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Asset Purchase Agreement - Williams Power Company Inc. and Bear Energy LP

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                            ASSET PURCHASE AGREEMENT

                                 BY AND BETWEEN

                          WILLIAMS POWER COMPANY, INC.

                                       AND

                                 BEAR ENERGY LP

                                  May 20, 2007

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                                TABLE OF CONTENTS
                                                                            Page

                                    ARTICLE 1
DEFINITIONS....................................................................1

                                    ARTICLE 2
PURCHASE AND SALE..............................................................8

2.1      Purchase and Sale; Assignment and Assumption..........................8
2.2      Payment of the Initial Purchase Price at Closing; Post-Closing
         Adjustment............................................................8
2.3      No Assumption of Retained Liabilities................................11
2.4      Retained Assets......................................................11
2.5      Amounts Held in Trust................................................12

                                    ARTICLE 3
REPRESENTATIONS AND WARRANTIES OF THE SELLER..................................12

3.1      Organization.........................................................12
3.2      Authorization........................................................12
3.3      Non-Contravention....................................................12
3.4      Requirements of Law..................................................13
3.5      Governmental Permits.................................................13
3.6      Intellectual Property................................................13
3.7      Title to Purchased Assets............................................13
3.8      Assumed Contracts....................................................13
3.9      Litigation...........................................................14
3.10     [INTENTIONALLY DELETED.] ............................................14
3.11     Tax Representations..................................................14
3.12     Certain Invoices.....................................................14

                                    ARTICLE 4
REPRESENTATIONS AND WARRANTIES OF THE BUYER...................................14

4.1      Organization.........................................................14
4.2      Authorization........................................................14
4.3      Non-Contravention....................................................15
4.4      [INTENTIONALLY DELETED.].............................................15
4.5      Litigation...........................................................15
4.6      Buyer's Financial Capacity...........................................15
4.7      Buyer's Knowledge....................................................15
4.8      Tax Representations..................................................15

                                    ARTICLE 5
PRE-CLOSING ACTIVITIES........................................................16

5.1      Conduct of Business..................................................16
5.2      Required Private Consents............................................17
5.3      Business Guaranties..................................................18
5.4      Required Governmental Consents.......................................18
5.5      Non-solicitation.....................................................19

                                       i
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5.6      Preparation for Transition Services Agreement; Buyer Access to
         Seller's Facilities..................................................19
5.7      Knowledge of Breaches................................................19

                                    ARTICLE 6
CONDITIONS PRECEDENT..........................................................20

6.1      Buyer's Conditions to Closing........................................20
6.2      Seller's Conditions to Closing.......................................21

                                    ARTICLE 7
CLOSING.......................................................................22

7.1      Closing..............................................................22
7.2      Seller's Deliveries..................................................22
7.3      Buyer's Deliveries...................................................23

                                    ARTICLE 8
INDEMNIFICATION...............................................................23

8.1      Limitation on and Survival of Representations and Warranties.........23
8.2      Indemnification by the Seller........................................24
8.3      Indemnification by the Buyer.........................................25
8.4      Limitation of Liability..............................................26
8.5      Sole and Exclusive Remedy............................................26

                                    ARTICLE 9
TERMINATION...................................................................27

9.1      Termination..........................................................27
9.2      Effect of Termination................................................27

                                   ARTICLE 10
TAXES AND FURTHER ASSURANCES..................................................27

10.1     Transfer Taxes.......................................................27
10.2     Allocation of Purchase Price.........................................27
10.3     Further Assurances...................................................28

                                   ARTICLE 11
MISCELLANEOUS.................................................................28

11.1     Entire Agreement; Amendment..........................................28
11.2     Expenses.............................................................28
11.3     Governing Law; Jurisdiction..........................................28
11.4     Assignment...........................................................28
11.5     Notices..............................................................28
11.6     Counterparts; Headings...............................................29
11.7     Interpretation.......................................................29
11.8     Schedules and Exhibits...............................................29
11.9     Supplement to Schedules..............................................30
11.10    Closing Over Breaches or Unsatisfied Conditions......................30
11.11    Occasional and Bulk Sales Law........................................30

                                       ii
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11.12    Disclaimers..........................................................30
11.13    Severability.........................................................31
11.14    No Reliance..........................................................32
11.15    Agreement for the Parties' Benefit...................................32
11.16    Non-Waiver...........................................................32
11.17    Public Announcements.................................................32
11.18    Confidentiality......................................................32
11.19    WAIVER OF JURY TRIAL.................................................33
11.20    Post Closing Obligations.............................................33
11.21    Survival.............................................................34

                                      iii
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List of Schedules

Schedule A        Assumed Contracts
Schedule B        Seller Intellectual Property
Schedule C        Key Governmental Approvals
Schedule D        Dormant Master Agreements
Schedule E        Knowledge of the Buyer
Schedule F        Knowledge of the Seller
Schedule G        [Reserved]
Schedule H        [Reserved]
Schedule I        Permitted Encumbrances
Schedule J        Purchased Assets
Schedule 3.4      Requirements of Law
Schedule 3.5      Governmental Permits
Schedule 3.6      Intellectual Property
Schedule 3.8(b)   Breaches and Defaults Under Material Assumed Contracts
Schedule 3.9      Litigation
Schedule 3.12     AES 4000 Agreement Invoices
Schedule 5.2(c)   Permitted TRS Counterparties
Schedule 5.2(d)   Third Party Software Licenses
Schedule 5.3      Business Guaranties (Including Williams Guaranties)
Schedule 5.5      Available Personnel

List of Exhibits

Exhibit A       Form of Assignment and Assumption Agreement
Exhibit B       Form of Bill of Sale
Exhibit C       Form of Intellectual Property License and Assignment Agreement
Exhibit D       Form of Novation Agreement
Exhibit E       Form of Transition Services Agreement
Exhibit F       Form of TRS Agreement
Exhibit G       Form of Facility License Agreement
Exhibit 6.1(g)  Form of Seller's Secretary's Certificate
Exhibit 6.2(g)  Form of Buyer's Secretary's Certificate

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                            ASSET PURCHASE AGREEMENT

      This ASSET PURCHASE AGREEMENT (this "Agreement"), dated May 20, 2007, is
by and between BEAR ENERGY LP, a Delaware limited partnership (the "Buyer"), and
WILLIAMS POWER COMPANY, INC., a Delaware corporation (the "Seller").

                                    RECITALS

      The Seller owns and manages a portfolio of (i) tolling agreements, (ii)
power purchase agreements, (iii) energy management agreements and (iv) physical
and financial electric power and natural gas marketing and trading agreements
and transactions.

      The Buyer and the Seller each desire that the Buyer acquire substantially
all such agreements and transactions and certain intellectual property rights,
books and records, data and other assets of the Seller on the terms and
conditions set forth in this Agreement.

      NOW, THEREFORE, in consideration of the recitals and of the premises,
mutual covenants, representations, warranties, conditions and agreements set
forth herein and for other good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged, it is hereby agreed that:

                                    ARTICLE 1
                                   DEFINITIONS

      "Action" means any complaint, suit, proceeding, claim, arbitration,
demand, assertion or other similar action.

      "Adjustment Statement" has the meaning set forth in Section 2.2(c).

      "AES 4000 Agreement" means the Material Assumed Contract identified as
such in Schedule A hereto.

      "Affiliate" means, as to any Person, any other Person or entity that,
directly or indirectly through one or more intermediaries, controls, is
controlled by or is under common control with such Person, whether by contract,
voting power or otherwise.

      "Agreement" means this Asset Purchase Agreement, together with the
Schedules and Exhibits attached hereto, as the same may be amended from time to
time in accordance with the terms hereof.

      "Ancillary Agreements" means the BSC Guaranty, the Transition Services
Agreement, each Assignment and Assumption Agreement, each Novation Agreement,
the Bill of Sale, the Intellectual Property License and Assignment Agreement,
and each other document, instrument or agreement delivered in connection
herewith or therewith according to the terms hereof or thereof.

                                       1
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      "Assignment and Assumption Agreement" means each Assignment and Assumption
Agreement substantially in the form of Exhibit A attached hereto executed and
delivered pursuant to Section 5.2(a).

      "Assumed Contracts" means the Contracts listed on Schedule A hereto.

      "Assumed Liabilities" has the meaning set forth in Section 2.1.

      "Bill of Sale" means the Bill of Sale for the Purchased Assets, other than
the Assumed Contracts and the Seller Intellectual Property, dated as of the
Closing Date, executed by the Seller in favor of the Buyer in the form of
Exhibit B attached hereto.

      "Books and Records" means, in respect of any of the Purchased Assets, (a)
the Operational Data, whether hard copy or digital, (b) copies of all Assumed
Contracts and correspondence amending, modifying or waiving any provision or
condition in any Assumed Contract, or otherwise relating to Seller's or a
counterparty's actual or alleged nonperformance thereunder, but specifically
excluding routine matters resolved in the settlement process, (c) copies of all
software licenses and related documentation (including specifications, technical
manuals, user manuals, programming manuals, flow diagrams and file
descriptions), whether owned or licensed, and (d) all other records with respect
to the foregoing in Seller's or any of its Affiliate's possession (including
such records located in off-site storage or held by any Person performing
services for Seller or any of its Affiliates) to the extent Seller or any of its
Affiliates has rights thereto, whether in the form of paper, electronic
(including electronic mail) or voice recording media, including accounts
receivable records, invoice and billing records, records of payment history,
credit support and posting records, databases, correspondence and miscellaneous
records; but in all cases excluding (x) records that are subject to the
attorney-work-product doctrine or records that are subject to attorney-client or
other privilege, the disclosure or delivery of which to the Buyer could result
in the loss of privilege and (y) personnel records and other records that the
Seller as a matter of Requirement of Law is required to retain in its
possession.

      "BSC Guaranty" means a guaranty to be provided by The Bear Stearns
Companies Inc. in accordance with the terms of this Agreement.

      "Business" means the Seller's and the Seller's subsidiaries' business of
engaging in physical and financial natural gas and electricity marketing and
trading transactions, including, without limitation, entering into and
performing the Assumed Contracts, but excluding the Gas Business and the Equity
Generation Business.

      "Business Day" means a day other than Saturday, Sunday or a day on which
banks are authorized to be closed for business in the State of New York, the
State of Oklahoma or the State of Texas.

      "Business Guaranty" and "Business Guaranties" have the meanings set forth
in Section 5.3.

      "Buyer" has the meaning set forth in the recitals to this Agreement.

                                       2
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      "Buyer Claim" has the meaning set forth in Section 8.2(a).

      "Buyer Claim Notice" has the meaning set forth in Section 8.2(b).

      "Buyer Indemnified Parties" has the meaning set forth in Section 8.2(a).

      "Buyer's Statement" has the meaning set forth in Section 2.2(c).

      "Cash Consideration" means an amount equal to Five Hundred and Twelve
Million Dollars ($512,000,000).

      "Closing" means the closing of the transactions contemplated hereby on the
Closing Date.

      "Closing Date" means the date upon which the Closing occurs, which shall
be on the first day of the month that is at least five (5) Business Days after
the satisfaction or waiver of each of the conditions set forth in ARTICLE 6
(other than such conditions that by their nature are to be satisfied at
Closing).

      "Closing Date NACF" has the meaning set forth in Section 2.2(c).

      "Contracts" means any contracts, agreements, instruments, license
agreements, physical and financial electric power marketing and trading
transactions, confirmations, cover sheets, commitments, credit support
documents, and invoices, schedules and annexes related thereto, in each case
whether oral or written.

      "Counterparty" or "Counterparties" means any of those parties to the
Assumed Contracts other than the Seller or a subsidiary of the Seller.

      "Deductible" has the meaning set forth in Section 8.4.

      "Dormant Master Agreement" means any of the Contracts that is a master
purchase and sale or financial transaction agreement as set forth in Schedule D.

      "Equity Generation Business" means the business related to the electric
generating facilities owned by Seller's Affiliates, Williams Flexible
Generation, LLC and Williams Generation Company - Hazleton.

