Message-ID: <4479113.1075840897670.JavaMail.evans@thyme> Date: Tue, 21 Aug 2001 16:56:55 -0700 (PDT) From: d..steffes@enron.com To: john.lavorato@enron.com, louise.kitchen@enron.com Subject: FERC Reporting Requirements for California Natural Gas Sales Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Steffes, James D. X-To: Lavorato, John , Kitchen, Louise X-cc: X-bcc: X-Folder: \ExMerge - Kitchen, Louise\'Americas\Regulatory X-Origin: KITCHEN-L X-FileName: louise kitchen 2-7-02.pst John & Louise -- I wanted to make sure that you were aware that FERC has ordered natural gas sellers to provide monthly reporting for transactions relating to California. We are, of course, seeking for FERC to modify its decision. Given the politics surrounding California energy markets, it is unlikely that FERC remove in whole the reporting obligation. Govt Affairs has talked with the West gas team about this new obligation and how we respond. If you have any questions, please call. Jim -----Original Message----- From: Cantrell, Rebecca W. Sent: Monday, August 20, 2001 11:45 AM To: Comnes, Alan; Tycholiz, Barry; Nicolay, Christi L.; Perrino, Dave; Black, Don; Fulton, Donna; Steffes, James D.; Dasovich, Jeff; Thome, Jennifer; Kaufman, Paul; Allen, Phillip K.; Alvarez, Ray; Frank, Robert; Miller, Stephanie; Walton, Steve; Mara, Susan; McMichael Jr., Ed; Tholt, Jane M.; Hewitt, Jess; Sullivan, Patti; Gay, Randall L.; Superty, Robert; Ponce, Roger; Calcagno, Suzanne; Kuykendall, Tori; South, Steven P.; Shireman, Kristann; Smith, George F.; Ermis, Frank; Sanders, Richard B.; Sharp, Greg; Gahn, Scott; Courtney, Mark; Lindberg, Susan; Ruffer, Mary Lynne; Pittenger, Cathy; Greif, Donna; Shapiro, Richard Cc: Lawner, Leslie; Pharms, Melinda Subject: Please Reply by Wednesday, 8/22 -- Draft Rehearing Request -- FERC Reporting Requirements for California Sales Attached is a draft of our rehearing request on the order FERC issued in RM01-9 requiring sellers of gas into California to file information on their sales, transport, and purchases. The rehearing request restates our arguments in response to the NOPR that (1) permanent, formal reporting requirements are not appropriate to address a temporary problem and are beyond the scope of the Commission's powers under the Natural Gas Act and (2) the commission significantly underestimated the burden of the reporting requirements as well as the responding parties' ability to comply. We also request that the reports, if they must be submitted, be due 45 days after the end of the month instead of the required 30 days. Please provide any comments or suggestions you may have on this draft to either myself (713-853-5840) or Leslie (505-623-6778) by COB Wednesday (8/22). Thanks.