I just got off the phone with Bill Nissen.  He is at an ABA seminar at which 
Paul Archietzel spoke today.  Mr. Archietzel is with the CFTC's Division of 
Economic Analysis and (Bill believes) is very involved in rule drafting and 
promulgation.

According to Bill, Mr. Archietzel stated in his speech that he believes it 
was no accident that Congress referred to "agricultural commodities" (rather 
than the enumerated grains and meats) in the CFMA when establishing which 
commodities will continue to be subject to full regulation.  Mr. Archietzel 
also expressly stated that there is at least a possibility that pulp and 
paper would be considered "agricultural commodities" as used in the CFMA.

Obviously, then, the upcoming rulemaking process could be of critical 
importance to our pulp and paper business as well as our agriculture 
business. We will clearly need to monitor the process very closely, and 
strongly consider getting involved in the comment process. 


Robert E. Bruce
Senior Counsel
Enron North America Corp.
T (713) 345-7780
F (713) 646-3393
robert.bruce@enron.com