      "Estimated Closing Date NACF" has the meaning set forth in Section 2.2(b).

      "Facility License Agreement" means the Facility License Agreement
substantially in the form attached hereto as Exhibit G.

      "FERC" means the Federal Energy Regulatory Commission.

      "FERC Approval" means the issuance by the FERC of one or more final orders
as required to authorize the transactions contemplated under this Agreement.

      "FERC Filing" has the meaning set forth in Section 5.4.

                                       3
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      "Gas Business" means the purchase, sale, or transport of natural gas by
the Seller other than pursuant to any Assumed Contact, including without
limitation related to or in support of any of the businesses of the Seller's
Affiliates, including without limitation, the transport, storage, processing, or
marketing of natural gas produced by the Seller's Affiliates and the purchase of
fuel and shrink for gathering and processing Affiliates of the Seller.

      "Governmental Action" means all consents, approvals, permits, waivers,
exceptions, variances, orders, proceedings, exemptions, publications, filings,
notices to or declarations of or with any Governmental Body.

      "Governmental Body" means any court, government (federal, state, local or
foreign), department, political subdivision, commission, board, bureau, agency,
official or other regulatory, administrative or governmental authority,
including but not limited to the FERC, the Federal Trade Commission, the
Securities and Exchange Commission, any state public service or public utility
or similar commission, any other governmental, quasi-governmental or
non-governmental body administering, regulating or having general oversight over
natural gas, electricity, power or other markets or transmission systems (but
excluding, for the avoidance of doubt, any counterparty to an Assumed Contract
in its capacity as such).

      "Governmental Permits" means all licenses, franchises, permits,
privileges, variances, immunities, consents, rulings, exemptions, orders,
judgments, decrees, approvals or other authorizations of any kind issued by any
Governmental Body.

      "HSR Act" means the Hart-Scott-Rodino Antitrust Improvements Act of 1976,
as amended.

      "HSR Act Termination" means the expiration or earlier termination of the
notification waiting period provided for in the HSR Act.

      "Initial Purchase Price" means an amount equal to the sum of (a) the Cash
Consideration, and (b) the Estimated Closing Date NACF.

      "Intellectual Property" means any or all of the following, and all rights
arising out of or associated therewith: (a) all United States, international and
foreign patents and applications therefor and all reissues, divisions, renewals,
extensions, provisionals, continuations and continuations-in-part thereof; (b)
all confidential and trade secret information, including all confidential
inventions (whether patentable or not), proprietary software, invention
disclosures, improvements, trade secrets, proprietary information, know-how,
technology, technical data and customer lists, and all documentation relating to
any of the foregoing throughout the world; and (c) all copyrights, copyright
registrations and applications therefor, and all other rights corresponding
thereto throughout the world.

      "Intellectual Property License and Assignment Agreement" means that
certain Intellectual Property License and Assignment Agreement by and between
the Parties, substantially in the form of Exhibit C.

      "Interim Adjustment Statement" has the meaning set forth in Section
2.2(c).

                                       4
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      "Interim Closing Adjustment" has the meaning set forth in Section 2.2(c).

      "Key Governmental Approvals" means the FERC Approval, the HSR Act
Termination and the Required Governmental Consents identified on Schedule C.

       "Key Required Private Consents" means the Required Private Consents
applicable to each of the Material Assumed Contracts.

       "Knowledge of the Buyer" means the actual knowledge of the individuals
listed on Schedule E.

      "Knowledge of the Seller" means the actual knowledge of the individuals
listed on Schedule F.

      "Law" means any law, statute, rule, regulation, ordinance order or other
pronouncements, actions or requirements of any Governmental Body.

      "Lien" means any lien, mortgage, security interest, tax lien, attachment,
levy, charge, claim, restriction, imposition, pledge, encumbrance, conditional
sale or title retention arrangement, or any other interest in property or assets
(or the income or profits therefrom), whether consensual or nonconsensual and
whether arising by agreement or under any Requirement of Law, or otherwise.

      "Losses" has the meaning set forth in Section 8.2(a).

      "Material Adverse Effect" means any casualty loss, Governmental Action,
litigation or other event or circumstance that adversely affects (i) the
Purchased Assets or (ii) the Counterparty to, or the generating assets (if any)
that are the subject of, any Assumed Contract that is a tolling agreement,
energy management agreement, or power purchase agreement, and in either case (i)
or (ii), that materially impairs the value of the Purchased Assets taken as a
whole; provided, however, that any adverse change or effect (or changes and/or
effects taken together) attributable to any of the following, in each case shall
not constitute a Material Adverse Effect: (a) any adoption, implementation,
promulgation, repeal, modification, reinterpretation or proposal of any rule,
regulation, ordinance, order, protocol or any other Law of or by any
Governmental Body, (b) changes or developments in international, national,
regional, state or local wholesale or retail markets for electricity or natural
gas or other energy commodities, including, without limitation, changes in
commodity prices, prices of related products (including, without limitation,
financial derivatives), market design, industry standards, or availability or
costs of transportation, (c) system-wide changes or developments in national,
regional or state electric transmission or distribution systems, (d) changes or
developments in financial or securities markets or the economy in general, (e)
the status or condition of the Buyer (including the Buyer's creditworthiness or
credit rating), (f) the accounting treatment for Buyer of the Purchased Assets,
this Agreement or the transactions contemplated hereby, (g) the announcement,
pendency or consummation of the transactions contemplated by this Agreement
(including any decrease in customer demand, any reduction in revenues, any
disruption in supplier, partner or similar relationships, or any loss of
employees); or (h) changes in generally accepted accounting principles; provided
that any loss, claim, occurrence, change or effect that is

                                       5
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cured (including by the payment of money) prior to the Closing Date shall not be
considered a Material Adverse Effect.

      "Material Assumed Contracts" means those Assumed Contracts identified as
such in Schedule A hereto.

      "Material Trading Counterparties" means those eight Counterparties
identified as such on Schedule A hereto.

      "Maximum Indemnity Amount" has the meaning set forth in Section 8.4.

      "Net Accumulated Cash Flow" means, for the period from (and including)
April 1, 2007 to (but not including) the Closing Date, an amount (whether
positive or negative) equal to (a) all of the Seller's payments made to the
Counterparties in the ordinary course of the Seller's Business pursuant to the
terms of the Assumed Contracts during such period (excluding any such payments
constituting postings of collateral or performance security or that relate to
periods prior to April 1, 2007) and all of Seller's payments made to third
Persons (including Counterparties) in the ordinary course of the Seller's
Business pursuant to any physical or financial natural gas or electricity
marketing or trading transactions which relate to the Assumed Contracts minus
(b) all of the payments made to the Seller by the Counterparties in the ordinary
course of the Seller's Business pursuant to the terms of the Assumed Contracts
during such period (excluding any such payments constituting postings of
collateral or performance assurance or that relate to periods prior to April 1,
2007) and all payments made to the Seller by third Persons (including
Counterparties) in the ordinary course of the Seller's Business pursuant to any
physical or financial natural gas or electricity marketing or trading
transactions which relate to the Assumed Contracts, plus (c) whichever of the
following is applicable: $2,500,000 if the Closing occurs during the period of
September 7, 2007 through October 6, 2007; $6,000,000 if the Closing occurs
during the period of October 7, 2007 through November 6, 2007; $10,500,000 if
the Closing occurs during the period of November 7, 2007 through December 6,
2007; or $15,500,000 if the Closing occurs during the period of December 7, 2007
through December 31, 2007.

      "Neutral Accounting Arbitrator" has the meaning set forth in Section
2.2(c).

      "Novation Agreement" means each Novation Agreement substantially in the
form of Exhibit D attached hereto and executed and delivered pursuant to Section
5.2(a).

      "Operational Data" means all computer, digital, electronic, analog,
telecommunications (including voice recording), metering, and billing data
relating to the Purchased Assets and the operations associated therewith and
held by the Seller or any of its Affiliates (to the extent Seller or any of its
Affiliates has rights thereto).

      "Party" means the Buyer or the Seller.

      "Permitted Encumbrances" means (a) the terms and conditions of this
Agreement and the Purchased Assets, (b) those Liens and other matters listed on
Schedule I, and (c) all rights reserved to or vested in any Governmental Body
controlling or regulating or having jurisdiction over any of the Purchased
Assets in any manner, and in all applicable Laws.

                                       6
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      "Permitted TRS Counterparty" means any Counterparty listed on Schedule
5.2.

      "Person" means any individual, corporation, partnership, joint venture,
limited liability company, association (whether incorporated or unincorporated),
joint-stock company, trust, Governmental Body, unincorporated organization or
other entity.

      "Preliminary Statement" has the meaning set forth in Section 2.2(b).

      "Purchased Assets" means the Assumed Contracts, the Dormant Master
Agreements, the Books and Records, Seller Hardware and the Seller Intellectual
Property assets identified on Schedule J.

      "Purchase Price" has the meaning set forth in Section 2.2(c).

      "Required Consents" means all Required Governmental Consents and Required
Private Consents.

      "Required Governmental Consents" means all of the Governmental Actions
required by or under any Requirements of Law in connection with the sale or
assignment of the Purchased Assets to the Buyer and the consummation of the
transactions contemplated hereby (including, without limitation, (i) the Buyer's
assumption, enforcement and performance of the Assumed Contracts in accordance
with the terms thereof, and (ii) the Buyer's ownership, use and operation of the
Purchased Assets).

      "Required Private Consents" means all of the consents, authorizations and
approvals (other than a Required Governmental Consent) required from any Person
by or under any Assumed Contract in connection with the Seller's sale,
assignment, or novation (as applicable) of the Purchased Assets to the Buyer and
consummation of the transactions contemplated hereby (including, without
limitation, (i) the Buyer's assumption, enforcement and performance of the
Assumed Contracts in accordance with the terms thereof, (ii) the replacement of
any Business Guaranties with a BSC Guaranty as provided in Section 5.3, (iii)
the release of Seller with respect to the Assumed Liabilities and (iv) the
Buyer's ownership, use and operation of the Purchased Assets).

      "Requirements of Law" means any requirements of any Law, including but not
limited to the requirements of any applicable Governmental Permits or
Governmental Actions.

      "Resolution Periods" has the meaning set forth in Section 2.2(c).

      "Restricted Information" has the meaning set forth in Section 11.18(b).

      "Retained Assets" has the meaning set forth in Section 2.4.

      "Retained Liabilities" means all liabilities and obligations of the Seller
and any of its Affiliates, other than the Assumed Liabilities.

      "Seller" has the meaning set forth in the recitals to this Agreement.

                                       7
<PAGE>

      "Seller Claim" has the meaning set forth in Section 8.3(a).

      "Seller Claim Notice" has the meaning set forth in Section 8.3(b).

      "Seller Hardware" means the Seller-owned servers used to host the
applications listed on Schedule B and Schedule 5.2(d)(A) as of the date of this
Agreement. Seller Hardware does not include proprietary software, third party
software, data, operating systems, non-attached storage, or confidential or
proprietary information.

      "Seller Indemnified Parties" has the meaning set forth in Section 8.3(a).

      "Seller Intellectual Property" means all Intellectual Property identified
on Schedule B.

      "Tax" or "Taxes" means any present or future federal, state, county, local
or foreign taxes, charges, levies, imposts, duties, other assessments or similar
charges or withholding of any kind whatsoever, including interest, penalties and
additions imposed thereon or with respect thereto, imposed by a Governmental
Body.

      "Tax Returns" means any reports, returns, information returns or other
information required to be supplied to a taxing authority in connection with
Taxes, including any return of an affiliated or combined unitary group.

      "Third Party Software Licenses" means all of the Assumed Contracts
identified as such on Schedule A.

      "Transition Services Agreement" means that certain Transition Services
Agreement by and between the Parties, substantially in the form attached hereto
as Exhibit E.

