Attached find Ron's outline of comments on the FERC's November 1 order in the 
Section 206 proceeding.  They are primarily legal arguments.   

Concerning his comments about the congestion management redesign - I'm not 
sure that we want to oppose LMP.  I think instead we want to ensure that 
there are not a large number of nodes.

Alan will be writing the technical comments on the $150 caps, not Seabron.  
Sue called me this morning and said IEP will not be contesting the $150 price 
cap.  This is too bad because we had hoped they would carry the ball on 
arguing why $150 is not sufficient to incent peaking generation.  Sue is 
working on IEP to try to get them to reconsider.

I think we also need to make sure we make all of the arguments that relate to 
the CPUC's subpoena.  I have asked Lysa Akin to set up a conference call 
about this ASAP with Richard, Dan, Gary Fergus, Me, Mike Day, Sue, and Jim.  
Please tell Lysa if I haven't listed you and you wish to be on this call.
---------------------- Forwarded by Mary Hain/HOU/ECT on 11/06/2000 09:27 AM 
---------------------------
   
	Enron Capital & Trade Resources Corp.
	
	From:  "Ronald Carroll" <rcarroll@bracepatt.com>                           
11/03/2000 02:58 PM
	

To: <mary.hain@enron.com>, <smara@enron.com>
cc: "Jeffrey Watkiss" <dwatkiss@bracepatt.com> 
Subject: Comments to November 1 Order


I have enclosed my thoughts on which issues to address in our comments.

 - 0133539.01