Unfortunately the CEC did NOT approve our label proposal (reasoning below).  
EESI has a couple of options for the product label, including (1)  2 
different product labels for the 5000 product where one label is for 
commercial customers receiving 100% green (ensuring these customers where 
5000 kwh in demand p/mo or less) and one for industrial customers (with a 
percentage green + system mix); and (2) aggregating all customers together 
and weighting the green percentages accordingly.   George & Richard are you 
available this afternoon to discuss?
---------------------- Forwarded by Stacey Bolton/HOU/EES on 08/18/2000 12:47 
PM ---------------------------


"Robert Grow" <Rgrow@energy.state.ca.us> on 08/18/2000 11:15:28 AM
To: <sbolton@enron.com>
cc: <Cholmes@energy.state.ca.us>, <DJohnson@energy.state.ca.us>, 
<Kgriffin@energy.state.ca.us>, <Mjones@energy.state.ca.us> 
Subject: Re: Label Calculation


Stacey:

Our counsel has reviewed your proposal.  We find that it doesn't meet our 
regulations, but it appears to represent a good faith effort to comply.  We 
cannot give official approval to labeling that is not in accord with the 
regs, but  counsel says we will not consider any sanction or punitive action 
in this case.

The problem with your proposal is that the product is represented by two 
labels, not one.  You could consider splitting the product into multiple 
products, only one of which is 100% renewable.  Even so, we think consumers 
should be able to understand the product as you have described it.

I hope this response is timely for your September billing.

Bob Grow
Program Manager
Power Source Disclosure
CA Energy Commission
(916) 654-5180


>>> "Stacey Bolton" <sbolton@enron.com> 08/15/00 04:58PM >>>


Bob:

Pursuant to our phone discussion today, outlined below is Enron Energy 
Service's
(EESI) proposed label calculation for review by your counsel.  EESI's product 
is
a 100% renewable product for the first 5,000 kilowatt hours per month.  (The
renewable energy in this product may exceed the 5,000 kwh per month depending
upon available renewable supply and the level at which the customer credit is
set.)   For any customer that exceeds 5,000 kilowatt hours of renewable energy
per month, the remainder of their product would be comprised of the California
System Mix.  Because the percentage of renewable energy that the end use
customer receives is dependent upon their size, (i.e. smaller commercial
customer might actually be receiving 100% renewable energy whereas larger
customers might be receiving only a little more renewable energy than is
contained in the CA system mix), this makes the label calculation difficult.  
It
is EESI's proposal to have two separate labels for this one product.  The 
first
label (label A) would be 100% renewable energy (representing the first 5,000
kwhs per month).  The second label (label B) would be the California System 
Mix.
EESI would explain to customers that depending upon the customer size, some
customers would be receiving "label A", provided they are 5000 kwhs per month 
in
usage or less.  For those customers that exceed 5,000 kwhs per month, the 
power
they receive would look closer to "label b" (the California System Mix).

EESI is under a tight deadline and is intending to notify customers of this
product in the September billing.  We would like to confirm with your counsel 
if
this arrangement is agreeable to the CEC and meets the standards set forth in 
SB
1305.  Please feel free to contact me with any questions regarding the label
calculation.

We greatly appreciate your assistance in this endeavor.

Sincerely,
Stacey Bolton
Manager, Environmental Strategies
Enron
713-853-9916