      "TRS Agreement" means the TRS Agreement by and between the Parties,
substantially in the form of Exhibit F, executed and delivered (if applicable)
pursuant to Section 5.2(c).

      "Williams Guaranties" means the guaranties provided by The Williams
Companies, Inc., or Williams Holdings of Delaware, Inc., to various of the
Counterparties or other Persons in connection with the Purchased Assets and
identified on Schedule 5.3.

                                    ARTICLE 2
                                PURCHASE AND SALE

      2.1 Purchase and Sale; Assignment and Assumption. As of the Closing, and
subject to all of the terms and conditions of this Agreement (including, without
limitation, Section 5.2(c)), the Seller shall sell, transfer, convey, assign and
deliver, and the Buyer shall purchase, all of the Seller's right, title and
interest in and to the Purchased Assets, and the Buyer shall assume, pay,
discharge and perform, each on a timely basis, all of liabilities and
obligations under contract or at Law as to any Assumed Contract or any other
Purchased Asset that are incurred or accrue or otherwise relate to the period
from and after the Closing Date (the "Assumed Liabilities").

      2.2 Payment of the Initial Purchase Price at Closing; Post-Closing
Adjustment.

                                       8
<PAGE>

            (a) At the Closing, and subject to all of the terms and conditions
      of this Agreement (including, without limitation, Section 5.2(c)), in
      consideration of the Seller's sale, transfer, assignment, conveyance and
      delivery of the Purchased Assets, including the Assumed Contracts, the
      Buyer shall assume the Assumed Liabilities and pay to the Seller an amount
      equal to the Initial Purchase Price, by wire transfer to an account or
      accounts designated by the Seller in writing prior to the Closing Date of
      immediately available funds.

            (b) At least five (5) Business Days prior to the anticipated Closing
      Date, the Seller shall prepare and deliver to the Buyer a statement (the
      "Preliminary Statement") that sets forth the Seller's good faith estimate
      of the Net Accumulated Cash Flow (the "Estimated Closing Date NACF").

            (c) The Initial Purchase Price shall be subject to the adjustment
      specified in this Section 2.2(c) (the Initial Purchase Price as so
      adjusted is herein referred to as the "Purchase Price"). Except as
      provided in this Section 2.2(c) (and except that any payments made by the
      Seller under ARTICLE 8 shall be treated for Tax purposes as adjustments to
      the Purchase Price), the Initial Purchase Price shall not be subject to
      any adjustments.

                  (i) Within ninety (90) calendar days after the Closing Date,
            the Seller shall prepare and deliver to the Buyer a statement (the
            "Adjustment Statement") that sets forth (A) its calculation of the
            Net Accumulated Cash Flow (the "Closing Date NACF") and (B) a
            calculation of an amount (whether resulting in a positive or
            negative number, the "Closing Adjustment") equal to (1) the Closing
            Date NACF minus (2) the Estimated Closing Date NACF. The Seller
            shall provide the Buyer and its accountants with access to the
            relevant books and records of the Seller and the Seller's employees
            to the extent required in connection with their review of and any
            dispute with respect to the Adjustment Statement and shall furnish
            the Buyer with any other information that might be relevant to the
            calculation of Closing Date NACF. If, at any time prior to the final
            resolution of all disputed items on the Adjustment Statement,
            additional information shall become known to the Buyer or the Seller
            that would change the amount of the Closing Date NACF shown on the
            calculation set forth in the Adjustment Statement, then the Buyer
            shall amend the Adjustment Statement to reflect such additional
            information. The Buyer and the Seller shall promptly notify each
            other upon it becoming aware of any additional information prior to
            the end of the Resolution Period (as defined below).

                  (ii) After receipt of the Adjustment Statement, the Buyer will
            have thirty (30) calendar days from receipt to review the Adjustment
            Statement together with the workpapers used in their preparation.
            Unless the Buyer delivers to the Seller a written notice setting
            forth in reasonable detail the specific items disputed by the Buyer
            and a written statement setting forth the Buyer's calculation of
            each line item shown on the Adjustment Statement so disputed and the
            amount in dispute (the "Buyer's Statement") on or prior to the
            thirtieth (30th) day after receipt of the Adjustment Statement, the
            Buyer will be deemed to have accepted

                                       9
<PAGE>

            and agreed to the Adjustment Statement and the Closing Adjustment
            calculated therein and such agreement will be final, binding and
            conclusive. Any items on the Adjustment Statement as to which the
            Buyer has not given notice of its objection and provided an
            alternative calculation on the Buyer's Statement will be deemed to
            have been agreed upon by the Parties, subject to the penultimate
            sentence of Section 2.2(c)(ii). If the Buyer so notifies the Seller
            of its objection to the Adjustment Statement and provides the Seller
            with the Buyer's Statement in a timely manner, the Buyer and the
            Seller will, within thirty (30) calendar days following such notice
            (the "Resolution Period"), attempt to resolve their differences. Any
            resolution by the Buyer and the Seller during the Resolution Period
            as to any disputed amounts will be final, binding and conclusive.

                  (iii) If the Buyer and the Seller do not resolve all disputed
            items by the end of the Resolution Period, then all items remaining
            in dispute will be submitted within ten (10) days after the
            expiration of the Resolution Period to a national independent
            accounting firm mutually acceptable to the Buyer and the Seller (the
            "Neutral Accounting Arbitrator"); it being understood that no member
            of the Neutral Accounting Arbitrator's engagement team shall have an
            existing professional relationship with the Buyer or Seller or any
            of their Affiliates. The Neutral Accounting Arbitrator shall act as
            an arbitrator to determine only those items in dispute. All fees and
            expenses relating to the work, if any, to be performed by the
            Neutral Accounting Arbitrator will be paid fifty percent (50%) by
            the Buyer and fifty percent (50%) by the Seller, provided that the
            Neutral Accounting Arbitrator may, upon determination that a Party
            did not raise its objections in respect of the matters in dispute in
            good faith, determine the fees and expenses to be paid by such Party
            up to and including all of such fees and expenses. The Neutral
            Accounting Arbitrator will deliver to the Buyer and the Seller a
            written determination (such determination to include a work sheet
            setting forth all material calculations used in arriving at such
            determination and to be based solely on information provided to the
            Neutral Accounting Arbitrator by the Seller and the Buyer) of the
            disputed items within thirty (30) days of receipt of the disputed
            items (or as soon as practicable thereafter), which determination
            will be final, binding and conclusive as to such disputed items. The
            final Adjustment Statement containing those items which either are
            agreed upon by the Buyer and the Seller or are delivered by the
            Neutral Accounting Arbitrator in accordance with this Section will
            be the "Interim Adjustment Statement". In the event that either the
            Buyer or the Seller fails to submit its statement regarding any
            items remaining in dispute within the time determined by the Neutral
            Accounting Arbitrator, then the Neutral Accounting Arbitrator shall
            render a decision based solely on the evidence timely submitted to
            the Neutral Accounting Arbitrator by the Buyer and/or the Seller.

                  (iv) If the Closing Adjustment as shown on the Interim
            Adjustment Statement (the "Interim Closing Adjustment") is a
            negative number, then the Initial Purchase Price will be reduced by
            the amount of the Interim Closing Adjustment and the Buyer shall be
            entitled to payment of such amount from the Seller by wire transfer
            of immediately available funds to an account or accounts

                                       10
<PAGE>

            designated by the Buyer. If the Interim Closing Adjustment is a
            positive number, then the Initial Purchase Price will be increased
            by the amount of the Interim Closing Adjustment and the Buyer shall
            pay such amount to the Seller by wire transfer of immediately
            available funds, to be paid to an account or accounts designated in
            writing by the Seller prior to the date when such payment is due.
            All payments to be made pursuant to this Section 2.2(c)(iv) will be
            made on the fifth Business Day following the date on which the Buyer
            and the Seller agree to, or the Neutral Accounting Arbitrator
            delivers, the Interim Statement and the Interim Adjustment
            Statement.

                  (v) On or prior to the one year anniversary of the Closing
            Date, either Buyer or Seller may notify the other Party of its
            desire to update the Interim Adjustment Statement to reflect
            additional items (i.e., items not taken into account in the Interim
            Closing Adjustment) that would change the Interim Closing
            Adjustment. Promptly after such notice is given, the Parties shall
            provide to each other a description and the amount of any such
            additional items. Any amounts paid in accordance with the terms of
            Section 2.5 shall not constitute or be included as additional items.
            Buyer shall prepare a statement that reflects the proposed changes
            to the Interim Closing Adjustment (which is also referenced to
            herein as the "Adjusted Statement") and provide the same to Seller.
            If the Parties do not reach an agreement on the Adjustment Statement
            within 30 days after Seller's receipt of the same, then the
            provisions of clause (iii) above shall apply. The Initial Purchase
            Price shall be adjusted to reflect any such adjustment agreed upon
            by the Parties or determined by the Neutral Accounting Arbitrator
            (as applicable) and the resulting payment due from Seller or Buyer
            shall be paid to the other Party by wire transfer of immediately
            available funds no later than the fifth Business Day following the
            date on which such agreement is reached or determination is made.

                  (vi) The Parties acknowledge and agree that neither the Net
            Accumulated Cash Flow nor any of the items comprising the
            calculation thereof include any charges for overhead or labor costs
            of Seller or its Affiliates.

      2.3 No Assumption of Retained Liabilities. The Buyer does not and will not
assume any of the Retained Liabilities, which shall remain the sole
responsibility of and shall be retained, paid, performed and discharged solely
by the Seller, or as applicable, the Seller's Affiliates.

      2.4 Retained Assets. Notwithstanding anything to the contrary contained in
Section 2.1 or elsewhere in this Agreement, any right, interest or claim of the
Seller relating to the Assumed Contracts and the other Purchased Assets that
arises or accrues during, or otherwise relates to, the period prior to the
Closing Date, including without limitation the right to the return of cash
collateral or any Business Guaranties posted or credited to Counterparties as of
the Closing Date (the "Retained Assets"), is excluded from the Assumed Contacts
and the other Purchased Assets and will remain the property of the Seller after
the Closing.

                                       11
<PAGE>

      2.5 Amounts Held in Trust. Any amounts received by the Buyer after the
Closing with respect to any Excluded Asset shall be held by the Buyer in trust
for the benefit of the Seller, shall be segregated from other property and funds
of the Buyer and shall forthwith be paid or delivered to the Seller in the same
form as so received (with any necessary endorsement or assignment). Likewise,
any amounts received by the Seller after the Closing with respect to any
Purchased Asset shall be held by the Seller in trust for the benefit of the
Buyer, shall be segregated from other property and funds of the Seller and shall
be forthwith paid or delivered to the Buyer in the same form as so received
(with any necessary endorsement or assignment).

                                    ARTICLE 3
                  REPRESENTATIONS AND WARRANTIES OF THE SELLER

      The Seller represents and warrants to the Buyer as of the date hereof and,
if the Closing occurs, as of the Closing, that:

      3.1 Organization. The Seller is a corporation duly organized and validly
existing under the laws of the State of Delaware, is duly qualified to transact
business as a foreign corporation in the State of Oklahoma and is in good
standing in the States of Oklahoma and Delaware. The Seller has delivered or
otherwise made available to the Buyer true and complete copies of the Seller's
Articles of Incorporation and By-laws, as in effect on the date hereof.

      3.2 Authorization. Seller has all requisite power and authority to execute
this Agreement and the Ancillary Agreements to which it will be a party and to
perform its obligations hereunder and thereunder. The execution and delivery of
this Agreement and the Ancillary Agreements to which it is or will be a party
and the consummation of the transactions contemplated hereby and thereby have
been duly and validly authorized and approved by all requisite action by the
Seller. This Agreement constitutes, and upon execution, the Ancillary Agreements
to which it is a party will constitute, the valid and binding obligations of the
Seller enforceable against the Seller in accordance with its terms, except as
such enforceability may be limited by (a) bankruptcy, insolvency,
reorganization, moratorium or similar Laws relating to or affecting generally
the enforcement of creditors' rights and (b) the availability of equitable
remedies (whether in a proceeding in equity or at Law).

