I will most likely not be able to attend.  However, my comment relating to 
this issue was a generalization of confidentiality clauses I've used on other 
interconnect agreements and other contracts, including the "model" 
interconnection agreement recently submitted to FERC by EPSA.  In essence, 
the issue is that the utility should not have the unilateral right to 
disclose any information to anyone they want that is sent to them in 
connection with a DG interconnection.  This would include ownership, facility 
output, markets for energy or capacity or ancillary sevices (if any) and 
maintenance schedules (these schedules may be coincident with a retail 
customer's facility maintenance schedule which itself may be confidential 
information between the generator and retail customer).  This information is 
potentially competitive and should be held confidential.  Potential wording 
for a simplified confidentiality section would be as follows:

"Unless compelled to disclose by judicial or administrative process or other 
provisions of law or as otherwise provided for in this Rule, the Electic 
Provider shall hold in confidence any and all documents and information 
furnished by the Electric Customer in connection with the interconnection, 
provide however, that to the extent it is necessary for the the EP to release 
or disclose such information to a third party in order to perform the EP's 
obligation herein, EP shall advise said third party of the confidential 
provisons of this Rule and use its best efforts to require said third party 
to agree in writing to comply with such provisions."

   




Bruno Gaillard
04/20/2000 11:47 AM
To: Jeff Dasovich/SFO/EES@EES, Tom Hoatson/HOU/EES@EES, Robert 
Frank/HOU/EES@EES
cc:  
Subject: Siting Committee Hearing - Interconnection Rules

Scott Tomashefsky is asking me to present our position on the confidentiality 
clause in Rule 21 at the CEC Hearing on 4/25. Any thoughts. I hope to be able 
to respond to him today.

Should an Enron rep be present to do so? Me or another?
Bob are you coming to Sacramento?
 
---------------------- Forwarded by Bruno Gaillard/SFO/EES on 04/20/2000 
09:41 AM ---------------------------


"Scott Tomashefsky" <Stomashe@energy.state.ca.us> on 04/20/2000 07:26:24 AM
To: bgaillar@enron.com
cc:  
Subject: Siting Committee Hearing


Bruno,

I was wondering if you would be willing to speak for 5-10 minutes on Tuesday 
regarding Section 2.7 of the proposed Rule 21 language (confidentiality of 
information)?  I was hoping you could convey your concerns for the Committee. 
We have also added language in the report stating the Energy Commission has 
previously urged positions similar to Enron's at the CPUC, but the CPUC has 
not accepted them.

Please let me know at your earliest convenience.

Scott