Rod - 
As you suggested, I put all your companies into one "portfolio" to treat them separately in our risk management policy.  The vast majority of verbiage in the policy is specifically relegated to the trading portfolio, but I'll be sure to walk you through it next week and highlight anything that addresses this portfolio.  These portfolios really just represent different buckets of risk:

1)	Trading Portfolio
2)	Merchant Portfolio
3)	Regulated Domestic Asset Portfolio
4)	Retail Portfolio
5)	Other Assets and Contracts Portfolio
6)	Capital Portfolio

Would you also help me think of a good name for this portfolio (#3)?  I'm struggling with it a bit - if I just say Transportation and Distribution, it's misleading because Elektro and related assets are excluded, if I add "Domestic" to the name, it wouldn't cover Wessex, etc..  Take a quick look at the descriptions of the portfolio categories below, and you'll see how I'm trying to capture the entire company, but carve your businesses out.

Another question - is it valid to distinguish trading activity included in Enron's DPR and that carried out - or to be carried out - by your businesses (PGE, ETS, EOTT), as all the activity in your companies is accrual accounting?  Or will some be marked to market?

Thank you,
Cassandra
x30429.
2.1	Mark-to-Market Trading Portfolio
The Company's Mark-to-Market Trading Portfolio (Trading Portfolio) is designed to capture and manage risks related to commodity sales and services, including the purchase, sale, marketing and delivery of energy and other commodities, to provide related risk management services, and to take advantage of market arbitrage opportunities and manage positions within the approved limits.  This Portfolio includes the Commodity Groups listed in Appendix ___, accounted for using a mark-to-market method.
2.2	Fair Value Merchant Portfolio
The Company's Fair Value Merchant Portfolio (Merchant Portfolio) is designed to capture and manage risks related to merchant investments in public and private companies, including the active management of embedded exposures, and to provide greater liquidity and transparency for the Company's merchant investment activities. This portfolio includes equity, "equity-like," debt and "debt-like" instruments in the public and private sector. 
2.3	Regulated Domestic Asset Portfolio
The  Regulated Domestic Asset Portfolio is designed to capture and manage risks related to the business activities of the Company's government regulated subsidiaries and affiliates (.e.g. pipelines and utilities).  While these subsidiaries and affiliates may engage in some activities similar to those in the Company's other Portfolios, their activities may have  specific accounting and legal and regulatory requirements that require separate application of risk management practices.
2.4	Retail Portfolio
The Company's Retail Portfolio is designed to capture and manage exposures inherent in the energy services business, particularly those related to credit, as it records the sale to or management of commodities on behalf of customers, and the provision of integrated outsourcing solutions   for energy management.
2.5	Other Assets and Contracts Portfolio
The Company's Other Assets and Contracts Portfolio is designed to capture and manage exposures and risks embedded in  assets and other investments, liabilities and contractual arrangements that are accounted for generally on an "accruals" basis or are not otherwise captured in the other Portfolios defined in this Policy.  This portfolio includes: 
operating assets throughout the Company's network of selective domestic and international asset ownership, 
ii) contracts that provide access to third-party assets and market-making activities, and 
iii) off-balance sheet or contingent contracts. 
2.6	Capital Portfolio
The Capital Portfolio is designed to capture and manage exposures inherent in positions and transactions involving Enron's own stock, issued debt and other funding transactions, or derivatives thereof, which may occur from time to time .