Usually, ENA legal hires outside counsel, but I'd be happy to assist you and 
outside counsel on it.  I don't know who legal typically uses although I'm 
pretty sure Dale used Dan Watkiss of  Bracewell and Patterson for one 
project.  Power marketers proposals are tariff filings for market-based rates 
under Section 205 of the Federal Power Act.  The Commission has 60 days to 
accept them from the date FERC notices the filing in the Federal Register or 
the filing is deemed accepted.  EWG applications are made under Section 32 of 
the Public Utiluty Holding Company Act.  Thereunder, the Commission must make 
an EWG determination within 60 days of its receipt of an EWG application.




Alan Larsen
11/02/2000 02:01 PM
To: Mary Hain/HOU/ECT@ECT
cc:  
Subject: FERC Filings in Connection with PSCo Project

Mary-- I have several "new guy" questions for you.  How do we prefer to take 
care of the required FERC filings for Market Based Rate Authorization and for 
EWG status in connection with power plant developments?  I ask this in the 
context of the PSCo project, where we have a project LLC as the development 
vehicle, and we anticipate selling the LLC before commercial operation.  
Specifically, do we do this in-house with govt. affairs people, through Enron 
DC office people, through outsside counsel for the project, through outside 
counsel not otherwise affiliated with the project, or otherwise? And, when do 
we  usually do the filings? Thanks. 
 Al Larsen