Attached is a revised IEP draft FERC Filing related to CAISO amendment no.
31.  Based on comments from the members, we have revised the document in two
primary areas: (1) added language emphasing the position of FERC as
articulated in the Morgan Stanley decision as to the nature of the purchaser
price caps, (2) sought Commission clarification as to the temporary nature
of any purchaser price caps, and referenced MSC comments to that effect, (3)
urged FERC to direct the CAISO to develop their market power critieria by
November 30, 2000, and establish a term for the extension of the price caps
for one year from that date (which will allow the MSC market refors to be
implemented and tested next summer).

IEP needs to file this document at FERC tomorrow (i.e. Thursday).
Accordingly, please provide any comments on this latest draft no later than
9:00 a.m. on Thursday, October. 5.  Forward comments to me and Andy Brown
[abb@eslawfirm.com].  Thank you,.

----- Original Message -----
From: Andy Brown <ABB@eslawfirm.com>
To: Steven Kelly (E-mail) <steven@iepa.com>
Cc: <andybrwn@earthlink.net>; Douglas Kerner <DKK@eslawfirm.com>; Eric
Janssen <EricJ@eslawfirm.com>
Sent: Wednesday, October 04, 2000 6:45 PM
Subject: Final draft IEP FERC filing on price cap


> Steven: attached is the draft filing in redline/strikeout which includes
the
> revisions members sent to you as we discussed.  I will need to send the
> filing out from our office in the morning on Thursday, therefore I must
have
> any comments by 9:00 am to have it timely filed in DC.  Comments should be
> made directly to me, preferably by telephone.  ABB
>
> Andrew B. Brown
> Ellison, Schneider & Harris, LLP
> 2015 H Street
> Sacramento, CA  95814
> Phone: (916) 447-2166
> Fax: (916) 447-3512
> mailto:abb@eslawfirm.com
>
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>  <<IEP_Mo_Interv_ER00-3673_ISOT_Am_31.ver1_rdln.doc>>
>

 - IEP_Mo_Interv_ER00-3673_ISOT_Am_31.ver1_rdln.doc