EXHIBIT 99.1

                            UNITED STATES OF AMERICA
                                   BEFORE THE
                      FEDERAL ENERGY REGULATORY COMMISSION

Fact-Finding Investigation of          )
  Potential Manipulation of Electric   )       Docket No.  PA02-2-000
  and Natural Gas Prices               )

                  RESPONSES TO COMMISSION STAFF'S DATA REQUEST
                 OF WILLIAMS ENERGY MARKETING & TRADING COMPANY


         Williams Energy Marketing & Trading Company ("Williams") respectfully
submits its responses to the Commission's data request dated May 22, 2002,
relating to trading activities described as "wash," "round trip" or
"sell/buyback" trading of natural gas in the U.S. portion of the WSCC and Texas
in 2000 and 2001.

         Williams understands "wash," "round trip" or "sell/buyback" trades to
refer to sales by Williams followed by a buyback of the same natural gas product
in a simultaneous transaction. Williams did not identify any such sales that it
initiated.

         To satisfy the Commission's request, Williams examined trading and
accounting data to screen for all transactions in the U.S. portion of the WSCC
or Texas in 2000 and 2001 that potentially could be responsive to the data
request (same counterparty, same volume, same price, same day). Transactions on
the same day with the same counterparty at the same volume and price did occur.
Williams examined each such match, both by reviewing deal tickets and trade
blotters and by interviews with relevant personnel, and did not identify any
such sells and buys that were simultaneous and part of the same transaction
except as explained in these responses. Moreover, Williams interviewed all
employees with relevant information and all confirmed that Williams had not
engaged in any "wash" transactions.





         Williams did identify two financial transactions made at the request of
a counterparty that may have facilitated a "wash" sale by that counterparty. On
March 1, 2001, Williams agreed to enter into two financial swap transactions
based on the SoCal border index at the same price and volume with El Paso
Merchant Energy LP ("El Paso") at El Paso's request. The first was for 233,333
MMBtu/day at $2.47/MMBtu for nine months and the second was for 100,000
MMBtu/day at $4.30/MMBtu for one month. Williams is providing the data relevant
to these transactions. Williams did not identify any other such transactions.

                  In the course of Williams' investigation of the Western
markets, Williams also identified three transactions outside of the West in 2001
that have some of the indicia of "round trip," "wash" or "sell/buyback"
transactions. None were in the relevant geographic region because they were
NYMEX swaps. These transactions were initiated by Williams to facilitate hedging
of price risks of natural gas reserves of Williams Exploration & Production and
to facilitate hedging of price risks associated with power sales by Williams
Energy Marketing & Trading Co. None had the purpose or effect of increasing
Williams' reported volumes or revenues since Williams reports its revenues on a
net basis. None of these transactions had any market price effects because no
brokers were used. All were financial swaps rather than purchases or sales of
natural gas for physical delivery. All three were with the same counterparty, El
Paso Merchant Energy LP. The first was on July 12, 2001 for 50,000 MMBtu/day for
$4.25/MMBtu for ten years. The second was on October 8, 2001 for 66,000
MMBtu/day for $3.20/MMBtu for one year. The third was on November 30, 2001 for
an average volume of 37,998 MMBtu/day for an average price of $3.65/MMBtu for
five years. While these transactions are outside of the geographic region
specified by the Commission and thus are not called for by the request, because
Williams identified them in its investigation, Williams is disclosing these
transactions to the Commission.





I.       Responses to Request for Admission.

         A.       Admit or Deny: the company engaged in activities referred to
                  as "wash," "round trip" or "sell/buyback" trading. This
                  trading involves the sale of natural gas together with a
                  simultaneous purchase of the same product at the same price.

         Williams DENIES.