FYI
---------------------- Forwarded by Kay Mann/Corp/Enron on 08/31/2000 03:57 
PM ---------------------------


"Boyd J. Springer" <bjspringer%JONESDAY@JonesDay.com> on 08/31/2000 03:33:34 
PM
To: gregg.penman@enron.com
cc: kay.mann@enron.com 

Subject: ICC Petition


_______________________________________________________________

This message and any attachments are intended for the individual or entity
named above.  If you are not the intended recipient, please do not read,
copy, use or disclose this communication to others; also please notify the
sender by replying to this message, and then delete it from your system.
Thank you.
_______________________________________________________________

Jerry Fox reports that Peoples is reviewing the Peitition and plans to
generate a new draft. Jerry indicates that Peoples does not think it will
be possible to identify a standard or guideline which the ICC could
consider with respect to the "complex" transactions covered by the
agreement (for example, pricing within a designated percentage or amount of
an index level). Do you have any thoughts on this? The Petitiion is asking
that the ICC approve these transactions in advance, so it is best to
explain as fully as possible what the transactions will look like. Jerry is
also not sure what can be said about why these transaction benefit the
public (the standard for approval under 7-101).  I had assumed that the
transactions might use otherwise idle capacity or create a credit to gas
cost otherwise recoverable under the Illinois PGA. Jerry is still
considering this. Jerry reports that Mary Klyshaaf and others spoke to the
ICC Staff about this and suggested that the affiliate agreement should be
approved because transactions under it are similar to transactions
currently on-going with non-affiliates. Jerry, however, is uncertain about
the nature of these transactions. I suggested that one approach might be to
identlfy some of the referenced transactions to see what can be said about
why they are in the public interest. If you have any ideas on these points,
please let me know. Jerry seems to agree that the Petition would be
improved if information could be added to explain why transactions under
the agreement would be beneficial to Peoples' customers.