Final Draft: GPG Order 637 Rehearing Comments ,
 See especially pages 5 & 6 of the attached doc., which include the argument 
that existing ROFR should not be grandfathered.  Please send any comments you 
have to me.  Thanks!!
---------------------- Forwarded by Susan Scott/ET&S/Enron on 03/10/2000 
09:09 AM ---------------------------


Shelley Corman
03/09/2000 06:20 PM
To: Caroline Barnes/FGT/Enron@ENRON, Martha Benner/ET&S/Enron@ENRON, Lynn 
Blair/ET&S/Enron@ENRON, Sharon Brown/ET&S/Enron@ENRON, Jack 
Boatman/FGT/Enron@ENRON, Janet Butler/ET&S/Enron@ENRON, Deb 
Cappiello/ET&S/Enron@ENRON, Alma Carrillo/ET&S/Enron@ENRON, Janet 
Cones/FGT/Enron@ENRON, Bill Cordes/ET&S/Enron@ENRON, Shelley 
Corman/ET&S/Enron@ENRON, Larry DeRoin/NPNG/Enron@ENRON, Rick 
Dietz/ET&S/Enron@ENRON, Dari Dornan/ET&S/Enron@ENRON, John 
Dushinske/ET&S/Enron@ENRON, Sharon Farrell/FGT/Enron@ENRON, Drew 
Fossum/ET&S/Enron@ENRON, Donna Fulton/Corp/Enron@ENRON, Lou 
Geiler/ET&S/Enron@ENRON, John Goodpasture/OTS/Enron@ENRON, Bob M 
Hall/FGT/Enron@ENRON, Steven Harris/ET&S/Enron@ENRON, Glen 
Hass/ET&S/Enron@ENRON, Rod Hayslett/FGT/Enron@ENRON, Bambi 
Heckerman/NPNG/Enron@ENRON, Theresa Hess/ET&S/Enron, Staci 
Holtzman/FGT/Enron@ENRON, Tamara Hopkins/ET&S/Enron@ENRON, Stanley 
Horton/Corp/Enron@Enron, Steven January/ET&S/Enron@ENRON, Anne 
Jolibois/FGT/Enron@ENRON, Steven J Kean/HOU/EES@EES, Robert 
Kilmer/FGT/Enron@ENRON, Frazier King/FGT/Enron@ENRON, Steve 
Kirk/ET&S/Enron@ENRON, Tim Kissner/ET&S/Enron@ENRON, Laura 
Lantefield/ET&S/Enron@ENRON, Terry Lehn/FGT/Enron@Enron, Teb 
Lokey/FGT/Enron@ENRON, Dorothy McCoppin/FGT/Enron@ENRON, Mike 
McGowan/ET&S/Enron@ENRON, Kent Miller/ET&S/Enron@ENRON, Mary Kay 
Miller/ET&S/Enron@ENRON, Michael Moran/ET&S/Enron@ENRON, Sheila 
Nacey/ET&S/Enron@ENRON, Ray Neppl/NPNG/Enron@ENRON, Virginia 
O'Neill/ET&S/Enron@Enron, Zelda Paschal/FGT/Enron@ENRON, Maria 
Pavlou/ET&S/Enron@ENRON, Keith Petersen/ET&S/Enron@ENRON, Peggy 
Phillips/FGT/Enron@ENRON, Janet Place/NPNG/Enron@ENRON, Tony 
Pryor/ET&S/Enron@ENRON, Pilar Ramirez/ET&S/Enron@ENRON, Jenny 
Rub/GPGFIN/Enron@Enron, Patti Rumler/ET&S/Enron@ENRON, Cynthia 
Sandherr/Corp/Enron@ENRON, Dave Schafer/ET&S/Enron@ENRON, Susan 
Scott/ET&S/Enron@ENRON, Emily Sellers/ET&S/Enron@ENRON, Sharon 
Solon/ET&S/Enron@ENRON, Cindy Stark/Corp/Enron@Enron, Rockey 
Storie/ET&S/Enron@ENRON, Dee Svatos/NPNG/Enron@ENRON, Gina 
Taylor/HOU/EES@EES, Stephen Veatch/FGT/Enron@ENRON, Linda 
Wehring/ET&S/Enron@ENRON, Julia White/ET&S/Enron@ENRON, Ricki 
Winters/ET&S/Enron@Enron
cc:  

Subject: Final Draft: GPG Order 637 Rehearing Comments

Thank you for all the comments.  Here is a last draft of our GPG rehearing 
comments.  Please forward any additional comments no later than noon, Friday 
March 10.

Significant changes from the last draft are as follows:
1.  We are asking the Commission to eliminate the peak/off-peak cost & 
revenue study, rather than clarify that the study applies only to excess 
revenues. (p.2)
2. References to the TW Global Settlement have been removed. The reference to 
existing settlements is more generic and included only to preserve our 
rights. (p.4)
3. A new argument on ROFR has been added.  We are asking the Commission to 
immediately apply the new policy that ROFR does not apply to discount rate 
agreements. (p.5-6)
4.Several reporting arguments have been deleted -- masking shipper names, 
clarifying that only senior employee names have to be posted and clarifying 
the Sept. 1 reporting date.  With respect to these last two arguments, we 
have decided that we can interpret it our way without further clarification.
5.New clarification concerning the date for which the lifting of the price 
caps on capacity release is to be implemented.
lindy.donoho@enron.com, jeffery.fawcett@enron.com, 