Complaint against some non-jurisdictionals (PowerEx, BC Hydro) and Mirant.  
CARE is a fringe group.  Probably won't be taken seriously.

Sue Mara
Enron Corp.
Tel: (415) 782-7802
Fax:(415) 782-7854
----- Forwarded by Susan J Mara/NA/Enron on 04/19/2001 08:42 AM -----

	"Ronald Carroll" <rcarroll@bracepatt.com>
	04/19/2001 06:49 AM
		 
		 To: <gfergus@brobeck.com>, <ray.alvarez@ei.enron.com>, <acomnes@enron.com>, 
<cyoder@enron.com>, <jsteffe@enron.com>, <rsanders@enron.com>, 
<smara@enron.com>, <sbishop@gibbs-bruns.com>
		 cc: 
		 Subject: Fwd: Californians for Renewable Energy, Inc. (CARE)  v. BC Hydro, 
et al., EL01-65


Date: Thu, 19 Apr 2001 07:27:07 -0500
From: "Tracey Bradley" <tbradley@bracepatt.com>
To: "Aryeh Fishman" <afishman@bracepatt.com>, "Andrea Settanni" 
<asettanni@bracepatt.com>, "Dan Watkiss" <dwatkiss@bracepatt.com>, "Kimberly 
Curry" <kcurry@bracepatt.com>, "Ronald Carroll" <rcarroll@bracepatt.com>
Subject: Californians for Renewable Energy, Inc. (CARE)  v. BC Hydro, et al., 
EL01-65
Mime-Version: 1.0
Content-Type: multipart/mixed; boundary="=_5D06B43C.1A7B1DE3"

FYI - Attached is a complaint filed by CARE on April 16 against BC Hydro, 
Powerex, Mirant and BPA (with the LADWP thrown in as an unnamed respondent).  
The complaint is principally directed against BC Hydro and Powerex.  It 
essentially accuses BC Hydro and Powerex of manipulating the reservoirs in BC 
and transmission capacity reserved by Powerex on the BPA system to COB and 
NOB to withhold power during a period of peak demand "to contrive a shortage 
and test their market power."  CARE accuses BC Hydro and Powerex of violating 
Section 206 of the FPA, state and federal anti-trust laws, the civil rights 
of Californians under Title VI of the Civil Rights Act of 1964 and NAFTA.

The complaint is long on sensational allegations and short on facts.  The 
evidence proffered in the complaint consists of a rant off the YAHOO Message 
Board by an unnamed power trader in Spokane (we think it is an Avista 
trader), selected transmission data from the ISO, the LA Times article of 
April 11, 2001 regarding the ISO's report on Powerex, BPA and LADWP, the ISO 
report itself, and BC Hydro's residential rate schedule.  CARE requests FERC 
to initiate an investigation, seeks unspecified refunds and punitive damages 
and also appears to want FERC to have the Secretary of DOE declare an 
emergency under Section 202(c) of the FPA and compel deliveries of 
electricity.

FERC has noticed the complaint and has established May 8 as the due date for 
interventions and responses.

 - el01-65.tiff