Recently, the CAISO filed Amendment 31 to its  tariff.? Amendment 31 asks 
FERC to grant authority to the CAISO to remove  the existing sunset date for 
its purchase price cap authority, thereby  essentially granting to the CAISO 
the authority to set the price cap and  determine its duration.? Attached is 
a memo from Ellison & Schneider  which addresses the amendment.
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While IEP does not believe that contesting the  authority of the CAISO to 
impose price caps makes sense, we have concerns that  the CAISO Amendment 31 
fails to provide any transparent, objective critieria for  determining if, 
when, and where purchaser price caps would be removed.?  This concern is one 
we have raised orally and in writing to the CAISO as part of  its Congestion 
Reform/Market Redesign Project.? As noted in the Ellison  & Schneider memo, 
this is an important issue which needs to be addressed in  order to provide a 
"roadmap" to market participants as to if, when, and where  price cap 
authority may be removed.
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As we noted in our previous email related to CAISO  Amendment #30, IEP's 
Restructuring/Transmission Special Fund is essentially  depleted.? We are 
interested in determining whether the membership wishes  us to proceed with 
developing comments on CAISO Amendment #31 addressing the  points raised in 
the Ellison & Schneider memo.? Equally important, we  are interested in 
determining whether sufficient funding support exists to  accomplish this 
outcome.? Responses to the CAISO Amendment #31 filing are  due October 2.
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If you are interested in funding IEP's effort in  this regard, please let me 
know by responding to this email ASAP.?  Thanks.
 - 000920_IEP_mmo_CAISO_Amnd_31.doc