Alan:

Are you still the code of conduct person?  If not, let me know & I'll keep 
looking.

Mark
---------------------- Forwarded by Mark - ECT Legal Taylor/HOU/ECT on 
12/14/98 04:53 PM ---------------------------


Mary Solmonson
12/14/98 10:38 AM
To: Christian Yoder/HOU/ECT@ECT, Vicki Sharp/HOU/EES@EES, Sheila 
Tweed/HOU/ECT@ECT, Jeffrey T Hodge/HOU/ECT@ECT, Mark - ECT Legal 
Taylor/HOU/ECT@ECT
cc: Debbie R Brackett/HOU/ECT@ECT, Sheila Glover/HOU/ECT@ECT 
Subject: Enron-Wide Global Counterparty Implementation - Code of Conduct 
Guidance/Approval Requested

We have been asked to implement the Global Counterparty (GCP) system at 
Portland General and EES to support Global Credit Aggregation with our major 
trading partners.  This information includes Counterparty Name, various 
Address data such as documentation (confirmation), headquarters, and 
settlement (including wire bank, ABA, and routing), and various contact names 
and phone numbers such as trader, settlements, etc.

For Global Credit Aggregation to be supported most efficiently, all Enron 
companies must utilize a common identifier for the counterparty on a trade, 
i.e., Southern Energy Marketing for Portland = Southern Energy Marketing for 
ECT = Southern Energy Marketing for EES = Southern Energy Marketing for 
EPMI.  Global Credit must 'see' exposure from each affiliate for a 
counterparty as the same party to aggregate to a corporate level.

For Portland General, the list of trading partners are mostly parties we 
already have in the GCP database.  However, there will be some counterparties 
that are specific to Portland General (the same could also be true about 
EES).  For that reason, I would like to train specific individuals at each 
company to perform the GCP administration/maintenance for their 
counterparties much like we handle the ECT London and Calgary operations.  
What we will have is a system shared as depicted below :




 

There would be select individuals at each company to maintain their 
counterparty information via Terminal Server in a common database maintained 
here in Houston by ECT IT.   This type of access would give these individuals 
access to Counterparty data for all companies regardless of their own company 
affiliation. Each company/business unit will have an extract or view from the 
main database of only their counterparties to support their trading and 
downstream systems versus those systems being integrated directly with the 
main database containing all information.

What I need to know is whether any of you see a problem with this 'sharing' 
of technology and data between ECT and PGE or EES and the intended 
implementation.  Based on Bill Dassenko's understanding of the FERC Code of 
Conduct, we think this proposal is within the guidelines.  Please provide any 
comments or your acceptance of this proposal by Monday, December 21st.    

Thank you.



---------------------- Forwarded by Mary Solmonson/HOU/ECT on 12/14/98 08:43 
AM ---------------------------


Debbie R Brackett
12/11/98 04:48 PM
To: Mary Solmonson/HOU/ECT@ECT
cc:  
Subject: Counter Party Name List

Mary,

This is the list we talked about. Reviewing it briefly, I only see a few that 
we don't already have in GCP. In discussing this with Bill (Dassenko), he 
sees no reason under the FERC code of conduct that we cannot see ( or share) 
public information  about shared counterparties such as would be populated in 
GCP. He is prohibited from sharing specific deal info or exposures, neither 
of which would be an issue in GCP. Hope this helps...I'll be back in on 
Tuesday and we can talk more if you need to.

Debbie 
---------------------- Forwarded by Debbie R Brackett/HOU/ECT on 12/11/98 
04:41 PM ---------------------------
From: HQ3.EM5:Bill Dassenko AT PORTLAND_PO@CCMAIL on 12/11/98 03:58 PM
To: Debbie R Brackett@ECT
cc:  
Subject: Counter Party Name List


Date:  12/11/1998  03:58 pm  (Friday)
From:  Bill Dassenko
To:  Brackett, Debbie R
Subject:  Counter Party Name List

Debbie,
Attached is a file containing PGE's list of counterparties.  There are a few 
financial counterparties which I have not yet included on this list. All 
names on the list are wholesale counterparties with which PGE trades power or 
gas or are wholesale customers.  There are no retail customers on this list.

In general, under the FERC "Code of Conduct" rules established for working 
with affiliated companies, the unregulated entity (ECT, EPMI) can tell all to 
the regulated entity, but the regulated entity (PGE) can share in only the 
most general of terms. Further,  PGE conversations can not convey any 
information which is otherwise not public about PGE's markets or customers.  
Although the question is a good, I believe I have more to worry about when 
talking to you than what you do when talking to me. Given that I have 
included as complete a list as I have.

Christian Yoder is the ECT lawyer who is tasked with code of conduct
issues for ECT.  His phone number is 503-464-7845.
 - List.xls