      3.3 Non-Contravention. Neither the execution or delivery of this Agreement
nor the Ancillary Agreements to which it will be a party by the Seller nor the
consummation of the transactions contemplated hereby or thereby, including but
not limited to the assignment of the Assumed Contracts to the Buyer and
retention of the Retained Liabilities, will conflict with or result in the
breach of any term or provision of, or constitute a default under, the Articles
of Incorporation, By-laws or other governing documents of the Seller or any of
its Affiliates; result in a default, or give rise to any right of termination,
cancellation or acceleration, impose any additional obligation under any
provision of any contract or agreement of the Seller or any of its Affiliates,
including, without limitation, any Assumed Contract, any loan agreements,
promissory notes, indentures or instruments to which the Seller or any of its
Affiliates is a party or by which the Seller or any of its Affiliates is bound;
(c) result in the creation or imposition of any Lien on any of the Purchased
Assets, other than Permitted Encumbrances; (d) violate any Requirements of Law
applicable to the Seller; or (e) other than the Required Private Consents and
the Required Governmental Consents, require on the part of the Seller the
approval, consent,

                                       12
<PAGE>

waiver, authorization or act of, or the making by the Seller of any declaration,
filing or registration with, any Person.

      3.4 Requirements of Law. To the Knowledge of the Seller, except as may be
indicated on Schedule 3.4, all of the Purchased Assets and their uses in the
Business as presently conducted by the Seller conform to all Requirements of
Law.

      3.5 Governmental Permits. Seller has obtained the Governmental Permits
identified on Schedule 3.5, which are the only Governmental Permits necessary
for it to own, use and manage the Purchased Assets and to carry on and conduct
the Business as currently conducted by the Seller, such Governmental Permits are
in full force and effect and the Seller is in compliance with all such
Governmental Permits.

      3.6 Intellectual Property. Except as set forth on Schedule 3.6, the Seller
Intellectual Property is owned by the Seller. To the Knowledge of the Seller,
the conduct of the Business as currently conducted by the Seller does not
infringe, or constitute an infringement or misappropriation of any Intellectual
Property of any Person. To the Knowledge of the Seller, no Person is infringing
or misappropriating the Seller Intellectual Property. Except as set forth on
Schedule 3.6, or otherwise evidenced under the terms of the Seller Intellectual
Property no current or former partner, director, officer, or employee of the
Seller or any third party will, after giving effect to each of the transactions
contemplated herein, own or retain any rights in or to any of the Seller
Intellectual Property, including the right to use, license, sublicense, or
receive royalties or other compensation with respect to such Seller Intellectual
Property.

      3.7 Title to Purchased Assets. The Seller has good and valid title to all
of the Purchased Assets free and clear of all Liens, other than Permitted
Encumbrances.

      3.8 Assumed Contracts.

            (a) Schedule A hereto sets forth a true and complete list of the
      Assumed Contracts as of April 1, 2007. The information set forth on
      Schedule A is accurate in all material respects as of such date. For the
      purposes of this subsection (a), "material" shall mean discrepancies in
      Schedule A in the aggregate exceeding Three Million Dollars
      ($3,000,000.00).

            (b) Except as set forth on Schedule 3.8(b), neither the Seller nor,
      to the Knowledge of the Seller, any Counterparty to any Material Assumed
      Contract is, as of the date hereof, in breach thereof or default
      thereunder, and there does not exist under any provision thereof, to the
      Knowledge of the Seller, as of the date hereof, any event that, with the
      giving of notice or the lapse of time or both, would constitute such a
      breach or default of any Material Assumed Contract, except for such
      breaches, defaults and events as to which requisite waivers or consents
      have been or will, on or prior to the Closing Date, be cured or obtained
      or which, collectively or individually, do not have, or would not
      reasonably be expected to have, a Material Adverse Effect.

            (c) Each of the Material Assumed Contracts is in full force and
      effect in all material respects and constitutes a legal, valid and binding
      obligation of the Seller and, to the Knowledge of the Seller, of the
      Counterparty thereto, except for such failures that,

                                       13
<PAGE>

      collectively or individually, do not have, or would not reasonably be
      expected to have, a Material Adverse Effect.

            (d) Except (i) as set forth on Schedule A, (ii) otherwise permitted
      pursuant to Section 5.1 or (iii) with respect to the Material Assumed
      Contracts with the Material Trading Counterparties, no Material Assumed
      Contract has been amended, supplemented or modified in any material
      respect. True and complete copies of all Assumed Contracts (including all
      amendments, supplements and modifications thereto) will be provided to the
      Buyer no later than Five (5) Business Days from the date of this
      Agreement.

      3.9 Litigation. Except as set forth on Schedule 3.9, there is no
Governmental Action or other suit or proceeding initiated by any Person pending
or, to the Knowledge of the Seller, threatened (a) under or in respect of any of
the Purchased Assets (including, but not limited to, any claim related to
environmental contamination, exposure, releases or other environmental matters)
except such as would not have or would not reasonably be expected to have a
Material Adverse Effect or (b) which questions the legality or propriety of the
transactions contemplated by this Agreement.

      3.10 [INTENTIONALLY DELETED.] .

      3.11 Tax Representations.

            (a) The Seller is not required by any applicable Law, as modified by
      the practice of any relevant Governmental Body, to make any deduction or
      withholding for or on account of any Tax from any payment to be made by it
      to the Buyer under this Agreement or any Ancillary Agreement.

            (b) The Seller is classified as a domestic corporation for U.S.
      federal income tax purposes.

      3.12 Certain Invoices. Attached as Schedule 3.12 are true and correct
copies of the monthly summary invoices as issued by the Counterparty to the
Seller under the AES 4000 Agreement with respect to the following periods:
January - December, 2005; January - December, 2006; and January - March, 2007.

                                    ARTICLE 4
                   REPRESENTATIONS AND WARRANTIES OF THE BUYER

      The Buyer represents and warrants to the Seller as of the date hereof and,
if the Closing occurs, as of the Closing, that:

      4.1 Organization. The Buyer is a limited partnership duly formed and
validly existing and in good standing under the laws of the State of Delaware.
The Buyer has full corporate power and authority to own or lease and to operate
and use its assets and carry on its business as now conducted and as it will be
conducted with the Purchased Assets.

      4.2 Authorization. Buyer has all requisite power and authority to execute
and deliver this Agreement and the Ancillary Agreements to which it will be a
party and to perform

                                       14
<PAGE>

its obligations hereunder and thereunder. The execution and delivery of this
Agreement and the Ancillary Agreements to which it is or will be a party and the
consummation of the transactions contemplated hereby and thereby have been duly
and validly authorized and approved by all requisite action by the Buyer. This
Agreement constitutes, and upon execution, the Ancillary Agreements to which it
is a party will constitute, the valid and binding obligations of the Buyer
enforceable against the Buyer in accordance with their respective terms, except
as such enforceability may be limited by (a) bankruptcy, insolvency,
reorganization, moratorium or similar Laws relating to or affecting generally
the enforcement of creditors' rights and (b) the availability of equitable
remedies (whether in a proceeding in equity or at Law).

      4.3 Non-Contravention. Neither the execution or delivery of this Agreement
and the Ancillary Agreements to which it will be a party by the Buyer nor the
consummation of the transactions contemplated hereby and thereby, including but
not limited to the assumption of the Assumed Contracts and Assumed Liabilities,
will (a) conflict with or result in the breach of any term or provision of, or
constitute a default under, the Articles of Incorporation, By-laws or other
governing documents of the Buyer or any of its Affiliates; (b) result in a
default, or give rise to any right of termination, cancellation or acceleration
of any material contract or agreement of the Buyer or any of its Affiliates,
including, without limitation, any loan agreements, promissory notes, indentures
or instruments to which the Buyer or any of its Affiliates is a party or by
which the Buyer or any of its Affiliates is bound; (c) violate any Requirements
of Law applicable to the Buyer; or (d) require on the part of the Buyer the
approval, consent, waiver, authorization or act of, or the making by the Buyer
of any declaration, filing or registration with, any Person, except for the
necessary filings and approvals under the HSR Act and from the FERC; and except
as would not prevent or delay in any material respect the consummation of the
transactions contemplated under this Agreement.

      4.4 [INTENTIONALLY DELETED.]

      4.5 Litigation. There is no Governmental Action, suit or proceeding
initiated by any Person pending or, to the Knowledge of the Buyer, threatened
which questions the legality or propriety of the transactions contemplated by
this Agreement.

      4.6 Buyer's Financial Capacity. The Buyer has the present financial
capacity and resources to satisfy its obligations to discharge and satisfy the
Assumed Liabilities and to pay the Purchase Price to the Seller, as and when
due.

      4.7 Buyer's Knowledge. To the Knowledge of the Buyer, as of the date of
this Agreement, the Seller is not in breach of any of the representation or
warranties in ARTICLE 3.

      4.8 Tax Representations.

            (a) The Buyer is not required by any applicable Law, as modified by
      the practice of any relevant Governmental Body, to make any deduction or
      withholding for or on account of any Tax from any payment to be made by it
      to the Seller under this Agreement or any Ancillary Agreement.

            (b) The Buyer is classified as a domestic limited partnership for
      U.S. federal income tax purposes.

                                       15
<PAGE>

                                    ARTICLE 5
                             PRE-CLOSING ACTIVITIES

      The applicable Party hereto, as set forth below, covenants and agrees
that, from and after the execution and delivery of this Agreement until the
Closing or the termination of this Agreement:

      5.1 Conduct of Business.

            (a) The Seller shall, except as the Buyer may otherwise consent in
      writing in the Buyer's reasonable discretion, perform the Assumed
      Contracts, protect and preserve the Purchased Assets, and conduct the
      Business as it relates to the Assumed Contracts in the ordinary and usual
      course of business and in accordance with past practices, except as set
      forth below. Without limiting the generality of the foregoing, except as
      set forth below, the Seller shall (i) duly comply in all material respects
      with all applicable Requirements of Law, perform in all material respects
      its obligations under all of the Assumed Contracts, maintain the Books and
      Records relating to the Assumed Contracts (in a manner consistent with
      generally accepted accounting principles as determined by Seller's
      independent auditor) and otherwise preserve intact and protect the
      Purchased Assets in an ordinary course of business consistent with past
      practices, (ii) maintain appropriate staff and management personnel and
      make requisite expenditures sufficient to perform the Assumed Contracts,
      and (iii) use commercially reasonable efforts to continue and preserve all
      business relationships with each party to the Assumed Contracts and any
      other Person having business or other dealings relating to the Purchased
      Assets and the Business as it related to the Assumed Contracts, including
      all Governmental Bodies. In addition to the foregoing, the Seller shall
      (A) not sell, assign, convey, lease or otherwise dispose of, or amend,
      modify or terminate, any of the Assumed Contracts or other Purchased
      Assets, except that the Seller shall be permitted to amend, modify or
      terminate any of the Assumed Contracts if such action (1) is done in the
      ordinary course of business, (2) is permitted under the Seller's trading
      and risk management policies in effect on the date of this Agreement to be
      done by an individual trader without approval of any other Person within
      the Seller's organization (without regard to any additional delegation of
      authority not evidenced in Seller's trading and risk management policies),
      and (3) does not involve any extension of the term of any Assumed Contract
      by more than one year; (B) not place a Lien on any of the Assumed
      Contracts or other Purchased Assets; (C) not enter into new Contracts or
      new transactions in respect of the Assumed Contracts existing on the date
      hereof, except that the Seller shall be permitted to enter into new
      Contracts or new transactions in respect of the Assumed Contracts if such
      action (1) is done in the ordinary course of business, (2) is permitted
      under the Seller's trading and risk management policies in effect on the
      date of this Agreement to be done by an individual trader without approval
      of any other Person within the Seller's organization (without regard to
      any additional delegation of authority not evidenced in Seller's trading
      and risk management policies), (3) does not involve entering into a
      Contract having a term beyond December 31, 2008; and (D) hedge fixed price
      power purchases or sales with natural gas. Notwithstanding the foregoing,
      Seller shall be permitted to enter into new Contracts pursuant to
      mandatory or "must offer" programs or auctions affecting the

                                       16
<PAGE>

      Assumed Contracts on the terms of such programs or auctions, including
      without limitation, the PJM RPM capacity market auction for years 2008,
      2009 and 2010.

