Dear Editorial Review Board,

At the last EC meeting, the EC voted to send a report to the FERC regarding
the issue of cross contract ranking.  Cross contract ranking was an action
item in the 1999 annual plan that after much debate failed at the EC, so the
recommended standards were never adopted. The recommended standards failed
because the EC was unable to form a consensus around the work product.
Normally, this voting failure would be seen as evidence that the industry was
not ready for such standards as a consensus could not be built for them.

Some Commission staff  has contacted some of the EC members to better
understand why these recommended standards were not adopted.  All minutes of
the meetings and work products are posted on the home page, accessible to any
interested party.  Because of the calls made and the repeated review at the
EC (November, February and April),  some EC members proposed that a letter be
sent to the FERC and voted on specific language, which is included in the
letter.  Care was taken that the language not be misconstrued as advocacy.

Please let me know if you would like a conference call on this matter, or if
you have any comments on the attached draft.  The EC is aware that the
Editorial Review Board must approve all written communications of this type.
Typical communications with the FERC take the form of a status report, so
this is somewhat unusual.

I look forward to your responses -- Best Regards, Rae

 - cr000615 cross contract ranking.pdf