Attached in Word format are the draft IEP comments, due to be filed on the 
22nd, regarding the FERC Staff Report on market monitoring and market power 
mitigation.  This is my suggested approach, which is obviously subject to 
change per our discussion during the call tomorrow.

I would like to highlight that the draft characterizes the approach as a 
"circuit breaker" during periods of highest demand and suggests that this is 
distinct from notions of market power abuse.  Other entities are arguing that 
during the highest demand, when it exceeds available supplies, all suppliers 
have and are "exercising" (as distinct from abusing?) market power.  The 
draft attempts to highlight the current regional supply context characterized 
by the drought as a rationale for the "emergency circuit breaker."

As mentioned in Katie Kaplan's email this morning, if your company has a 
draft of comments, we would appreciate an opportunity to look at them to 
avoid substantive conflicts.

I trust this is the right distribution list but I was not able to use the 
list from this morning's email because of computer problems at my end.  ABB

--
Andrew Brown
Sacramento, CA
abb@eslawfirm.com

 - DRAFT_010318_el00-95-012_IEP_Cmts_Staff_Rpt.doc