            (b) The Seller shall provide to a representative of the Buyer as
      designated by the Buyer (and whom the Buyer shall ensure is not
      responsible for execution of the commercial activity of the Buyer) on a
      weekly basis a summary of the trading activity, changes in collateral
      postings and holdings and payments received and made, associated with the
      Assumed Contracts.

      5.2 Required Private Consents.

            (a) The Parties agree to use commercially reasonable efforts, and to
      cooperate and provide each other with reasonable assistance, to do all
      things necessary or appropriate to cause or permit the novation or
      assignment of the Assumed Contracts to the Buyer (including, in the case
      of Buyer, entering into new master or enabling agreements if necessary)
      and to obtain any Required Private Consents (and, if needed, the consent
      of any Person providing credit support on behalf of the applicable
      Counterparty) so that all right, title and interest of the Seller with
      respect to the applicable Assumed Contract shall be novated or assigned to
      the Buyer effective as of the Closing. In furtherance of the foregoing,
      the Buyer shall provide to each Counterparty to an Assumed Contract within
      a reasonable period of time following the date hereof, a form of Novation
      Agreement or a form of Assignment and Assumption Agreement, with such
      modifications, if any, thereto that have been mutually agreed to by the
      Seller and the Buyer acting reasonably. Notwithstanding the foregoing, the
      Parties agree that the Required Private Consents for the Third Party
      Software Licenses and the Dormant Master Agreements shall not be due upon
      Closing.

            (b) Except as set forth in Schedule 5.2(d), each Party shall bear
      its own costs in connection with obtaining all Required Private Consents.
      Neither Party shall have any obligation to make any economic concession to
      a third party as a condition to obtaining a Required Consent.

            (c) Nothing in this Agreement shall be deemed to be an agreement to
      assign the Seller's rights under any Assumed Contract or any other
      Purchased Asset to be assigned to the Buyer in the absence of a Required
      Consent if such an attempted assignment would constitute a breach thereof
      or be unlawful. If any Required Consent in respect of any Assumed Contract
      other than a Material Assumed Contract is not obtained, or if an attempted
      assignment or assumption of any Assumed Contract other than a Material
      Assumed Contract would be ineffective or would adversely affect the rights
      or increase the obligations of any Party to this Agreement or any of its
      Affiliates with respect to any Assumed Contract, so that the Buyer would
      not, in fact, receive the rights, or assume the obligations with respect
      thereto as the same exist prior to such attempted assignment or
      assumption, then, at the Closing the Parties will enter into the TRS
      Agreement in respect of any such Assumed Contracts, if the Counterparty to
      such Assumed Contract is a Permitted TRS Counterparty. The establishment
      of the TRS shall be deemed, for purposes of Section 6.1(b), the equivalent
      of obtaining the subject Required Consents for the Assumed Contracts
      covered by the TRS.

                                       17
<PAGE>

            (d) The Parties agree to use commercially reasonably efforts in
      assuming the obligations set forth in Schedule 5.2(d) to cause the
      assignment of the Third Party Software Licenses identified on Schedule
      5.2(d) and the Dormant Master Agreements identified on Schedule D to the
      Buyer.

      5.3 Business Guaranties. The Buyer shall use commercially reasonable
efforts, (a) to replace, effective as of the Closing, each of the Williams
Guaranties and each of the guaranties, letters of credit, letters of comfort and
performance bonds set forth in Schedule 5.3 hereto (each, a "Business Guaranty",
collectively the "Business Guaranties") with a BSC Guaranty or a replacement
letter of credit, and (b) to assist Seller in obtaining release effective as of
the Closing of all obligations of the Seller or any Affiliate of Seller under
the Business Guaranties, but only to the extent relating to the Assumed
Liabilities under the applicable Assumed Contracts. If the Buyer is unable to so
replace any Business Guaranty, or Seller or any Affiliate of Seller is not so
released, at the Closing after using its commercially reasonable efforts to do
so, or assist Seller in doing so, the Buyer shall provide to the Seller and
maintain in full force and effect in respect of each such Business Guaranty, a
BSC Guaranty in form and substance substantially similar to such Business
Guaranty, with respect to the obligations covered by each Business Guaranty for
which the Buyer does not effect at the Closing such replacement or for which a
release of Seller is not obtained, but only to the extent such Business
Guaranties relate to the Assumed Liabilities under the applicable Assumed
Contracts.

      5.4 Required Governmental Consents.

            (a) The Buyer and the Seller agree that as soon as practicable, but
      in no event later than fifteen (15) days after the date of this Agreement,
      (i) each will complete and file the "Antitrust Improvements Act
      Notification and Report Form for Certain Mergers and Acquisitions", if and
      as required by the HSR Act, and will promptly complete and file responses
      to all requests for additional data and information which may be made
      under such Act, and (ii) they will jointly file the FERC application (the
      "FERC Filing"). The Buyer shall prepare the FERC Filing in consultation
      with the Seller. The Buyer shall pay all costs for preparation of the FERC
      Filing (other than the Seller's costs) and all HSR Act filing fees
      relating to the transactions contemplated hereby, irrespective of whether
      the transactions contemplated by this Agreement are consummated.

            (b) Each Party shall, and shall cause their respective Affiliates
      to, use their commercially reasonable efforts, at their own costs, to (i)
      cause the expiration of the notice periods under any Laws with respect to
      the transactions contemplated by this Agreement as promptly as is
      reasonably practicable before the Closing Date and (ii) resolve on
      commercially reasonable terms such objections, if any, as may be asserted
      by any Governmental Body with respect to the transactions contemplated by
      this Agreement. In connection therewith, if any administrative or judicial
      action or proceeding is instituted (or threatened to be instituted)
      challenging the transaction contemplated by this Agreement as violative of
      any Law, each of the Parties shall, and shall cause their respective
      Affiliates to, cooperate and use their commercially reasonable efforts to
      contest and resist, except insofar as the Seller and the Buyer may
      otherwise agree, any such action or proceeding, including any action or
      proceeding that seeks a temporary

                                       18
<PAGE>

      restraining order or preliminary injunction that would prohibit, prevent
      or restrict consummation of the transactions contemplated by this
      Agreement.

            (c) Each Party shall, and shall cause their respective Affiliates,
      at their own cost, to furnish to the other all information necessary with
      respect to any application or other filing to be made in connection with
      the transactions contemplated by this Agreement, including in connection
      with any filings, conferences or other submissions related to resolving
      any investigation or other inquiry by any such Governmental Body with
      respect to the transactions contemplated by this Agreement. Each of the
      Seller and the Buyer shall promptly inform the other of any communication
      with, and any proposed understanding, undertaking or agreement with, any
      Governmental Body in respect of any such filings, investigation or other
      inquiry. If a Party intends to independently participate in any meeting
      with any Governmental Body in respect of any such filings, investigation
      or other inquiry, then such Party shall give the other Party reasonable
      prior notice of such meeting such that the other Party has reasonable
      opportunity to attend and participate at such a meeting. The Parties shall
      consult and cooperate with one another in connection with any analyses,
      appearances, presentations, memoranda, briefs, arguments and opinions made
      or submitted by or on behalf of any Party in connection with all meetings,
      actions and proceedings under or relating to any such application or
      filing.

      5.5 Non-solicitation. Other than with respect to those individuals listed
on Schedule 5.5 (whom Buyer may solicit but not employ or otherwise engage as an
employee, independent contractor or otherwise prior to the termination of Phase
I of the Transition Services Agreement), until the date that is one year after
the Closing Date, neither the Buyer nor any of its Affiliates shall, directly or
indirectly, (a) induce any employee of the Seller or any of its Affiliates to
leave the employ of the Seller or its Affiliates or (b) employ or otherwise
engage as an employee, independent contractor or otherwise any such employee,
except that the Buyer and its Affiliates shall not be precluded from hiring any
such employee who (i) initiates discussions regarding such employment without
any direct or indirect solicitation by the Buyer or its Affiliates or (ii)
responds to any public advertisement placed by the Buyer or its Affiliates.

      5.6 Preparation for Transition Services Agreement; Buyer Access to
Seller's Facilities.

            (a) Seller shall use its commercially reasonable efforts to obtain
      any consents, waivers, permits or sublicenses necessary in order for
      Seller to provide services under the Transition Services Agreement.

            (b) From the date of this Agreement through Closing, upon request of
      Buyer, Seller shall provide Buyer with reasonable access to Seller's
      employees and facilities during normal business hours in order to
      facilitate transition planning and post-Closing implementation of the
      transactions contemplated herein, including pursuant to the Transition
      Services Agreement.

      5.7 Knowledge of Breaches. If after the date of this Agreement and prior
to the Closing, either Party becomes aware of any breach by the Seller or Buyer
of any representation and warranty under this Agreement, it will promptly notify
the other Party thereof.

                                       19
<PAGE>

                                    ARTICLE 6
                              CONDITIONS PRECEDENT

      6.1 Buyer's Conditions to Closing. The obligations of the Buyer under this
Agreement with respect to the purchase and sale of the Purchased Assets and the
assumption of the Assumed Liabilities shall be subject to the fulfillment on or
prior to the Closing of each of the following conditions, any of which may be
waived by the Buyer, in the Buyer's sole discretion.

            (a) All of the representations and warranties of the Seller
      contained in this Agreement and all other Ancillary Agreements will be, if
      qualified by materiality, true and correct in all respects, and if not so
      qualified, shall be true and correct in all material respects, except with
      respect to the representations and warranties contained in Section 3.2 and
      Section 3.7, to which no materiality qualifier shall apply, as of the
      Closing Date as though made on and as of the Closing Date (except to the
      extent such representations and warranties speak as of an earlier date and
      except for the representations and warranties contained in Section 3.8(a),
      which shall be deemed made as of the date most recent to the Closing Date
      that Schedule A is supplemented and amended pursuant to Section 11.9(b)).
      The Seller shall have complied with, performed and satisfied in all
      material respects all of the agreements, covenants, and conditions
      contained in this Agreement to be performed or complied with by it on or
      prior to the Closing.

            (b) The Buyer shall have received (i) each of the Key Governmental
      Approvals in the form prescribed hereunder or in a form otherwise
      reasonably satisfactory to the Buyer, (ii) each of the Key Required
      Private Consents in the form prescribed hereunder or in a form otherwise
      reasonably satisfactory to the Buyer, and (iii) the assignment or novation
      of each Assumed Contract, or the TRS Agreement or such other arrangement
      reasonably satisfactory to Buyer with respect to such Assumed Contract as
      provided in Section 5.2, effective as of the Closing. Notwithstanding the
      foregoing, the Parties agree that neither the assignment nor receipt of
      Required Private Consents with respect to either the Third Party Software
      Licenses or the Dormant Master Agreements shall be conditions to Closing.

            (c) There shall be no Action, pending or threatened by any third
      party (including any Governmental Body) and no judgment shall have been
      entered and not vacated by any Governmental Body of competent jurisdiction
      in any Governmental Action or other Action, arising therefrom, which seeks
      to enjoin, restrain, make illegal, or prohibit consummation of the
      transactions contemplated by this Agreement or that seeks to prohibit or
      limit the Buyer's ownership or performance of any portion of the Purchased
      Assets.

            (d) Except for (i) matters that are the subject of the Seller's
      representations and warranties in ARTICLE 3 (which representations and
      warranties constitute the Buyer's exclusive assurance with respect to the
      subject matters thereof), (ii) facts or circumstances of which the Buyer
      has Knowledge on the date hereof not required to be corrected or
      remediated on or before the Closing Date and (iii) matters resulting from
      acts

                                       20
<PAGE>

      or omissions of the Buyer or any of its Affiliates or representatives,
      since the date of this Agreement, no event or circumstance has occurred
      and is continuing that has had or reasonably would be expected to have a
      Material Adverse Effect.

