until yesterday, and responses are due today, so we did not have enough time
to circulate our attached filing for review and comments.