TW

In the last several weeks several areas have come up where the TW commercial
team could, in my opinion, use some clear written guidance on gray areas
under the tariff ought to be interpreted. Here is my list. Please add items
if I've missed any.

1. When can TW "selectively market" available capacity? I.e., if capacity
is on the board as available, and no one has bought it, are there any limits
on calling up a customer, or a group of customers, and pitching a deal? I
think we have a lot of discretion here--after all, using the telephone to
talk to one customer is always "selective" since there's only one guy on the
phone, not all our customers. Also, can we deliberately leave a customer off
the list of "the usual suspects" we call to pitch a special deal like an
index to index deal or a discount? I've asked Lee to pull together a quick
analysis of this issue.

2. If we get multiple bids for a chunk of capacity outside of the open
season context, how do we allocate it? This is the situation we got into a
couple of weeks ago on the '02 and '03 space. Are we always required to use
a lottery? Do we need to modify the tariff to use pro rata, or can we use
pro rata simply by notifying the customers in advance?

3. What approval process applies to max rate contracts and negotiated rate
contracts? The ET&S discount approval procedure still applies to TW
discounted deals (even there is no ET&S anymore). I think all neg. rate
deals should be approved by law and regulatory, but I don't need to see max
rate strd language deals.
4. ??? I think there was another issue, but I can't remember what it was.

Thanks for your input on this. DF