Exhibit D-15
STATE OF INDIANA
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INDIANA UTILITY REGULATORY COMMISSION
302 W. WASHINGTON STREET, ROOM E306
June 23, 2000
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549
RE: NISource, Inc. and Columbia Energy Group
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Dear Mr. Katz:
The Indiana Utility Regulatory Commission (IURC) received an inquiry
regarding our ability to continue to monitor possible cross-subsidization issues
between NISource's subsidiary Northern Indiana Public Service Company (NIPSCO)
and Columbia Energy Group (Columbia) as a result of the acquisition of Columbia
by NISource. The IURC believes based on Indiana Code 8-1-2-49, that NIPSCO and
Columbia are "affiliated interests" and, as such, NIPSCO must file any contract
between it and Columbia. Specifically, Indiana Code 8-1-2-49 provides, in part,
that:
[I]f it be found that any such contract is not in the public interest,
the commission after investigation and hearing is - authorized to
disapprove such contract.
Based on this statutory authority, and other related statutes, the Commission
believes that it has jurisdiction to monitor the activities of NIPSCO to ensure
that cross-subsidization between NIPSCO and Columbia or any other affiliate does
not occur.
The foregoing opinion is given with the understanding that NISource
will operate Columbia and NIPSCO as separate subsidiaries of NISource and that
Columbia and NIPSCO will not be merged into a single company. The Commission
reserves the right to alter this opinion in the event that there are material
changes between NIPSCO and Columbia, NISource and its affiliates, or this
Commission's statutory authority.
<PAGE>
Jonathan G. Katz
June 23, 2000
Page 2.
Finally, the IURC advises that Northern Indiana has operated in
Indiana as a combination electric and gas utility, with overlapping service
territories, continuously since 1912, and such combined electric and gas
operations are in conformity with our policies and Indiana law.
Sincerely,
/s/ William D. McCarty
William D. McCarty
Chairman
