Scott, what is our emissions strategy for these counterparties?

Regards
Delainey
---------------------- Forwarded by David W Delainey/HOU/ECT on 05/15/2000 
09:51 AM ---------------------------
   
	Enron North America Corp.
	
	From:  Jeffrey Keeler @ ENRON                           05/15/2000 08:13 AM
	

To: Michael Terraso/OTS/Enron@ENRON, Marc Phillips/OTS/Enron@ENRON, Mary 
Schoen/HOU/EES@EES, Stacey Bolton/HOU/EES@EES, Susan 
Worthen/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Henry 
Van/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Gus Eghneim/Corp/Enron@Enron, David 
Ronkainen/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Donnie 
Willmann/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Robert N 
Moss/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Frank Smith/Corp/Enron@ENRON, David 
Nutt/Corp/Enron@ENRON, Bruce N Stram/HOU/EES@EES, Peggy Mahoney/HOU/EES@EES, 
Heather Mitchell/HOU/EES@EES, Sean A Holmes/HOU/EES@EES, John 
Shafer/OTS/Enron@Enron, William Kendrick/OTS/Enron@ENRON, Louis 
Soldano/ET&S/Enron@ENRON, Bret Reich/ET&S/Enron@ENRON, Kevin M 
Presto/HOU/ECT@ECT, John D Suarez/HOU/ECT@ECT, Paul Racicot/Enron 
Communications@Enron Communications, John Llodra/Corp/Enron@ENRON, Mark Dana 
Davis/HOU/ECT@ECT, Christi L Nicolay@ECT, George Hopley/HOU/ECT@ect, Vince 
Middleton/HOU/ECT@ECT, Scott Affelt/HOU/ECT@ECT, David W 
Delainey/HOU/ECT@ECT, Mike J Miller@ECT, Ben Jacoby/HOU/ECT@ECT, Dave 
Kellermeyer/HOU/ECT@ECT, Jeffrey M Keenan/HOU/ECT@ECT, Fred 
Mitro/HOU/ECT@ECT, Clay Spears/HOU/ECT@ECT, David Dye@ECT, Roger Persson@ECT, 
Stephen Thome@ECT, Stephen Dowd/Enron Communications@Enron Communications, 
David Parquet/SF/ECT@ECT, Scott Healy/HOU/ECT@ECT, Susan Wood/HOU/ECT@ECT, 
Greg Woulfe/HOU/ECT@ECT, Doug Gilbert-Smith/Corp/Enron@ENRON, Janel 
Guerrero/Corp/Enron@Enron, Daniel Reck/HOU/ECT@ECT, George McClellan@ECT, 
Kevin McGowan/Corp/Enron@ENRON, Matthew Goering/HOU/ECT@ECT, Mark 
Driscoll/ECP/Enron@Enron, Zal Masani/HOU/ECT@ECT, Kenneth 
Lovejoy/Corp/Enron@ENRON, Molly Sample/Houston/Eott@Eott, Hap 
Boyd/EWC/Enron@Enron, Wayne_Lei@pgn.com, Bruce_Trout@pgn.com, 
Dennis_Norton@pgn.com, Terry_Worrell@pgn.com, Scott Bolton/Enron 
Communications@Enron Communications, Steven J Kean/HOU/EES@EES, Richard 
Shapiro/HOU/EES@EES, Cynthia Sandherr/Corp/Enron@ENRON, Mark 
Palmer/Corp/Enron@ENRON, Rob Bradley/Corp/Enron@ENRON, Janine 
Migden/DUB/EES@EES, Steve Montovano/DUB/EES@EES, Barbara A 
Hueter/DUB/EES@EES, Susan M Landwehr/HOU/EES@EES, Daniel 
Allegretti/HOU/EES@EES, Howard Fromer/HOU/EES@EES, James D 
Steffes/HOU/EES@EES, Becky L Merola/DUB/EES@EES, Frank Rishe/HOU/EES@EES, 
Lisa Yoho/HOU/EES@EES, Joe Hartsoe/Corp/Enron@Enron, Sarah 
Novosel/Corp/Enron@Enron
cc:  
Subject: Emissions - Mass. power plants

E&E Newsline - May 11, 2000

MASSACHUSETTS POWER PLANTS AGREE TO SIGNIFICANT UPGRADES

     Massachusetts this week announced that its six highest-polluting
power plants will voluntarily upgrade their pollution control technology to
not only significantly reduce air pollution but to also put the old
facilities under the same standards as new facilities.

     The action makes Massachusetts the first state to require older
plants to meet the same emissions standards as new facilities. The reduced
emissions will be in place as soon as 2003, according to Massachusetts
Governor Paul Cellucci's (R) office.

     The state approached the six plants and asked them to either reduce
their emissions or face regulatory action by the Department of
Environmental Protection. Cellucci said, "We challenged these power plants
to clean up their act, and they have answered our call to meet the most
comprehensive air emissions standards in the United States."

     The agreement -- which the five operators of the six plants agreed
to with the state -- is voluntary, but enforceable rules will follow.

     Lieutenant Governor Jane Swift explained that the agreement
resulted through "cooperative efforts," but added, "We will pursue new
regulations through the Department of Environmental Protection to ensure
the plant owners' commitments are enforceable, and will require the
finalization of a detailed plan for each of the six facilities."

     The regulations, which are expected to be proposed in the next few
months -- will set standards of 1.5 ponds of nitrogen oxide and 3 pounds of
sulfur dioxide per megawatt-hour.

     The five companies -- including Sithe Energies, Inc., NRG Energy
Inc., PE&E, Western Massachusetts Electric Companies/ Northeast Utilities,
and Southern Company/Southern Energy New England, LLC -- have submitted
preliminary plans. Under the plans, nitrogen oxide and sulfur dioxide
emissions would be slashed by up to 50 percent, and mercury, particulate
and carbon dioxide pollution would be curbed.

     "Our Air Quality Improvement Plan demonstrates that environmental
excellence works in today's competitive market," said James McGowan, senior
vice president of Sithe. "This is a win-win program that will produce the
best power plant for Sithe, the local communities and the environment as a
whole."

     The statement counters many other utilities' position on the issue,
particularly the Midwestern coal-fired plants subject to a massive EPA
enforcement action initiated late last year to have the facilities use
upgraded pollution control technology. Specifically, the lawsuit charges
the utilities with noncompliance with New Source Review requirements of the
Clean Air Act.

     The Massachusetts situation "does undercut the arguments of
dirtier, Midwestern companies that claim it can't be done," said Frank
O'Donnell, with Clean Air Trust.

     Pat Hemlepp, spokesperson for American Electric Power, one of the
utilities involved in the EPA lawsuit, argued, however, "that is like
comparing apples to oranges."

     Though Northeastern states blame the Midwest for pollution
migrating in their air, Hemlepp explained that since there are no serious
problems with non-attainment with CAA regulation in the Midwest, stricter
controls on utilities operating in that part of the country are
unnecessary. "States like Massachusetts have every right to go in and ask
utilities within their state to upgrade. There are major non-attainment
problems in the Northeast, so it makes sense," Hemlepp argued.

     And about EPA's lawsuit, "What people overlook is that EPA's
lawsuit is not about emissions, it's about what is and isn't legal under
the Clean Air Act. ... We feel very strongly that what we've done is
legal," Hemlepp said.