Message-ID: <18910446.1075846666151.JavaMail.evans@thyme> Date: Thu, 15 Jun 2000 10:53:00 -0700 (PDT) From: susan.scott@enron.com To: mday@gmssr.com Subject: RE: Late-Filed Exhibit Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Susan Scott X-To: MBD X-cc: X-bcc: X-Folder: \Susan_Scott_Dec2000_June2001_1\Notes Folders\All documents X-Origin: SCOTT-S X-FileName: sscott3.nsf Mike -- Thanks for the input...we stewed over this for a while but decided to respond (as briefly as possible) rather than give Norm a chance to whine to the judge that we were being uncooperative in this somewhat unusual exhibit drafting process. Jeff's answer is consistent with what will appear in the exhibit (and from what one can find out about TW in numerous of our FERC filings, for that matter). If Norm tries somehow to make Jeff's response part of the record you can bet I will object...if it's not on the record already, or on the face of this one late-filed exhibit, it should not be allowed into the record. Apparently Norm has also called Rich Hall with annoying questions. I don't plan to respond if he contacts us with any follow-up, but will let you know if he does. SS MBD on 06/15/2000 05:39:54 PM To: "'Susan.Scott@enron.com'" cc: Subject: RE: Late-Filed Exhibit Susan: Good response. Be advised that Norm is a little out of order asking discovery questions like this after the record is closed. You are not obligated to respond to him under these circumstances. He is still trying to buttress his apparent belief that the EPNG and TW capacity to the California border is completely fungible and can be delivered to either SoCal or PG&E without any limitations. Please let me know if he tries this again. Thanks, Mike -----Original Message----- From: Susan.Scott@enron.com [mailto:Susan.Scott@enron.com] Sent: Thursday, June 15, 2000 2:17 PM To: Norman A. Pedersen Cc: 'Pocta, Robert M.'; Cherry, Brian - TPBKC; 'AlexanMS@sce.com'; 'paulamirault@aec.ca'; 'david.bayless@utility.com'; 'Tomb@crossborderenergy.com'; 'Burkee@cts.com'; 'Craigc@calpine.com'; 'Rick.Counihan@greenmountain.com'; 'Jdasovic@enron.com'; 'Mday@gmssr.com'; 'bdingwall@unitedgas.com'; 'Douglass@arterhadden.com'; 'eke@aelaw.com'; 'Jfawcet@enron.com'; 'rfoss@coral-energy.com'; 'Gileau, Patrick L.'; 'johnj@bcjlaw.com'; 'Johnson_Pamela@lacoe.edu'; 'karpjos@sf.whitecase.com'; 'jleslie@luce.com'; 'kmccrea@sablaw.com'; 'jmpa@dynegy.com'; 'porterdk@sce.com'; 'RochmanM@cubjpa.org'; 'RochmanM@spurr.org'; Betonte, Robert - TP2RSB; Brill, Thomas R.; Follett, B. David - TPDBF; Harrigan, James P. - TP1JPH; Hay, James E.; Lorenz, Lad - TPLPL; McVay, Nancy W - TPNWM; Morrow, Rick - TP3RMM; Purves, Ralph A.; Sakarias, Wayne P.; Schavrien, Lee; Sullivan, Glen J.; Surak, Thomas M. - TP1TMS; Teeter, James S.; Van Lierop, Jan - TP2JXV; Watson, Steven - TP2SAW; Wright, Gillian - TP1GXW; Barker, David - TPDTB; 'How-Downing, Lindsey'; 'Jun, Christine'; 'Gileau, Patrick L.'; 'Khoury, Dexter'; 'ack@aelaw.com'; Nelson, Eric B. - TPEBN; Suwara, J.- TPJUS; Wright, Gillian - TP1GXW; Reed, William; 'Paul, Joe'; 'Hawiger, Marcel'; 'Fawcett, Jeff'; 'O'Neill, Ed'; 'Power, Pat'; 'Ramirez, Jaime'; 'Black, Larry'; Fair, Pam; 'Hall, Rich'; 'Eisenman, Eric'; 'Stoner, Ron'; 'McConn, Kathy' Subject: Late-Filed Exhibit In response to your inquiry, Transwestern would first like to clear up the terminology being used here. As you know, currently SoCalGas doesn't assign "primary rights" to deliveries off of any interconnecting pipeline. The establishment of tradeable rights for intrastate capacity is among the issues currently under consideration in the GIR proceeding. However, if what you are asking about is what has been the historical or otherwise available receipt capacity for Transwestern deliveries at North Needles, then let me offer the following. Transwestern has always operated on the premise that SoCalGas could physically accept up to a maximum of 750 MMcf/d at its North Needles receipt point. Consequently, Transwestern has sold firm transportation to its interstate customers for west flow deliveries to North Needles not to exceed the 750 MMcf/d limitation. Our west flow mainline capacity is 1.09 Bcf/d. "Norman A. Pedersen" on 06/14/2000 08:12:05 PM To: Susan.Scott@enron.com cc: "ceyap" Subject: Re: Late-Filed Exhibit _______________________________________________________________ This message and any attachments are intended for the individual or entity named above. If you are not the intended recipient, please do not read, copy, use or disclose this communication to others; also please notify the sender by replying to this message, and then delete it from your system. Thank you. _______________________________________________________________ To: Jeff Fawcett: Do Transwestern shippers to Transwestern's North Needles delivery point have 1090 MMcfd of primary rights into ScCalGas, 750 of primary rights. or some other number?