From: nancy.bagot@enron.com
To: bambi.heckerman@enron.com, dari.dornan@enron.com, dorothy.mccoppin@enron.com, drew.fossum@enron.com, frazier.king@enron.com, glen.hass@enron.com, janet.butler@enron.com, janet.place@enron.com, maria.pavlou@enron.com, mary.miller@enron.com, michele.winckowski@enron.com, ray.neppl@enron.com, robert.kilmer@enron.com, shelley.corman@enron.com, teb.lokey@enron.com
Date: 2000-11-29 12:09:00+00:00
Subject: Order 637 compliance update

As we're beginning to see the second wave of Order 637 proceeding technical 
conferences being scheduled, here is a brief update on the proposed 
timetables for the first few dockets.  As December kicks off, we are in a 
settlement mode in all the cases, with most pipelines in informal discussions 
with customers/parties to work towards consensus settlements that can be 
filed with the Commission.  

** Note that Koch, adamant that segmentation is not operationally feasible on 
its system, has circulated a settlement proposal on segmentation.  See below.


ANR, RP00-332: 

 After three technical conferences at FERC, ANR is committed to developing a 
total consensus document.  ANR is circulating their latest revisions to 
customers by December 7th, and customers are meeting without the Commission 
or the pipeline to discuss ANR's proposal on December 15th.  A follow-up 
technical conference at FERC is scheduled for January 11, 2001.


Dominion, RP00-344:

Dominion has held at least five meetings with customers to work out a 
settlement in this case.  A technical conference, originally scheduled for 
late October, has been rescheduled with FERC Staff for December 14th.  This 
should be a meeting on a settlement proposal.


Koch, RP00-340:

Koch has circulated revisions to its Order 637 filing, including a settlement 
proposal for segmentation.  There will be a conference call among Koch and 
its customers on December 5th to get comments on the tariff revisions as 
discussed at the October 25th technical conference and the new segmentation 
proposal.  After that call, a follow-up technical conference at FERC should 
be scheduled for sometime in January.

[The segmentation proposal would allow customers broader supplemental rights 
in the zones in which their primary receipt and primary delivery points are 
located.  When points are located in different zones, the customer would be 
entitled to utilize its full MDQ in each zone (in essence doubling their 
MDQ).   It's critical to Koch's offer that all segmented transactions will be 
scheduled on a supplemental basis, as this is the only protection for the 
operational integrity of its system and primary firm services of other 
customers.  The right to segmentation can be waived by customers and it will 
be available on a prospective basis only for new or renegotiated contracts.  
Koch is also proposing a "segmentation fee" to be assessed either to those 
customers utilizing segmentation or by all Koch customers (undecided in the 
proposal).  This fee will be used to recover all costs associated with 
developing the segmentation program and necessary computer system.]


Colorado Interstate, RP00-325:

CIG will circulate revisions by December 1st to its compliance filing as 
discussed at the pipeline's second technical conference on October 26th.  
Parties will send comments to CIG by December 10th.  The schedule, from that 
point, will go into January.  CIG may follow Dominion's lead and schedule 
settlement meetings with parties before meeting with Staff again.


Tennessee, RP00-477:

Tennessee is circulating revisions based on discussions at the November 14th 
technical conference by December 8th.  Parties will meet within two weeks of 
that date to discuss the revisions (either separately or at a FERC technical 
conference).


Kinder Morgan, RP00-343:

Kinder Morgan plans to circulate a revised 637 package by December 15th, with 
a conference call scheduled for January 4th to get feedback from customers on 
the revisions.  The pipeline believes there may not be a need for a second 
technical conference and hopes to file a settlement and implementation plan 
by the end of January.