My comments --

I assume that in the Enron filing we will make a stronger argument for sticking with the 12-15-02 date?  Also, critical to highlight that the FERC should have one "major" change date, not multiple given the liquidity problems with significant regulatory change.

Finally, break out competitive retailers in the list of the ONE RTO Coalition. Every state inside this region (except VT) has competitive retail access.  Furthering this effort with further the policy directions of the states by lowering wholesale prices and making business "easier" for companies like EES.  We should play this up.  We are really pushing hard on the physical retail gen side in NYC and Boston and taking another look at PA and MD - this is the real benefit - that consumers' bills go down.  I didn't see that language on consumer benefits.

Jim

 -----Original Message-----
From: 	Novosel, Sarah  
Sent:	Monday, October 08, 2001 9:36 AM
To:	Shapiro, Richard; Steffes, James D.; Lindberg, Susan
Subject:	One RTO Coalition Drafts

Rick, Jim and Susan:

Enclosed is the One RTO draft comments on the Northeast Mediation.  We would like to include Enron as a signatory party to the comments, so please read them to make sure that you are okay with us signing on.  Although the date issue is somewhat amorphous (we support PJM (with a Nov 2003 date but we also urge implementation as soon as possible -- Dec 2002 if possible).  

This was the best we could get the Coalition to agree to -- there are many parties who strenuously opposed advocating any date early than Nov 2003 and I had to threaten to take our name off the comments if we didn't say something about an earlier date.  We have not given final signoff, but they would like to hear from us by the end of the day (comments are due tomorrow).

Susan, please show the comments to Kevin, Dana, Paul (and anyone else who would like to see them).  We are also writing our own comments, which we will circulate by COB today for filing tomorrow.  They do not need to read the affidavits -- just the comments to make sure we're not saying anything they disagree with.

Also attached is the Henning affidavit that supports the Mirant study.  Although Mirant probably did not make the best choice in using an internal regulatory person to do the study presentation at FERC, everyone who I have talked to thinks that FERC staff reacted favorably to the study's findings.  One person overheard FERC staff say that they expected $440 million in savings per year, and they weren't questioning these savings, but wondered if these were enough savings to justify a movement to one RTO.  It seems to me that $440 million is significant savings, but who knows.  Anyway, we need to discuss whether we want to join in the Mirant Midwest study.  Provided that a similar study can be conducted in the midwest (since there are no ISOs there), with a similar good outcome, I think we should consider supporting the Mirant effort.

Please let me know what you think.  Thanks

Sarah

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