            (e) A duly authorized officer of the Seller shall have certified the
      satisfaction of the conditions in paragraph (a) of this Section 6.1.

            (f) The Seller shall have made or stand willing and able to make all
      of the deliveries to the Buyer set forth in Section 7.2.

            (g) The Secretary of the Seller shall have executed a certificate
      substantially in the form attached hereto as Exhibit 6.1(g).

      6.2 Seller's Conditions to Closing. The obligations of the Seller under
this Agreement with respect to the purchase and sale of the Purchased Assets and
the assumption of the Assumed Liabilities by the Buyer shall be subject to the
fulfillment on or prior to the Closing of each of the following conditions, any
of which may be waived by the Seller in the Seller's sole discretion:

            (a) All of the representations and warranties of the Buyer contained
      in this Agreement and all other Ancillary Agreements will be, if qualified
      by materiality, true and correct in all respects, and if not so qualified,
      shall be true and correct in all material respects, as of the Closing Date
      as though made on and as of the Closing Date (except to the extent such
      representations and warranties speak as of an earlier date). The Buyer
      shall have complied with, performed and satisfied in all material respects
      all of the agreements, covenants, and conditions contained in this
      Agreement to be performed or complied with by it on or prior to the
      Closing.

            (b) The Seller shall have received (i) each of the Key Governmental
      Approvals in the form prescribed hereunder or in a form otherwise
      reasonably satisfactory to the Seller, (ii) each of the Key Required
      Private Consents in the form prescribed hereunder or in a form otherwise
      reasonably satisfactory to the Seller, and (iii) the assignment or
      novation of each Assumed Contract, or the TRS Agreement or such other
      arrangement reasonably satisfactory to Seller with respect to such Assumed
      Contract as provided in Section 5.2, effective as of the Closing.
      Notwithstanding the foregoing, the Parties agree that neither the
      assignment nor receipt of Required Private Consents with respect to either
      the Third Party Software Licenses or the Dormant Master Agreements shall
      be conditions to Closing.

            (c) The Williams Companies, Inc. and Williams Holdings of Delaware,
      Inc. shall have been unconditionally released, subject only to Closing,
      from all Williams Guaranties and other Business Guaranties (but only to
      the extent the Business Guaranties relate to the Assumed Liabilities).

            (d) There shall be no Action, pending or threatened by any third
      party (including any Governmental Body) and no judgment shall have been
      entered and not vacated by any Governmental Body of competent jurisdiction
      in any Governmental Action or other Action, arising therefrom, which seeks
      to (i) enjoin, restrain, make illegal,

                                       21
<PAGE>

      or prohibit consummation of the transaction contemplated by this Agreement
      or (ii) prohibit or limit the Buyer's ownership or performance of any
      portion of the Purchased Assets.

            (e) The Buyer shall have made or stand willing and able to make all
      of the deliveries to the Seller set forth in Section 7.3.

            (f) A duly authorized officer of the Buyer shall have certified the
      satisfaction of the paragraph (a) of this Section 6.2.

            (g) The Secretary of the Buyer shall have executed a certificate
      substantially in the form attached hereto as Exhibit 6.2(g).

                                    ARTICLE 7
                                     CLOSING

      7.1 Closing. The Closing shall take place on the Closing Date at the
Buyer's offices in Houston, Texas, or at such other location as may be
designated by the Parties.

      7.2 Seller's Deliveries. On the Closing Date, the Seller shall deliver or
cause to be delivered to the Buyer the following:

            (a) A certificate of good standing from the Secretaries of State of
      the States of Delaware and Oklahoma stating that the Seller is a validly
      existing corporation in good standing and qualified to do business as a
      foreign corporation, as applicable;

            (b) A duly executed Bill of Sale;

            (c) Duly executed Novation Agreements or Assignment and Assumption
      Agreements for each Assumed Contract to be conveyed at Closing;

            (d) Duly executed Transition Services Agreement and Facility License
      Agreement;

            (e) The certificates described in Section 6.1(d) and Section 6.1(f);

            (f) To the extent not previously delivered, originals or true and
      correct copies of all Assumed Contracts and originals or true and correct
      copies of all Books and Records;

            (g) A duly executed Intellectual Property License and Assignment
      Agreement;

            (h) A duly executed TRS Agreement (if any shall be required pursuant
      to Section 5.2(c)); and

                                       22
<PAGE>

            (i) The Preliminary Statement (if not already delivered) and such
      other documents and instruments as shall be reasonably necessary to effect
      the intent of this Agreement and consummation of the transaction
      contemplated hereby.

      7.3 Buyer's Deliveries. On the Closing Date, the Buyer shall deliver or
cause to be delivered to the Seller the following:

            (a) The Initial Purchase Price payable by wire transfer of
      immediately available funds to such bank account pursuant to written
      instructions of the Seller delivered to the Buyer prior to the Closing
      Date;

            (b) A certificate of good standing from the Secretaries of State of
      Delaware stating that the Buyer is a validly existing limited partnership
      in good standing;

            (c) A duly executed Bill of Sale;

            (d) Duly executed Novation Agreements or Assignment and Assumption
      Agreements for each Assumed Contract to be conveyed at Closing;

            (e) Duly executed Transition Services Agreement and Facility License
      Agreement;

            (f) The certificates described in Section 6.2(f) and Section 6.2(g);

            (g) A duly executed Intellectual Property License and Assignment
      Agreement;

            (h) A duly executed TRS Agreement (if any shall be required pursuant
      to Section 5.2(c)); and

            (i) Such other documents and instruments as shall be reasonably
      necessary to effect the intent of this Agreement and consummation of the
      transactions contemplated hereby.

                                    ARTICLE 8
                                 INDEMNIFICATION

      8.1 Limitation on and Survival of Representations and Warranties. All
representations and warranties contained in this Agreement, or in any agreements
or instruments executed in connection herewith or delivered pursuant hereto,
shall survive the Closing for a period of fifteen (15) months beginning on the
Closing Date, but not longer, except that the representations and warranties set
forth in (a) Sections 3.2 and 3.7 shall survive and (b) Section 3.11 shall
survive until the thirtieth (30th) day after the expiration of the applicable
statute of limitations relating thereto. Such representations and warranties
shall only be effective with respect to any breach or claim when notice of such
breach or claim shall have been given in writing to the other Party in breach or
against whom indemnification is sought within such period. Any claim for
indemnification for which written notice has been given within the

                                       23
<PAGE>

prescribed period may be prosecuted to conclusion notwithstanding the subsequent
expiration of such period.

      8.2 Indemnification by the Seller.

            (a) Subject to the limitations set forth in this ARTICLE 8, the
      Seller hereby agrees to indemnify and hold the Buyer and its directors,
      officers, employees and Affiliates (collectively, the "Buyer Indemnified
      Parties") harmless from and against any and all claims, demands, suits,
      proceedings, judgments, losses, liabilities, damages, costs and expenses
      (including, but not limited to, reasonable attorneys' fees) (collectively,
      "Losses") imposed upon or incurred by the Buyer Indemnified Parties (any
      claims for such Losses by a Buyer Indemnified Party, a "Buyer Claim") as a
      result of or in connection with any of the following:

                  (i) any inaccuracy or breach of a representation or warranty
            made by the Seller in this Agreement or in any agreement or
            instrument executed in connection herewith or pursuant hereto (and
            for purposes of determining the accuracy of any such representation
            and warranty and the Losses attributable thereto, all materiality
            and Material Adverse Effect qualifiers set forth therein shall be
            disregarded);

                  (ii) the breach of, or default in the performance by the
            Seller of, any covenant, agreement or obligation to be performed by
            the Seller pursuant to this Agreement or any agreement or instrument
            delivered pursuant to Section 7.2(b), Section 7.2(c), or Section
            7.2(g); and

                  (iii) any Retained Liabilities.

            (b) Promptly after receipt by a Buyer Indemnified Party of notice of
      an Action or other event giving rise to a Buyer Claim with respect to
      which the Buyer Indemnified Party is entitled to indemnification under
      this Section 8.2, the Buyer Indemnified Party receiving such notice shall
      notify (the "Buyer Claim Notice") the Seller in writing of the
      commencement of such Action or the assertion of such Buyer Claim;
      provided, however, that failure to give such notice shall not affect the
      right to indemnification hereunder except to the extent of actual
      prejudice to the Seller. The Seller shall have the option, and shall
      notify the Buyer Indemnified Party in writing within thirty (30) Business
      Days after the date of the Buyer Claim Notice of its election, either: (i)
      to participate (at the expense of the Seller) in the defense of such
      Action or Buyer Claim (in which case the defense of such Action or Buyer
      Claim shall be controlled by the Buyer) or (ii) to take charge of and
      control the defense of such Action or Buyer Claim (at the expense of the
      Seller). If the Seller elects to control the defense, it will not
      compromise or settle the Action or Buyer Claim absent each Buyer
      Indemnified Party's written consent, which may be granted or denied in
      such Party's reasonable discretion, if (A) the amount to be paid in
      settlement exceeds the Maximum Indemnity Amount or (B) the settlement does
      not include a provision reasonably satisfactory to the Buyer Indemnified
      Party releasing the Buyer Indemnified Party from all liabilities with
      respect thereto. If the Seller fails to notify the Buyer Indemnified Party
      of its election within the applicable response period, then the

                                       24
<PAGE>

      Seller shall be deemed to have elected not to control the defense of such
      Action or Buyer Claim. If the Seller elects to control the defense of any
      Action or Buyer Claim, the Buyer Indemnified Party shall have the right to
      employ separate counsel and participate in the defense of such Action or
      Buyer Claim, but the fees and expenses of such counsel shall be at the
      expense of the Buyer Indemnified Party unless: (1) the named parties in
      such Action or Buyer Claim (including any impleaded parties) include both
      the Buyer Indemnified Party and the Seller and the Buyer Indemnified Party
      shall have been advised by such counsel that there may be one or more
      legal defenses available to it that are different from or additional to
      those available to the Seller, or (2) the Buyer Indemnified Party has
      reasonably determined that Losses that may be incurred may exceed either
      individually, or when aggregated with other Buyer Claims, the Maximum
      Indemnity Amount (in which case, the Seller shall not have the right to
      control the defense of such Action or Buyer Claim on behalf of the Buyer
      Indemnified Party, it being understood, however, that the Seller shall
      not, in connection with such Action or Buyer Claim, be liable for the fees
      and expenses of more than one (1) separate firm of attorneys (in addition
      to any local counsel) and that all such fees and expenses shall be
      reimbursed as they are incurred).

            (c) If the Seller does not control the defense of any Action or
      Buyer Claim, then the Buyer Indemnified Party may settle such Action or
      Buyer Claim with the written consent of the Seller (not to be unreasonably
      withheld).

      8.3 Indemnification by the Buyer.

            (a) Subject to the limitations set forth in this ARTICLE 8, the
      Buyer hereby agrees to indemnify and hold the Seller and its directors,
      officers, employees, and Affiliates (collectively, the "Seller Indemnified
      Parties") harmless from and against any and all Losses imposed upon or
      incurred by the Seller Indemnified Parties (any claim for such Losses by a
      Seller Indemnified Party, a "Seller Claim") as a result of or in
      connection with any of the following:

                  (i) any inaccuracy or breach of a representation or warranty
            made by the Buyer in this Agreement or in any agreement or
            instrument executed in connection herewith or pursuant hereto;

                  (ii) the breach of or default in the performance by the Buyer
            of any covenant, agreement or obligation to be performed by the
            Buyer pursuant to this Agreement or any agreement or instrument
            delivered pursuant to Section 7.3(c), Section 7.3(d), or Section
            7.3(g); and

                  (iii) any Assumed Liabilities or a breach or default in the
            performance by the Buyer of its obligations under Section 5.3.

