FYI
-----Original Message-----
From: Comnes, Alan 
Sent: Friday, November 09, 2001 12:26 PM
To: Steffes, James; Novosel, Sarah
Subject: FW: EPSA MBR Paper


FYI
-----Original Message-----
From: Neason, Judy [mailto:Judy.Neason@williams.com]
Sent: Friday, November 09, 2001 9:41 AM
To: 'Erin Perrigo'; fallonr@dsmo.com; mfgildea@duke-energy.com; Steve.Huntoon@dynegy.com; acomnes@enron.com; dennis.capella@exeloncorp.com; jeffrey.roark@mirant.com; jack.hawks@neg.pge.com; jadillon@pplweb.com
Cc: Julie Simon; Sheridan, Amy; Goldberg, Alex; Thuston, Tim
Subject: RE: EPSA MBR Paper




        Erin, 
        Thanks for the advance copy of the paper.  While there are a number of very good points made in the paper, Williams has a fundamental problem with EPSA endorsing a new market power test that is more stringent than we think is necessary.  We would recommend that EPSA support the Limited Competing Supplier Test, or perhaps simply take the position in option 5 (no test for bid-based markets operated by an ISO or RTO).  We simply believe that EPSA should not be "negotiating with itself" at this juncture.  That is, we should not assume that the majority of the Commissioners are with Massey.  We should use this paper to argue to the other Commissioners and staff that if they move off Hub and Spoke, they only need to move incrementally, not dramatically.  In making this recommendation we recognize that this may not be enough for FERC and we may not like what we end up with.  But Williams is simply not prepared to support a position we really don't agree with in the hope that we can avoid an even worse result.  I particularly recall Linda Breathitt's reservations about these issues (voiced at the meeting a month ago) and am hopeful that we can influence Wood and Brownell in this regard.

        The language that reiterates EPSA's position that FERC's primary focus should be on getting market design right is very well done.  Also the arguments on why it would be disastrous to condition our market based rate authority is well done and timely.

        We recognize that EPSA has been working on this issue for weeks now, but this is not a simple issue and we have needed this time to think it through.  We appreciate your efforts and believe this is an important issue for EPSA.   Thanks, Judy Neason

-----Original Message----- 
From: Erin Perrigo [ <mailto:EPerrigo@epsa.org>] 
Sent: Thursday, November 08, 2001 10:06 AM 
To: fallonr@dsmo.com; mfgildea@duke-energy.com; 
Steve.Huntoon@dynegy.com; acomnes@enron.com; 
dennis.capella@exeloncorp.com; jeffrey.roark@mirant.com; 
jack.hawks@neg.pge.com; jadillon@pplweb.com; Neason, Judy 
Cc: Julie Simon 
Subject: EPSA MBR Paper 


Attached is the last draft of the MBR paper from Boston Pacific.  We are not sending it to the entire group at this point - but would like provide those who have been most active an opportunity to see it one more time.  We'd like to have all comments by tomorrow, COB.

-Erin 

Erin N. Perrigo 
Manager of Policy 
Electric Power Supply Association 
1401 New York Ave., NW 
11th Floor 
Washington, DC  20005 
p)  202.628.8200 
f)   202.628.8260 
eperrigo@epsa.org