I will check on this.  I may be incorrect in the 12/21 date based on the
following quoted response that I found.  I will get further clarification.
"In its November 1, 2000, Order, FERC outlined a series of flaws in the
California markets and proposed a number of measured designed to reform the
market.  One of such proposals what that the ISO modify its single price
auction "so that bids above $150/MWh could not set the market clearing price
that is paid to all bidders and imposing certain reporting and monitoring
requirements for transactions and bids above the $150/MWh breakpoint."
Pursuant to FERC's November 1 Order, the ISO filed Amendment 33 with FERC on
December 8, 2000, which was approved on the same day.  On December 15, 2000,
FERC issued an Order Directing Remedies for California Wholesale Electric
Markets, and further clarified its December 8, 2000 Order.

Pursuant to Amendment 33, effective December 8, 2000, FERC authorized the
ISO to set a "soft" bid cap for the purchase of real-time energy.  The order
specified that although the ISO would pay those entities bidding above the
soft cap as bid, all bids above the breakpoint would be are subject to
market refund following FERC's review of the bid data "in order to ensure
just and reasonable rates".  Effective December 12, 2000, FERC's order
authorized the ISO to assess the costs of real-time purchases above the soft
cap and allocate to SCs which under-schedule load the difference between the
interval MCP and the bid price above the soft cap bid prices to SCs which
underschedule load.  The ISO created CT 487 to accomplish this allocation.

Please see the following excerpt from the FERC December 15, 2000, order,
Docket No. EL00-95-000, et al:

"On December 8, 2000, the ISO filed Tariff Amendment No. 33 in Docket No.
ER01-607-000, seeking expedited consideration of tariff revisions to address
emergency reliability conditions.  The filing sought three modification of
the ISO's tariff: (1) immediate implementation of an interim price
mitigation proposal based on the breakpoint concept that was proposed in the
November 1 Order (at $250/MWh) to encourage greater participation of
generators in its markets; (2) provision of penalties on generators that
fail to respond to dispatch instructions during a system emergency, to
become effective December 8, 2000; and (3) allocation of the costs of
obtaining additional energy to Scheduling Coordinators who rely on the ISO's
real-time Imbalance Energy market, as an incentive to loads to purchase
energy in the forward markets.  The ISO requested an effective date of
December 12, 2000 for the third modification.

The commission approved the tariff revisions in an order issued December 8,
2000, with the effective dates requested by the ISO."

After an extensive review, the ISO has concluded that the charges for
purchases above the soft cap break point (currently set at $150/mwh),
although high, are consistent with the filing approved by FERC.  FERC
continues to review the just and reasonableness of all bids dispatched in
our real-time market that are above the $150.00 breakpoint, and will order
market refund if the dispatched bid price is not found to be just and
reasonable.  The ISO continues to review this issue, and is considering
alternative allocation methods, which would continue to be consistent with
the tariff. "



Keoni Almeida
California Independent System Operator
phone: 916/608-7053
pager:  916/814-7352
alpha page:  9169812000.1151268@pagenet.net
e-mail:  <mailto:kalmeida@caiso.com>




-----Original Message-----
From: Donna.Johnson@enron.com [mailto:Donna.Johnson@enron.com]
Sent: Wednesday, May 09, 2001 9:37 AM
To: KAlmeida@caiso.com
Subject: RE: Soft Cap allocation


Thanks for the info Keoni.  I need further clarification.  If the price Cap
went into effect on 12/21/00, how is the CAISO able to charge above the
$150.00 soft price CAP in Uninstructed Energy (407) for 12/22/00-12/31/00?

Donna

    -----Original Message-----
   From:   "Almeida, Keoni" <KAlmeida@caiso.com>@ENRON

[mailto:IMCEANOTES-+22Almeida+2C+20Keoni+22+20+3CKAlmeida+40caiso+2Ecom+3E+4
0ENRON@ENRON.com]


   Sent:   Tuesday, May 08, 2001 5:56 PM
   To:     Johnson, Donna
   Cc:     Stokley, Chris
   Subject:  Soft Cap allocation

   See message below.  I will look to see if there is a better explanation.

   Keoni Almeida
   California Independent System Operator
   phone: 916/608-7053
   pager:  916/814-7352
   alpha page:  9169812000.1151268@pagenet.net
   e-mail:  <mailto:kalmeida@caiso.com>

   "Almeida, Keoni" <KAlmeida@caiso.com> on 02/08/2001 03:25:43 PM

   To:   "Johnson, Donna" <Donna.Johnson@enron.com>, "Nelson , Kourtney"
         <Kourtney.Nelson@enron.com>
   cc:   "Stokley, Chris" <chris.stokley@enron.com>

   Subject:  FW: OOM cost allocation


   I got another error indicating:
   Your message did not reach some or all of the intended recipients.

         Subject: FW: OOM cost allocation
         Sent:    2/8/01 3:22 PM

   The following recipient(s) could not be reached:

         Nelson , Kourtney on 2/8/01 3:24 PM
               Unable to deliver the message due to a recipient problem
               MSEXCH:MSExchangeIS:Corporate:CSIFIAPP667

   I will send out the pieces to this e-mail separately.

   Keoni Almeida
   California Independent System Operator
   phone: 916/608-7053
   pager:  916/814-7352
   alpha page:  9169812000.1151268@pagenet.net
   e-mail:  <mailto:kalmeida@caiso.com>



   > -----Original Message-----
   > From:   Almeida, Keoni
   > Sent:   Thursday, February 01, 2001 3:47 PM
   > To:     Johnson, Donna; Nelson , Kourtney
   > Subject:     OOM cost allocation
   >
   > OOM cost is allocated to the market using CT407 up to the MCP, which
   was
   > up to $250 until 12/21/00 then $150 thereafter.  Anything above the
   MCP
   is
   > allocated to CT487.  Prior to this new charge type CT 1010 was used to
   > allocate OOM calls reater than the price cap.
   > We pay OOM charges using 401.  SCs deviating arepaid the dec price for
   > overshceduling and for those underscheduling they get charged the inc
   > price.  When the dec and inc price differ, it gets picked up in 1010.