CONTOUR ENERGY CO
RW, 2000-08-22
NATURAL GAS TRANSMISSION
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<PAGE>   1
                         [Contour Energy Co. Letterhead]



                                 August 21, 2000


Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn:    Mr. Albert Yarashus

VIA FACSIMILE (202.942.9648) AND EDGAR TRANSMISSION

Ladies and Gentlemen:

Contour Energy Co. filed a Registration Statement on S-4 on May 18, 1999 (Reg.
No 333-37332). Contour agreed, in a Stipulation and Agreement of Compromise,
Settlement and Release approved on August 7, 2000 by Final Order of the Court of
Chancery of the State of Delaware and relating to litigation in which Contour
was named as a defendant, to withdraw the registration statement. Contour did
not commence the consent solicitation contemplated by that registration
statement. Contour received no such consents and made no offerings or sales of
securities using the prospectus included in that registration statement. Contour
requests that the Commission find Contour's withdrawal of the Registration
Statement to be consistent with the public interest and the protection of
investors and consent to Contour's withdrawal of the Registration Statement
pursuant to Rule 477 promulgated under the Securities Act of 1933.


                               Very truly yours,



                               /s/ RICK G. LESTER

                               Rick G. Lester,
                               Senior Vice President and Chief Financial Officer



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