Message-ID: <3072953.1075846659651.JavaMail.evans@thyme>
Date: Tue, 4 Apr 2000 03:55:00 -0700 (PDT)
From: susan.scott@enron.com
To: jeffery.fawcett@enron.com, mbaldwin@igservice.com
Subject: GIR testimony
Mime-Version: 1.0
Content-Type: text/plain; charset=us-ascii
Content-Transfer-Encoding: 7bit
X-From: Susan Scott
X-To: Jeffery Fawcett, mbaldwin@igservice.com
X-cc: 
X-bcc: 
X-Folder: \Susan_Scott_Dec2000_June2001_1\Notes Folders\All documents
X-Origin: SCOTT-S
X-FileName: sscott3.nsf

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.