Concur with Harry, i.e., continue to take the position that the program 
should be available to all.  When I was in Sacramento last week at a meeting 
of all the players, the utilities argument against including DA customers was 
based on "double dipping," i.e., payments to customers/ESPs for curtailment, 
plus payments to customers/ESPs for the re-sale of power to the ISO resulting 
from the curtailment.

The utilities "double dipping" argument is off base.  As important, the state 
is facing the threat of frequent and severe supply disruptions this summer 
and it needs to take each and every step necessary to try to avoid them.  The 
utility position (apart from being incorrect) seems pretty short-sighted 
given the dire circumstances.  So seems clear that California should include 
both DA and bundled customers in the program.

Best,
Jeff






	Harry Kingerski
	03/06/2001 09:02 AM
		 
		 To: Susan J Mara/NA/Enron@ENRON, Jeff Dasovich/NA/Enron@Enron, James D 
Steffes/NA/Enron@Enron, Paul Kaufman/PDX/ECT@ECT
		 cc: Fred L Kelly/ENRON_DEVELOPMENT@ENRON_DEVELOPMENt, Dave 
Roberts/HOU/EES@EES, Gary Weiss/HOU/EES@EES, Scott Stoness/HOU/EES@EES, 
Jubran Whalan/HOU/EES@EES, Neil Bresnan/HOU/EES@EES, Leslie 
Lawner/NA/Enron@Enron, Robert Frank/NA/Enron@Enron, Scott Gahn/HOU/EES@EES
		 Subject: AB31X - Response Needed

Mike Day left me a message saying in discussions yesterday on AB 31X 
(Wright's load curtailment bill), the utilities were making the point that 
31x should only address bundled customers since the utilities were making the 
incentive payments out of funds that would otherwise go to pay DWR  (in 
effect, the curtailments are reducing the utility net short position).  They 
were ok with having ESPs aggregate the loads of bundled customers (which will 
be a very significant win, if we get it).   They think DA customers can get 
curtailment benefits through existing (and new) ISO programs.

The dilemmas are:
the ISO programs may or may not be finalized for this summer and may or may 
not give incentives that are as beneficial as AB31X
the utility plan discriminates against DA 
preferably, the ISO would administer the programs described by AB31X for all 
customers but that puts the ISO in the position of having to get approvals 
from FERC for a CA-legislated program (they will have to do this anyway)
(nearly) all of our customers will be bundled this summer anyway, so there's 
no immediate loss from going with the utility's position


We owe Mike an answer today.  Any thoughts?  My suggestion at this point is 
to stick with the high road and argue for non-discriminatory treatment with 
equal incentives paid to bundled and DA customers.

Background:  AB31X would give $500/mwh incentives for day ahead curtailment, 
$750/mwh incentives for day-of curtailments, and incentives to be determined 
for scheduled load reductions.  The ISO would invoke the programs based on 
system conditions.

The ISO so far has put in place the equivalent of a scheduled load reduction 
program, with specific payments, but has not finalized any day ahead or day 
of programs.