Please see attached file as solution to problems identified by Jim.  




James D Steffes
08/16/2000 07:56 AM
To: Bruno Gaillard/SFO/EES@EES
cc: Steven J Kean/HOU/EES@EES, Harry Kingerski/HOU/EES@EES, Jeff 
Dasovich/SFO/EES@EES, Mona L Petrochko/SFO/EES@EES, Susan J Mara/SFO/EES@EES, 
Richard Shapiro/HOU/EES@EES, Sandra McCubbin/SFO/EES@EES, Paul 
Kaufman/PDX/ECT@ECT 
Subject: Re: Comments on Duque/ Wood Decisions -- Due TODAY 8/16  

Bruno --

I completely disagree with this pleading.   Direct access customers should 
not be afforded the same regulatory "bad policy" as bundled customers as 
relates to their energy component.  If the regulatory fix was to reduce 
distribution rates for the period, then I would seek that fix.

We, as Enron, have been loudly proclaiming that our direct access customers 
have managed their price exposure by locking in with a contract and price 
with us.  We took the price exposure for our customers and managed it 
appropriately.

If other members of ARM are not hedging their short retail position than they 
are just as "bad" as the utility.  

This is not the message we want to be sending.  This pleading should say what 
Bruno's change proposes, and then little more.  The competitive market looks 
like  a bunch of "yahoos" for advocating markets and price volatility and 
then asking for handouts!

Jim







Bruno Gaillard
08/15/2000 08:47 PM
To: Harry Kingerski/HOU/EES@EES, James D Steffes/HOU/EES@EES, Jeff 
Dasovich/SFO/EES@EES, Mona L Petrochko/SFO/EES@EES, Susan J Mara/SFO/EES@EES, 
Richard Shapiro/HOU/EES@EES, Sandra McCubbin/SFO/EES@EES, Paul 
Kaufman/PDX/ECT@ECT
cc:  
Subject: Comments on Duque/ Wood Decisions -- Due TODAY 8/16

Attached is the first draft ARM's our comments. It will be revised, however 
we need to get comments in ASAP

I asked Jeanne Bennett to change the third sentence in the introduction from 
"ARM does not dispute the need to offer relief..." to a statement that would 
reflect ARM's belief that the market will ultimately offer the best hedging 
tools for all customers, However, ARM recognizes that there is an immediate 
problem in SDG&E than can be mitigated on an interim basis with the Wood or 
Duque proposal.  

The paragraph will be redrafted to clarify the fact that we do not want the 
levelized payment plan to be the default for any customer class and that the 
LPP should be only offered to smaller customers on an optional basis as 
larger customers are more sophisticated and can find these options in the 
market.

If you have concerns, please provide comments by 11 am CST on 8/16 as the 
filing is due on 8/16

---------------------- Forwarded by Bruno Gaillard/SFO/EES on 08/15/2000 
06:41 PM ---------------------------


JMB <JBennett@GMSSR.com> on 08/15/2000 03:34:25 PM
To: "'ARM@Phaser.com'" <ARM@Phaser.com>
cc: "'jleslie@luce.com'" <jleslie@luce.com>, "'bluden@greenmountain.com'" 
<bluden@greenmountain.com> 
Subject: Comments on Duque/ Wood Decisions -- Privileged -- Attorney Work 
Product


Attached is a draft of the comments on Wood's and Duques' proposed
decisions. It tracks our conversation of this morning.  As you all know,
these comments are  due tomorrow.  Please have all comments on the draft to
me by no later than noon tomorrow (the 16th).


 <<X15748.DOC>>

Jeanne


 - X15748.DOC