In response to Jim's E-mail  - here's is my proposed list of issues for 
Enron's November 9 comments.  We have to send our issue list to FERC tomorrow 
so please comment on this ASAP.

We should discuss price signals including:
price caps and
market information

Here's my rationale.  Since we'll only have five to ten minutes to talk, our 
comments should focus on the most important commercial issues to us: removing 
or improving price caps and improving market transparency by providing market 
information to market participants.  We could summarize the positions we took 
in the white paper about why the Commission shouldn't allow a price cap at 
all and why we need information.  In addition, we should assume that they 
will adopt price caps anyway and may reaffirm their own proposal, so we 
should also tell them how the $150 cap will be too low to incent investment 
in new generation, how the reporting requirement will create special problems 
for power marketers  (we don't have marginal costs and the Commission has yet 
to determine what opportunity costs are), and how they still have not 
addressed the problems created by OOM.

In addition, although I don't think we need to tell FERC this, our comments 
could briefly congratulate the Commission for removing the buy/sell 
requirement, addressing underscheduling of load, creating independent 
governance and directing the ISO to file generation interconnection 
procedures.  Although our written comments will probably want to discuss any 
clarifications of this measures as well as the long term measures the 
Commission discussed (reserve requirements, alternate auction mechanisms, 
balanced schedules, enhanced market mitigation, congestion management 
redesign, demand response programs, RTO development and compliance) our oral 
comment time is too precious to use on these issues.  In addition, our 
written comments will want to beef up the legal support for the Staff's 
conclusion about refunds and perhaps request rehearing of the Commission's 
decision to move the refund effective date.  I'm sure we'll find more issues 
as we go.