Thanks for the draft.  Will circulate internally and respond.

Jim

 -----Original Message-----
From: 	"ROBERT LAMB" <LAMB@wrightlaw.com>@ENRON  
Sent:	Friday, October 12, 2001 2:02 PM
To:	glazec@pjm.com
Cc:	HARRISPG@charon.pjm.com; janderson@elcon.org; myacker@elcon.org; jsteffe@enron.com; dsalvosa@epsa.org; mbennett@epsa.org; drom@pjm.com; Cole Keith; Barry SPECTOR
Subject:	Draft revisions to the 9/6/01 Bingaman reliability provision

Enclosed is my draft of possible revisions to the above-referenced reliability provision, taking into
account suggestions by Craig. I have enclosed a redline version and a clean one. The revision does
the following:
1.By adding"without hindering reliable, non-discriminatory, and efficiently priced transmission service"
it uses words of art from FERC Order No. 2000 and shows the intertwined nature of security and commercial practices.
2.By adding the reference to section 201(f), it specifically includes  Federal and State entities.
3.There is no named reference for any particular industry  standards body---thus no attempt to either
provide an advantage or disadvantage to any existing body.
4.The FERC could take into consideration recommendations of enties with technical expertise regarding reliability standards---such as WECC , Regional Advisory Bodies, and the States.
5. FERC could assign enforcement responsibility in a given area to any appropriate entity---such as WECC or RTOs.
6.It puts in a definition of reliability standards that is limited to security and, by not including adequacy, is
not as intrusive on prerogatives of States.
7.I bracketed the possibility of a States savings provision for further consideration. Of course, the
narrower the scope---i.e. no consideration of generation adequacy---the less need there is for such
a provision.
Please give me any feedback.
Bobby

 - SEC 410 redline.doc << File: SEC 410 redline.doc >> 
 - SEC 410 clean3.doc << File: SEC 410 clean3.doc >>