Good info.  I like the Reg Orig plays.  Amr should track our success.

Jim

 -----Original Message-----
From: 	Kingerski, Harry  
Sent:	Wednesday, September 05, 2001 11:55 AM
To:	Steffes, James D.; Shapiro, Richard
Subject:	FW: 

fyi.

 -----Original Message-----
From: 	Kingerski, Harry  
Sent:	Wednesday, September 05, 2001 11:54 AM
To:	Anderson, Meriwether; Tawney, Mark; Smith, Mike; Herndon, Rogers
Cc:	Frank, Robert; Yoho, Lisa; Landwehr, Susan M.; Lassere, Donald; Montovano, Steve; Arefieva, Maria
Subject:	

Attached is the first draft of our intervention in the Georgia Power rate case.
 << File: Georgia Power Case3.doc >> 

Our goals are to get:
Georgia Power's weather risk transferred to the market through purchase of weather hedges, in lieu of GP's proposal to refund a portion of above normal weather revenues in exchange for supposedly bearing downside weather risk (for EGM, principally);
Disclosure of new capacity contracts whose costs are proposed to be recovered through a new automatic capacity recovery mechanism, to help our own ability to hedge existing retail positions (for EWS);
Application of an earnings test that would limit when the capacity cost recovery mechanism goes into place, to help keep down rate increases on our existing retail positions (for EWS);
A reduction in GP's ROE if the automatic capacity recovery mechanism is approved; to limit rate increases on our existing retail positions (for EWS).

Andy and Mark, please give me your suggestions.  I will schedule follow-ups as needed.  Mark, I have talked to Gary Taylor and he is working up some hedge examples that will be very useful.  Also, Bob Frank and I had a very general discussion with Dynegy about our issues.  They have intervened in this case also and may be supportive.  Do you have any objection to sharing our views with them?  They could be very helpful.  

Mike, I think this is the first rate case where Enron is intervening in a closed state (Georgia).  It's certainly likely other parties will want to know our interests.  Most of the retail position is from Springs, Owens Corning, Quebecor, Rich, and Simon.  Another half-dozen contracts also have positions there.  I want to make sure you have no objection to Enron's participation.  Any suggestion on how best to characterize our interest would be great.

We have four weeks before this must be finalized so there is time.  But hearings start next week for GP's witnesses so any immediate feedback in terms of direction, etc. would be great.

Thank you.