Here is another hefty ISO  filing that came in this week.  Please let Sue or 
I know if you believe we should intervene/protest.

Alan Comnes

Summary of ISO Amendment 34:

Filed: December 28

Effective Date: 1/1/01 (expedited treatment requested)

Protests Due: January 17? (need to confirm this)

Filing in a Nutshell: The ISO states that the purpose of the amendment is to 
clarify certain issues associated with implementation of the new transmission 
Access Charge methodology it orginally proposed in Amendment No. 27. 
(According to the ISO, Amendment 27 has been accepted for filing, suspended, 
and set for hearing.  Settlement negotiations are ongoing.  (Is Enron a party 
to these settlements?)) In addition, the ISO provides new transmission Access 
Charge (TAC) rates that will be in effect if the Commission approves the City 
of Vernon joining the ISO effective January 1, 2001 and the amount of Firm 
Transmission Rights that will be given to Vernon in accordance with the ISO 
Tariff.

Specific Proposed Changes

Clarification of Wheeling Access Charge Quantity

The ISO proposes that these provisions be clarified to specify that in the 
determination of the Wheeling Access Charge, the proper calculation is to use 
transmission facility ownership and Entitlements less all Encumbrances.  
Encumbrances include transmission used to meet demands of existing 
contracts.  This is how the ISO is currently calculating this charge and the 
ISO appears to be using this filing to codify this method.

New HV TAC Rates Using Year-1 of the ISO,s Proposed Transmission Methodology

The current Access Charge methodology consists of three separate zone rates 
based on the Transmission Revenue Requirement of the Original Participating 
TO.  Because each zone corresponds to the service territory of the TO, they 
are known as &license plate8 rates.  Under Amendment No. 27, this methodology 
continues in effect until a New Participating TO joins the ISO.  Once that 
occurs, the Access Charge for High Voltage Transmission Facilities will be 
assessed based on the combined High Voltage Transmission Revenue Requirements 
of all the Participating TOs in each TAC Area.

The filing claims to implement an already-approved transition formula wherein 
new members of the ISO will pay a rate that is a mix license place and system 
average embedded costs.  The goal is that after 10 years there will be only 1 
high voltage access charge. The following table shows that under the current 
method, which would be a 90/10 split of license-plate/system-average charges, 
PG&E and SCE TO access charges would rise approximately $3.2 million and 
Vernon would be subsidized approximately $7 million.

Calculation of the net (benefits)/burdens from Access Charge and GMC Impact.  
 PG&E and SCE have a $32 Million cap annually and 
SDG&E has a $8 Million cap annually; Vernon is held harmless; I
OUs pay muni cost increases in proportion to their cap relative to the total 
cap.	Adjusted
	Net
	(Benefit)/
	Burden
	($1000)
	[37]
PG&E	$3,283 
SCE	$3,283 
SDG&E	$821 
Vernon	($7,051)
  Total	$336 
	
	
	Note: a positive number means the TAC is going up.  A negative number means 
the TAC is going down (or will be lower than would be the case under 100% 
license plate ratemaking)


Vernon,s Existing Transmission Rights Converted to FTRs

Veron, by joining the ISO effective 1/1/01, agrees to convert existing 
transmission rights to FTRs of presumably an equivalent amount.  The proposed 
FTRs to allocate to Vernon are in the filing.  These FTRs will expire when 
the underlying contract right expires or 10 years, whichever is sooner.







Susan J Mara@ENRON
12/28/2000 03:57 PM
To: Richard Shapiro/NA/Enron@Enron, James D Steffes/NA/Enron@Enron, Joe 
Hartsoe/Corp/Enron@ENRON, Sarah Novosel/Corp/Enron@ENRON, Mary 
Hain/HOU/ECT@ECT, Tim Belden/HOU/ECT@ECT, Jeff Dasovich/NA/Enron@Enron, 
Sandra McCubbin/NA/Enron@Enron, Alan Comnes/PDX/ECT@ECT, Donna 
Fulton/Corp/Enron@ENRON, David Parquet/SF/ECT@ECT, Christopher F 
Calger/PDX/ECT@ECT, gfergus@brobeck.com, Christian Yoder/HOU/ECT@ECT, Richard 
B Sanders/HOU/ECT@ECT, Robert Badeer/HOU/ECT@ECT, Jeff Richter/HOU/ECT@ECT, 
Chris H Foster/HOU/ECT@ECT, Dennis Benevides/HOU/EES@EES, Jubran 
Whalan/HOU/EES@EES, Neil Bresnan/HOU/EES@EES, Roger Yang/SFO/EES@EES
cc: rcarroll@bracepatt.com 

Subject: There is No Christmas for CA -- NEW FERC Filings

Here we go:

12/20/00 - PG&E files emergency request for rehearing of 12/15 order.  It 
seeks refunds, cost of service rates, elimination of market-based rate 
authority and more.

12/20/00 - CA Bureau of Audit opposes the emergency motion of the generators 
to require FERC-like confidentiality provisions to apply to data requested 
from the ISO.

12/22/00 -  Dynegy files complaint - EL01-23-000 - alleging discriminatory 
use of OOM by the ISO against in-state generators.  Seeks pricing above 
short-run marginal costs plus 15% on a temporary basis and to prohibit the 
ISO from using OOM for non-emergency conditions (I thought we won that one a 
while ago).  And more ...

12/22/00 - Dynegy seeks clarification on FERC's 12/15 order -- wants FERC to 
clarify that standard commercial practices will be used to deal with the 
utilties' creditworthiness problems, wants to avoid the IOUs somehow claiming 
the FERC order obviates their need to be credit worthy. (huh?)

12/26/00 - CalPX files to request for rehearing of FERC's 12/15 order to save 
itself.  It asks to stay the prohibition for the IOUs to sell to the PX, stay 
the termination of the CTS rate schedule, and stay the $150 "breakpoint" 
applied to the PX day-ahead market.

12/?/00 - Cal PX also institutes new pricing method (plus and minus $125 for 
constrained areas), but claims it's only a software change and does not 
require a Board vote or a FERC filing

Note:  There were no filings made on Christmas Day, as far as we can tell.

regards,
Sue