Attached is the final draft of this paper for comment.  It incorporates the comments of those who responded but there is time for further redrafting.  However, given the filing deadline (Wednesday) further changes are likely to be wordsmithing unless someone vehemently objects to the structure.

regards
Mike ext. 57634

PS.  There were no objections to my thoughts on structure so we have concentrated on the rationale supporting RTO's and effective spot markets as mechanisms that achieve the goals of ICAP (i.e A spot market is Enrons solution).  We then state that if others have different views, any resulting separate iCap proposal if implemented should be interim in nature and minimise spot market distortions.  Finally we attach a simple interim solution as an appendix (so it does not detract from our main argument structure) so that if there is an ongoing debate we will be able to take part...