            (b) Promptly after receipt by a Seller Indemnified Party of notice
      of an Action or other event giving rise to a Seller Claim with respect to
      which the Seller Indemnified Party is entitled to indemnification under
      this Section 8.3, the Seller Indemnified Party receiving such notice shall
      notify (the "Seller Claim Notice") the Buyer in writing of the

                                       25
<PAGE>

      commencement of such Action or the assertion of such Seller Claim;
      provided, however, that failure to give such notice shall not affect the
      right to indemnification hereunder except to the extent of actual
      prejudice to the Buyer. The Buyer shall have the option, and shall notify
      each Seller Indemnified Party in writing within thirty (30) Business Days
      after the date of the Seller Claim Notice of its election, either: (i) to
      participate (at the expense of the Buyer) in the defense of the Action or
      Seller Claim (in which case the defense of such Action or Seller Claim
      shall be controlled by the Seller) or (ii) to take charge of and control
      defense of such Action or Seller Claim (at the expense of the Buyer). If
      the Buyer fails to notify the Seller Indemnified Party of its election
      within the applicable response period, then the Buyer shall be deemed to
      have elected not to control the defense of such Action or Seller Claim. If
      the Buyer elects to control the defense of any Action or Seller Claim, the
      Seller Indemnified Party shall have the right to employ separate counsel
      and participate in the defense of any such Action or Seller Claim, but the
      fees and expenses of such counsel shall be at the expense of the Seller
      Indemnified Party unless the named parties in such Action or Seller Claim
      (including any impleaded parties) include both the Seller Indemnified
      Party and the Buyer and the Seller Indemnified Party shall have been
      advised by such counsel that there may be one or more legal defenses
      available to it that are different from or additional to those available
      to the Buyer (in which case, the Buyer shall not have the right to control
      the defense of such Action or Seller Claim on behalf of the Seller
      Indemnified Party, it being understood, however, that the Buyer shall not,
      in connection with such Action or Seller Claim be liable for the fees and
      expenses of more than one (1) separate firm of attorneys (in addition to
      any local counsel) and that such fees and expenses shall be reimbursed as
      they are incurred).

            (c) If the Buyer does not control the defense of any Action or
      Seller Claim, then the Seller Indemnified Party may settle such Action or
      Seller Claim with the written consent of the Buyer (not to be unreasonably
      withheld).

      8.4 Limitation of Liability. Notwithstanding the foregoing, the Seller
shall not be obligated to indemnify the Buyer Indemnified Parties pursuant to
Section 8.2(a)(i) or Section 8.2(a)(ii) except to the extent the amount of all
Losses incurred by the Buyer Indemnified Parties thereunder exceeds Five Million
Dollars ($5,000,000.00) in the aggregate (the "Deductible"), in which event the
Buyer may recover all Losses incurred in excess of the Deductible and (net of
insurance proceeds or other compensatory reimbursement from third parties
actually received less expenses incurred in connection therewith) the Seller's
maximum liability for Losses under Section 8.2(a)(i) or Section 8.2(a)(ii) shall
be Two Hundred Fifty Six Million Dollars ($256,000,000.00) (the "Maximum
Indemnity Amount"); provided, however, that for Losses incurred by the Buyer
Indemnified Parties for breaches of the representations and warranties in
Sections 3.2 and 3.7, the Seller's maximum liability shall be the Purchase
Price.

      8.5 Sole and Exclusive Remedy. If the Closing occurs, the indemnification
provisions of this ARTICLE 8 shall be the sole and exclusive remedy of each
Party (including the Seller Indemnified Parties and the Buyer Indemnified
Parties) (a) for any breach of the other Party's representations, warranties,
covenants, or agreements contained in this Agreement or (b) otherwise with
respect to this Agreement, the agreements and instruments executed in connection
herewith, the Purchased Assets, or the transactions contemplated hereby.

                                       26
<PAGE>

                                    ARTICLE 9
                                   TERMINATION

      9.1 Termination. This Agreement may be terminated, and the transactions
contemplated hereby may be abandoned, as follows:

            (a) at any time before the Closing, by either Party, by written
      notice from one Party to the other Party, if any Law or final order
      restrains, enjoins or otherwise prohibits or makes illegal the
      transactions contemplated pursuant to this Agreement;

            (b) at any time before the Closing, by either Party, by written
      notice from one Party to the other, if such other Party has materially
      breached its representations or warranties or its obligations hereunder
      and such breach (other than a breach of the Buyer's obligation to pay the
      Purchase Price in accordance with the terms of ARTICLE 2, which for
      purposes of clarification shall have no cure period, and other than with
      respect to Sections 3.2 and 3.7 to which no materiality qualifier shall
      apply) has not been cured within thirty (30) days following written
      notification thereof;

            (c) on and after December 31, 2007, by either Party, by written
      notice from one Party to the other, if the Closing has not occurred by
      such date, unless the Parties mutually agree in writing (i) to extend the
      period in which such Closing must occur or (ii) to waive or amend the
      provisions of this Section 9.1(c); provided that the failure of the
      Closing to occur by such date is not the result of a breach of this
      Agreement by the Party seeking to terminate; or

            (d) by mutual written consent of the Parties.

      9.2 Effect of Termination. If this Agreement is validly terminated
pursuant to Section 9.1(a) or 9.2(c), notwithstanding anything in this Agreement
to the contrary, there will be no liability or obligation on the part of the
Seller or the Buyer (or any of their respective Representatives or Affiliates),
provided that (a) Sections 11.1, 11.2, 11.3, 11.5 through 11.8, inclusive, and
11.12 through 11.19, inclusive, will survive any such termination and (b) each
Party shall continue to be liable for any breach of this Agreement by it
occurring prior to such termination.

                                   ARTICLE 10
                          TAXES AND FURTHER ASSURANCES

      10.1 Transfer Taxes. The Buyer shall pay all transfer, sales, recording
and similar Taxes arising in connection with the transactions contemplated
hereunder, whether such Taxes are imposed on the Seller or the Buyer. The
Parties shall cooperate to comply with all requirements for such Taxes and shall
provide such documentation and take such other actions as may be necessary to
minimize the amount of any such Taxes.

      10.2 Allocation of Purchase Price. The Parties will use their commercially
reasonable efforts to agree upon the allocation of the Purchase Price for Tax
purposes. In the event the Parties are unable to so agree, each Party shall be
free to make its own allocation of the Purchase Price.

                                       27
<PAGE>

      10.3 Further Assurances. At any time and from time to time at or after the
Closing, at any Party's request and without further consideration, the Parties
agree to cooperate with each other, to execute and deliver such other documents,
instruments of transfer or assignment, files, books and records and do all such
further acts and things as may be reasonably required to carry out the
transactions contemplated hereby.

                                   ARTICLE 11
                                  MISCELLANEOUS

      11.1 Entire Agreement; Amendment. This Agreement and the documents
referred to herein to be delivered pursuant hereto constitute the entire
agreement between the Parties pertaining to the subject matter hereof, and
supersede all prior and contemporaneous agreements, understandings, negotiations
and discussions of the Parties, whether oral or written, and there are no
warranties, representations or other agreements between the Parties in
connection with the subject matter hereof, except as specifically set forth
herein or therein. No amendment, supplement, modification or termination of this
Agreement shall be binding unless executed in writing by the Party to be bound
thereby. No waiver of any of the provisions of this Agreement shall be deemed or
shall constitute a waiver of any other provision of this Agreement, whether or
not similar, nor shall such waiver constitute a continuing waiver unless
otherwise expressly provided.

      11.2 Expenses. Except as specifically set forth herein, each of the
Parties shall pay the fees and expenses of their respective counsel, accountants
and other experts and the other expenses incident to the negotiation and
preparation of this Agreement and consummation of the transactions contemplated
hereby.

      11.3 Governing Law; Jurisdiction. This Agreement shall be construed and
interpreted according to the laws of the State of New York, without regard to
the conflicts of law rules thereof.

      11.4 Assignment. This Agreement and each Party's respective rights
hereunder may not be assigned, by operation of Law, change of control, or
otherwise, without the prior written consent of the other Party, which consent
may be withheld in the discretion of such other Party. Notwithstanding the
foregoing, the Buyer shall have the right to designate one or more Affiliates to
take title to and/or assume any or all of the Purchased Assets at Closing, but
the Buyer shall remain liable to the Seller hereunder notwithstanding any such
delegation.

      11.5 Notices. All communications, notices and disclosures required or
permitted by this Agreement shall be in writing and shall be deemed to have been
given at the earlier of the date (a) when delivered personally or by messenger
or by overnight delivery service by a recognized commercial carrier, (b) five
(5) days after being mailed by registered or certified United States mail,
postage prepaid, return receipt requested, or (c) when received via telecopy,
telex, facsimile or other electronic transmission, in all cases addressed to the
Person for whom it is intended at his address set forth below or to such other
address as a Party shall have designated by notice in writing to the other Party
in the manner provided by this Section 11.5:

            If to the Buyer:            Bear Energy LP

                                       28
<PAGE>

                                        700 Louisiana Street, Suite 1000
                                        Houston, TX  77002
                                        Phone:  713.236.3000
                                        Fax:  713.236.5000
                                        Attention:  President

            With a copy to:             Bear Energy LP
                                        700 Louisiana Street, Suite 1000
                                        Houston, TX  77002
                                        Phone:  713.236.3000
                                        Fax:  713.236.5000
                                        Attention:  Legal Department

            If to the Seller:           Williams Power Company, Inc.
                                        One Williams Center, WRC 2
                                        Tulsa, OK  74172
                                        Phone:  918.573.2000
                                        Fax:  918.573.1717
                                        Attention:  Chief Financial Officer

            With a copy to:             The Williams Companies, Inc.
                                        One Williams Center, Suite 4900
                                        Tulsa, OK  74172
                                        Phone:  918.573.2000
                                        Fax:  918.573.5942
                                        Attention:  General Counsel

      11.6 Counterparts; Headings. This Agreement may be executed in several
counterparts, each of which shall be deemed an original, but such counterparts
shall together constitute but one and the same agreement. The headings in this
Agreement are inserted for convenience of reference only and shall not
constitute a part, or impact the interpretation, hereof.

      11.7 Interpretation. Unless the context requires otherwise, all words used
in this Agreement in the singular number shall extend to and include the plural,
all words in the plural number shall extend to and include the singular and all
words in any gender shall extend to and include all genders. All references to
contracts, agreements, leases or other understandings or arrangements shall
refer to oral as well as written matters. This Agreement has been negotiated
between the Parties and shall not be read in a light more favorable to one Party
relative to the other.

      11.8 Schedules and Exhibits. Disclosure of any fact or item in any
Schedule or Exhibit hereto referenced by a particular paragraph or Section in
this Agreement shall, should the existence of the fact or item or its contents
be relevant to any other paragraph or Section, be deemed to be disclosed with
respect to that other paragraph or Section whether or not an explicit
cross-reference appears.

                                       29
<PAGE>

      11.9 Supplement to Schedules.

            (a) The Seller may, from time to time prior to the Closing by
      written notice to the Buyer, supplement or amend the Schedules to this
      Agreement, provided that, for purposes of determining whether Buyer's
      condition set forth in Section 6.1 has been fulfilled, the Schedules
      (except Schedule A and Schedule 5.3, each of which shall be amended and
      supplemented only as provided in Section 11.9(b)) shall be deemed to
      include only that information contained therein on the date of this
      Agreement and shall be deemed to exclude all information contained in any
      supplement or amendment thereto. .

            (b) Not earlier than ten (10) Business Days and no later than three
      (3) Business Days prior to the Closing, the Seller shall, by written
      notice to the Buyer, supplement or amend Schedule A and Schedule 5.3 to
      reflect all activity since April 1, 2007 related to the Assumed Contracts.

