WPTF has just voted to file a protest on Amendment 30 (the ISO is asking to 
be able to buy power for itself in the forward market).  I agreed to fund as 
did 4, maybe 5, others.  The discussion was not exactly as you describe below 
but I will be able to have lots of input on the filing, and am sure I can get 
the points included.  Therefore, I recommend that Enron NOT make a separate 
filing on this.

Here is what WPTF voted on:  Ask FERC to limit ISO procurement only to the 
super peak product that has already been developed by the APX and require 
that the price caps end in 6 months; if the ISO wishes to renew the price 
caps it would have to file 60 days in advance of the 6-month deadline.






Mary Hain@ECT
09/28/2000 12:28 PM
To: Susan J Mara/SFO/EES@EES
cc: <mary.hain@enron.com>@ENRON, <smara@enron.com>@ENRON, 
<snovose@enron.com>@ENRON, Paul Kaufman/PDX/ECT@ECT, James D 
Steffes/HOU/EES@EES, Tim Belden/HOU/ECT@ECT, Robert Badeer/HOU/ECT@ECT, Jeff 
Richter/HOU/ECT@ECT, carrrn@bracepatt.com 
Subject: Cal ISO Amendment 30  

Sue- in WPTF's protest of Amendment 30, is WPTF proposing to make the 
following arguments?  If not we need to have Ron give an estimate for an RCR 
and draft a protest.

Amendment 30, which would allow the Cal ISO to do limited forward contracting 
and to allocate the costs thereof to under/overschedulers (protests due 
Oct.2)the traders would like to say that the ISO should not be in the forward 
market, rather the IOUs should be in the forward market and should be 
incented to do so.  Rather than doing anything to fix this failure to hedge 
and underscheduling by the IOUs, this filing would further amplify the 
problem by concentrating even more transactions with the ISO and lead to the 
slippery slope to the ISO running the entire market.  

Since, the filing also creates other problems.  Through the proposal to do 
bilateral deals without first receiving bids, the ISO moved itself out of 
compliance with Order No. 2000 (assuming it ever complied) by starting to 
violate the independence characteristic - the FERC's first minimum 
characteristic for an RTO.  Under this, the RTO is required to be independent 
of market participants.  Order No. 2000 defines a market participant as any 
entity or its affiliate that buys or sells electric energy in the RTO's 
region or in any neighboring region that might be effected by the RTO's 
actions.  

Further, the ISO is already buying out of market and this move would further 
complicate existing problems that we have with OOM.

In addition, although the filing claims that it's request is  limited, yet 
there is no time limitation.  Further, the limitation seems to have little 
real effect. 


   
	Enron Capital & Trade Resources Corp.
	
	From:  "Ronald Carroll" <rcarroll@bracepatt.com>                           
09/19/2000 03:23 PM
	

To: <mary.hain@enron.com>, <smara@enron.com>, <snovose@enron.com>
cc:  
Subject: New California Filings


There have been several recent filings related to California that you may 
wish to intervene in and/or protest:

1.  CAISO proposal to extend price cap (ER00-3673-000) (due Oct. 5);

2.  CAISO compliance filing with San Diego order to make limited forward 
contracting and to allocate the costs for those contracts to SCs whose 
forward schedules do not reflect their actual real-time demands.  
(ER00-3636-000) (due Oct. 2);

3.  City of Vernon filing to join ISO (EL00-105-000) (due September 29).  
This filing triggers the CAISO's TAC charge effective 1/1/01;

4.  Complaint by Cities of Anaheim, Azusa, etc. regarding the CAISO's 
collection of OOM incurred to meet system reliability and to require the 
CAISO to abide by the cap in Neutrality Adjustment Charge.

Please let me know as soon as possible if you wish to intervene in and/or 
protest any of these filings.  Thanks.  Ron