FYI:

I sent the attached documents to the members of the NWRTO Legal Working
Group this evening.  Given the schedule of events, there is very little
time to touch bases with you folks to verify that the positions stated
in the documents reflect your own. My gut feeling is that they do... but
if there is any positions within the documents with which you take
issue, please let me know.

I won't be able to attend the Legal working group meetings because of
conflicts with the congestion management and ancillary services working
group meetings.  (And if we can't get more commitment to shoring up the
funding of the power marketer coalition, then I may not be attending
those working group meetings after this week either.)  Of all the
contract documents addressed above (TCA, GIA, LIA, Bylaws, Articles), I
think that the ones to which we need to devote the most attention are
the GIA and the TCA.

As to the GIA: I think it would be especially worthwhile if some of you
(Dynegy, Reliant, Calpine) who've been operating under an ISO already -
and who are therefore already sensitive to the burdens that can be
imposed on generators by an ISO/RTO - could give the GIA (and my
comments on the GIA) a thorough technical review and a thorough legal
review.  Since I haven't been on the battlelines in this area, I may
have missed a few issues.  PG&E Gen (Dave) might also want to take a
good look at the document, since I've seen the press releases about the
Umatilla plant near Hermiston.

Carl Imparato
510-558-1456

Message-ID: <39694455.E56@tca-us.com>
Date: Sun, 09 Jul 2000 20:34:45 -0700
From: Carl Imparato <cfi1@tca-us.com>
Reply-To: cfi1@tca-us.com
Organization: Tabors, Caramanis & Associates
X-Mailer: Mozilla 3.0Gold (Win95; U)
MIME-Version: 1.0
To: mwood@stoel.com, sdleonard@earthlink.com, ericf@prestongates.com, 
bmspeckman@aol.com
Subject: Comments on NWRTO Legal Work Group Documents
Content-Type: multipart/mixed; boundary="------------67E94F796ED1"

Attached are my comments, on behalf of the power marketer group, on the
following drafts:

- Transmission Control Agreement
- Generation Integration Agreement
- Load Integration Agreement
- Bylaws
- Articles of Incorporation.

I am sending these documents to you because I understand that Marcus is
responsible for the TCA, Sarah is responsble for the GIA and LIA, Eric
is responsible for portions of the Bylaws, and Barney might know who is
responsible for the remainder of the Bylaws and Articles.

Due to scheduling conflicts with other NWRTO working groups, I will not
be able to attend the meetings that have been scheduled to discuss the
Legal Work Group documents.  But if I can be of help in further
explaining the concerns raised in the attached documents, please let me
know.

Carl Imparato
510-558-1456

 - NWRTO-TCA-Comments-CFI-070800.rtf
 - NWRTO-GIA-Comments-CFI-070800.rtf
 - NWRTO-LIA-Comments-CFI-070800.rtf
 - NWRTO-Bylaws-CFI-070800.rtf
 - NWRTO-ArtIncpn-CFI-070800.rtf
 - NWRTO-GIA-112697.doc