            (c) If the Closing shall occur, then any matters disclosed to Buyer
      pursuant to any supplement or amendment at or prior to the Closing shall
      be deemed to be waived by Buyer and Buyer shall not be entitled to make a
      claim thereon under this Agreement.

      11.10 Closing Over Breaches or Unsatisfied Conditions. Notwithstanding
anything to the contrary contained in this Agreement, if the Seller or the Buyer
elects to proceed with the Closing, and any failure of any condition in its
favor to be satisfied or the breach of any representation, warranty or covenant
by the other Party is within the Knowledge of the Buyer or the Knowledge of the
Seller, as applicable, the condition that is unsatisfied, or the representation,
warranty or covenant that is breached, at the Closing Date will be deemed waived
by such Party, and such Party will be deemed to fully release and forever
discharge the other Party on account of any and all claims, demands or charges,
known or unknown, with respect to the same.

      11.11 Occasional and Bulk Sales Law. The Buyer and the Seller each agree
to waive compliance by the other with the provisions of the Bulk Sales Law of
any jurisdiction.

      11.12 Disclaimers.

            (a) Buyer's Review. The Buyer has reviewed and has access to all
      documents, records and information which it has desired to review in
      connection with its decision to enter into this Agreement, and to
      consummate the transactions contemplated hereby. The Buyer has not relied
      upon any representation, warranty, statement, advice, document,
      projection, or other information of any type provided by the Seller, its
      Affiliates, or any of their representatives, except for those expressly
      set forth in this Agreement. In deciding to enter into this Agreement, and
      to consummate the transactions contemplated hereby, the Buyer has relied
      solely upon its own knowledge, investigation, and analysis (and that of
      its representatives) of the Purchased Assets and the Business and not on
      any disclosure or representation made by, or any duty to disclose on the
      part of, the Seller, its Affiliates, or any of their representatives,
      other than the representations and warranties of the Seller expressly set
      forth herein.

            (b) Information. Except as provided in ARTICLE 3, the Seller makes
      no representation or warranty, express, implied, at common law, statutory
      or otherwise, with

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<PAGE>

      respect to the accuracy or completeness of the information, records, and
      data now, heretofore, or hereafter made available to the Buyer in
      connection with this Agreement (including any description of the Business
      or the Purchased Assets, revenue, price and expense assumptions, price
      forecasts, or any other information furnished to the Buyer by the Seller
      or any Affiliate of the Seller or any director, officer, employee,
      counsel, agent, or advisor thereof).

            (c) Purchased Assets. Notwithstanding anything contained to the
      contrary in any other provision of this Agreement, it is the explicit
      intent of each Party that the Seller and its Affiliates are not making any
      representation or warranty whatsoever, express, implied, at common law,
      statutory or otherwise, except for the representations or warranties given
      in this Agreement, and it is understood that the Buyer, with such
      exceptions, takes the Purchased Assets "as is" and "where is". Without
      limiting the generality of the immediately preceding sentence, except as
      provided in this Agreement, the Seller hereby expressly disclaims and
      negates any representation or warranty, express or implied, at common law,
      statutory, or otherwise, relating to (i) the condition of the Purchased
      Assets (including any implied or express warranty of merchantability or
      fitness for a particular purpose, or of conformity to models or samples of
      materials), or (ii) any infringement by the Seller, or any of its
      Affiliates of any patent or proprietary right of any third party. The
      Buyer has agreed not to rely on any representation made by the Seller with
      respect to the condition, quality, or state of the Purchased Assets except
      for those in this Agreement, but rather, as a significant portion of the
      consideration given to the Seller for this purchase and sale, has agreed
      to rely solely and exclusively upon its own evaluation of the Purchased
      Assets, except as provided herein. The provisions contained in this
      Agreement are the result of extensive negotiations between the Buyer and
      the Seller and not other assurances, representations or warranties about
      the quality, condition, or state of the Purchased Assets were made by the
      Seller in the inducement thereof, except as provided herein.

            (d) Waiver of Damages. Notwithstanding anything contained to the
      contrary in this Agreement, the Seller and the Buyer agree that the
      recovery by either Party of any damages suffered or incurred by it as a
      result of any breach by the other Party of any of its obligations under
      this Agreement shall be limited to the actual damages suffered or incurred
      by the non-breaching Party as a result of the breach by the breaching
      Party of its obligations hereunder and in no event shall the breaching
      Party be liable to the non-breaching Party for any indirect,
      consequential, special, exemplary, or punitive damages (including any
      damages on account of lost profits or opportunities or lost or delayed
      generation) suffered or incurred by the non-breaching Party as a result of
      the breach by the breaching Party of any of its obligations hereunder;
      provided, however, that the foregoing shall not be considered a waiver of
      cover damages.

      11.13 Severability. If any provision, clause or part of this Agreement, or
the application thereof under certain circumstances, is held invalid, the
remainder of this Agreement, or the application of such provision, clause or
part under other circumstances, shall not be affected thereby.

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<PAGE>

      11.14 No Reliance. No third party is entitled to rely on any of the
representations, warranties and agreements contained in this Agreement. The
Buyer and the Seller assume no liability to any third party because of any
reliance on the representations, warranties and agreements of the Buyer or the
Seller contained in this Agreement.

      11.15 Agreement for the Parties' Benefit. Except for the provisions of
Section 5.3 which is also intended to benefit and to be enforceable by any
Affiliate of the Seller that is obligated under one or more of the Business
Guaranties, and the provisions of ARTICLE 8, which are also intended to benefit
and to be enforceable by any of the Buyer Indemnified Parties and the Seller
Indemnified Parties, this Agreement is not intended to confer upon any Person
not a Party any rights or remedies hereunder, and no Person other than the
Parties or such Persons described above is entitled to rely on any
representation, warranty or covenant contained herein.

      11.16 Non-Waiver. No waiver by either Party hereto of any one or more
defaults by the other in performance of any of the provisions of this Agreement
shall be construed as a waiver of any other default or defaults, whether of a
like kind or different nature.

      11.17 Public Announcements. Except pursuant to a Requirement of Law or the
rules of a national securities exchange applicable to the Buyer, the Seller or
their respective Affiliates, neither Party hereto may make any public
announcements regarding this Agreement or the subject matter hereof without the
prior written consent of the other Party. Notwithstanding the foregoing,
following the execution of this Agreement, the Parties shall cooperate in
issuing public announcements regarding the transactions described herein,
including the Purchase Price, with such announcement to be released within five
(5) Business Days or on an earlier date agreed to by the Parties.

      11.18 Confidentiality.

            (a) This Agreement is confidential and, except pursuant to a
      Requirement of Law or the rules of a national securities exchange
      applicable to the Buyer, the Seller or their respective Affiliates,
      neither the fact that the Parties have entered into this Agreement, nor
      any of the terms and conditions herein, may be disclosed to a third party
      without the other Party's prior written consent, except that either Party
      may disclose this Agreement and its contents to its financial, accounting,
      engineering and legal advisors who have a need to know such information
      and who agree to maintain its confidentiality.

            (b) From and after the Closing, the Seller shall, and shall cause
      their respective Affiliates to, keep confidential and not disclose all
      information relating to the Purchased Assets (the "Restricted
      Information"), and shall not directly or indirectly use such Restricted
      Information for any purpose, except as and to the extent permitted by the
      terms of this Agreement or the Ancillary Agreements. The confidentiality
      obligation set forth in this Section shall not apply to any information
      that (i) is in the public domain, (ii) is published or otherwise becomes
      part of the public domain through no fault of the Seller or any of its
      Affiliates or (iii) becomes available to the Seller or any of its
      Affiliates on a non-confidential basis from a source that did not acquire
      such information (directly or indirectly) from the Seller or the Buyer or
      any of their respective Affiliates on a confidential basis.
      Notwithstanding the foregoing, the Seller may make disclosures

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      required by Law and in connection with disputes hereunder; provided,
      however, that the Seller, to the extent practicable, shall provide the
      Buyer with prompt notice thereof so that the Buyer may seek a protective
      order or other appropriate remedy or waive compliance with the provisions
      of this Section 11.18. In the event that such protective order or other
      remedy is not obtained or the Buyer waives compliance with the provisions
      of this Section 11.18, the Seller shall or shall cause the Person required
      to disclose such Restricted Information to furnish only that portion of
      the information that such Person is legally required, and, to the extent
      practicable, the Seller shall exercise commercially reasonable efforts to
      obtain reliable assurance that confidential treatment is accorded the
      Restricted Information so furnished. The Seller's confidentiality
      obligations under this Section shall continue for (5) years from the date
      hereof; provided that, with respect to Restricted Information relating to
      any Assumed Contract, such obligation shall terminate on a date that is
      the later of (A) the end of such five (5) year period and (B) the date of
      termination of such Assumed Contract.

            (c) From and after the Closing, any restrictions contained herein or
      in the Confidentiality Agreement dated December 22, 2006 among the Buyer,
      the Seller and The Williams Companies, Inc., as amended, relating to the
      Buyer's use or disclosure of any Restricted Information shall be null and
      void.

      11.19 WAIVER OF JURY TRIAL. THE SELLER AND THE BUYER EACH HEREBY
IRREVOCABLY WAIVES TRIAL BY JURY IN ANY ACTION OR PROCEEDING WITH RESPECT TO
THIS AGREEMENT OR ANY ANCILLARY AGREEMENT.

      11.20 Post Closing Obligations.

            (a) At any time or from time to time after the Closing, each Party
      will, upon the reasonable request of the other Party, execute and deliver
      any further instruments or documents, and exercise commercially reasonable
      efforts to take such further actions as may reasonably be required, to
      fulfill and implement the terms of this Agreement or realize the benefits
      intended to be afforded hereby. In addition, at any time or from time to
      time after the Closing, each Party will cooperate reasonably with the
      other Party (and the other Party's counsel, as applicable) and make
      available their personnel, and provide such testimony and access to their
      books and records as shall be reasonably requested, (i) in connection with
      the contest or defense against any action, suit, proceeding, hearing,
      investigation, charge, complaint, claim, or demand in connection with (A)
      any transaction contemplated under this Agreement or (B) any fact,
      situation, circumstances, status, condition, activity, practice, plan,
      occurrence, event, incident, action, failure to act, or transaction
      relating to the Purchased Assets (including during such period prior to
      Closing) or (ii) otherwise at the other Party's reasonable request in
      connection with any other matter arising and relating to the Purchased
      Assets, all at the reasonable out-of-pocket expense of the requesting
      Party (unless the requesting Party is entitled to indemnification therefor
      hereunder).

            (b) For a period of seven (7) years after the Closing Date, neither
      Party will dispose of any books, records, documents or information
      reasonably relating to the

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<PAGE>

      Purchased Assets without first giving notice to the other Party thereof
      and permitting the other Party to retain or copy such books and records as
      it may select. During such period, each Party will permit the other Party
      to examine and make copies, at the other Party's expense, of such books,
      records, documents and information for any reasonable purpose, including
      any litigation now pending or hereafter commenced against the Party or its
      Affiliates, or the preparation of income or other tax returns; provided,
      however, that all such examinations by the other Party shall occur and all
      such access shall be provided to a Party at times and places reasonably
      set by the other Party.

      11.21 Survival. Subject to limitations in respect of representations and
warranties set forth in Section 8.1, all representations, warranties, covenants
and obligations in this Agreement, the Ancillary Agreements and any other
certificate or document delivered pursuant to this Agreement shall survive the
Closing and the consummation of the transactions contemplated hereby.

                            [Signature Page Follows]

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<PAGE>

            IN WITNESS WHEREOF, each Party hereto has caused this Agreement to
be executed in its name by a duly authorized officer as of the day and year
first above written.

                                        BEAR ENERGY LP

                                        By:  /s/    Paul J. Posoli
                                           -------------------------------------
                                           Name:   Paul J. Posoli
                                           Title:  President


                                        WILLIAMS POWER COMPANY, INC.

                                        By:  /s/  Andrew D. Sunderman
                                           -------------------------------------
                                           Name:    Andrew D. Sunderman
                                           Title:   Vice President