I know that WPTF is supporting Hebert's approach and would suggest starting 
with $250 or higher with big increments every six months.  WPTF is also 
asking for clarification on what the cap applies to.  I don't recall what the 
comments said on refund and I haven't taken a look at the WPTF final yet.  
I'll let you know.  I'll check on the others today.



	James D Steffes
	11/22/2000 07:30 AM
		
		 To: Alan Comnes/PDX/ECT@ECT, bernadette Hawkins/Corp/Enron@Enron, 
gfergus@brobeck.com, Christopher F Calger/PDX/ECT@ECT, David 
Parquet/SF/ECT@ECT, Debra Davidson/PDX/ECT@ECT, Dennis Benevides/HOU/EES@EES, 
Ginger Dernehl/NA/Enron@Enron, Jeff Dasovich/NA/Enron@Enron, Jeff 
Richter/HOU/ECT@ECT, Joe Hartsoe/Corp/Enron@Enron, Joseph 
Alamo/NA/Enron@Enron, Jubran Whalan/HOU/EES@EES, kcurry@bracepatt.com, 
lanai.wolfe@enron.com, Marcia A Linton/NA/Enron@Enron, Mary Hain/HOU/ECT@ECT, 
Maureen McVicker/NA/Enron@Enron, Mona L Petrochko/NA/Enron@Enron, Neil 
Bresnan/HOU/EES@EES, Paul Kaufman/PDX/ECT@ECT, rcarroll@bracepatt.com, 
Richard Shapiro/NA/Enron@Enron, Robert Badeer/HOU/ECT@ECT, Sarah 
Novosel/Corp/Enron@Enron, Steven J Kean/NA/Enron@Enron, Susan J 
Mara/NA/Enron@Enron, Tim Belden/HOU/ECT@ECT, Richard Shapiro/NA/Enron@Enron
		 cc: 
		 Subject: Enron's Response Today - Key Point to Focus On

As I've been thinking about our response today, I would like Enron to focus 
on making sure that the California (WSCC) markets are as good a possible for 
business over the next 15 to 24 months.  Following that idea, I think that 
the key points are (1) clarifying/raising the soft cap and (2) reducing the 
burden/risk of the prospective refund period.

I know that we had discussed leading off with the debate over market power / 
retroactive refunds, but I think that (a) FERC is not inclined to do much 
more on this issue, (b) FERC wants to fix the market as much as it can given 
the current political realities, and (c) if retroactive refunds become an 
issue, we still have our full compliment of resources to later fight this 
fight.

I would recommend that the pleading and Alan's testimony be modified to bring 
these issues to the top of the ticket.   We should still include all of our 
other arguments.

Finally, I want to make sure that Enron is taking the right position by 
quietly supporting a $250/Mwh soft cap with safe harbor fixes?  Sue Mara, can 
you please try and find out what EPSA, IEPCA, and WPTF are going to file?  I 
want to make sure that we are in the ball park on this issue but not getting 
too soft.

Jim