This is pretty big stuff and moving pretty quickly.  Understanding that times are crazy, and that it's a holiday week, if we could nonetheless begin discussing tomorrow, or even late today, that would be very useful.

Best,
Jeff

 -----Original Message-----
From: 	Steffes, James D.  
Sent:	Monday, November 19, 2001 11:18 AM
To:	Smith, Mike B; Dasovich, Jeff
Subject:	FW: Implementation of the Suspension Direct Access -- UDCs' Plan

Can we talk this week on our response?

Jim

 -----Original Message-----
From: 	JBennett <JBennett@GMSSR.com>@ENRON  
Sent:	Monday, November 19, 2001 11:11 AM
To:	Jeff Dasovich (E-mail); Jim Steffes (E-mail); Sue Mara (E-mail)
Cc:	MDay
Subject:	Implementation of the Suspension Direct Access -- UDCs' Plan

On Friday, November 16th, the UDCs submitted their joint plan for
implementing the suspension of direct access.  Parties have until,
Wednesday, November 28th, to comment.

The following are proposed implementation rules for which the UDCs seek
Commission approval:

1.  A  DASR can only be processed if the customer name appears on the ESP
List submitted to the UDCs on October 5, 2001.

2. In order to submit an ESP List the ESP must have a valid ESP/UDC Service
Agreement as of September 20, 2001 and , for ESPs serving small customers,
they must have in effect a valid Commission registration as of September 20,
2001.

3. For a DASR to be processed for a residential or small commercial customer
account, the ESP must be able to demonstrate that the required third party
verification took place prior to September 20, 2001.

4.  Customers should not be allowed to switch from one ESP to another after
September 20 unless the new ESP had a valid ESP- customer contract in place
on or before Sept. 20th.

5.  Seamless moves within a UDC's service territory will be allowed.

6. For customers on bundled service as of September 20, 2001 (but still
under a DA contract), the UDCs are proposing not to allow such customers to
process DASRs even if their names are on the October 5 list.


7.  If all  accounts of one ESP transferred to another as a result of a
merger, then the situation is okay because no new DASR would be required;
requests for one customer to switch from one ESP to another only allowed if
the new ESP-customer relationship had a contract prior to Sept. 20, 2001.

8. Changes in customer identity allowed on  case by case basis (e.g., if a
customer changes its type of business it would not be allowed).

9. One  customer can not transfer or assign its direct access service rights
to another.

10.  Processing of DASRs submitted for customers who attempt to opt into a
community aggregation program after the suspension date should not be
allowed.

In addition to the above, the UDCs proposed three additional options for
implementing the suspension.

1.  The Commission should impose a DASR cut-off date (received and
accepted).

2.  If the Commission does not impose a strict DASR cut off, it should
require that any ESP which wishes to have a DASR processed after the cut off
to submit their account specific DASR information and ESP contract to the
Commission along with an explanation of why the customer is eligible to
receive DA.  The UDC will not process the DASR until it receives an okay
from the Commission.

3.  The ESP certifies through an affidavit that a particular DASR was
associated with a contract in existence on September 20, 2001 (the UDCs set
forth a proposed affidavit.)

If you have any questions, please call

Jeanne