I am back in the office.  I assume you are handling this and will let me see 
a copy of the draft.  Thanks.




Steve Walton
01/05/2001 09:34 AM
To: Mary Hain/HOU/ECT@ECT, Alan Comnes/PDX/ECT@ECT, Sarah 
Novosel/Corp/Enron@ENRON
cc: Paul Kaufman/PDX/ECT@ECT 
Subject: Comments on RTO West December 1st Filing

I have not gone over the filing in great detail, I have found one thing we 
may want to file to address.  All the parties except PGE/Sierra/Nevada agreed 
to eliminate the export fees.  PGE/Sierra/Nevada made a joint filing asking 
the FERC to require the RTO West to include export fees and their effect in 
the financial modeling of their Stage 2 filing.  I think we should consider 
filing comments  to oppose this requiest from PGE/Sierra/Nevada for the 
following reasons:

Elimination of the export fees is a positive step to resolve one of the three 
major "seams" issues.  With RTO West taking the lead, the other RTOs (CAISO & 
DSTAR) can follow suit.
The nature and type of export fee to be used would have to be developed.  
This eat up an enormous amount of time on a speculative fee which the 
majority of the parties are opposed to including.  The delay engendered and 
use of limited resources is unconsiounable.

We can reiterate our concerns regarding allocation of rights instead of an 
auction and about the potential exclusion of facilities from the RTO West 
control.  The December 1st filing really doesn't change those things.  Since 
the comments are due on the 16th and I will be gone all next week, I thought 
I had better let you know my views before leaving.

I am including the IPP/Marketers comments for reference.

Steve