Message-ID: <11656951.1075846345286.JavaMail.evans@thyme> Date: Sat, 29 Jul 2000 17:03:00 -0700 (PDT) From: james.steffes@enron.com To: steve.kean@enron.com, richard.shapiro@enron.com, joe.hartsoe@enron.com Subject: Follow-up on Larcamp Visit: Comparing Gas /Electric Positions Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: James D Steffes X-To: steve kean, richard shapiro, joe hartsoe X-cc: X-bcc: X-Folder: \Steven_Kean_Dec2000_1\Notes Folders\Ferc X-Origin: KEAN-S X-FileName: skean.nsf FYI. I'll keep all of you posted as we complete our analysis and respond to Larcamp's thoughts. Jim ---------------------- Forwarded by James D Steffes/HOU/EES on 07/30/2000 12:02 AM --------------------------- Shelley Corman@ENRON 07/27/2000 03:01 PM To: Stanley Horton/Corp/Enron@Enron, Bill Cordes/ET&S/Enron@ENRON, Rockford Meyer/FGT/Enron@ENRON, Mary Kay Miller/ET&S/Enron@ENRON, rkilmer@enron.com, Ray Neppl/NPNG/Enron@ENRON, Drew Fossum/ET&S/Enron@ENRON, Teb Lokey/FGT/Enron@ENRON, Julia White/ET&S/Enron@ENRON, Steven Harris/ET&S/Enron@ENRON, Susan Scott/ET&S/Enron@ENRON cc: James D Steffes/HOU/EES@EES, Christi L Nicolay/HOU/ECT@ECT Subject: Follow-up on Larcamp Visit: Comparing Gas /Electric Positions When Dan Larcamp recently visited he commented that pipelines need to take a look at differences between gas and electric positions and practices. In fact, his main concern about pipeline marketing affiliate practices relate to the fact that they differ from practices on the electric side. I am working with Jim Steffes and Christi Nicolay on a comparison of gas and electric practices in the following areas mentioned by Dan Larcamp. Here is a quick look at the areas that we are comparing: Contracting for transportation/transmission capacity. Pipelines currently have a form of service agreement in their tariffs, but they also enter into non-conforming agreements and discount agreements with shippers. In contrast, transmission customers enter a two-page standardized blanket transmission agreement. Then they reserve specific quantities and points on-line via OASIS. This is probably the area that we'll have the most difficult time arguing why we are different than the electric side. Negotiating discounts. Customers may call or fax pipeline staff to negotiate discounts, although sometimes a pipeline may post a generally available discount on the website. On the electric side, discounts are rarely granted, but if discounts are granted it is handled through OASIS. Functionality of OASIS vs. pipeline websites. Its true that the OASIS system facilitates the reservation of transmission space (i.e. contracting) and discounts, but it doesn't accommodate nominations, invoices, and index of customers or many of the other features available on pipeline web sites. Marketing affiliate rules. I plan to lay out a side by side comparison of Sec. 37 (electric rules) and 161 (gas marketing affiliate rules). One difference, the posting of organization charts, will be gone after September, as pipelines will add this information to the web site. Content of Form 1 vs. Form 2. Dan Larcamp mentioned that he feels like electric form 1s have more useful market data. I'm not sure we're comparing apples and apples, as the electrics are still integrated utilities and thus the form 1 includes sales data. But, we'll put together a comparison nonetheless. Hopefully, the detailed comparison can be completed in the next month. Also, FYI Enron Government Affairs is currently working on their comments to the latest OASIS rulemaking and plan to use the comparison work to suggest best pipeline website practices that could be a model for OASIS. I'll keep you posted.