Kevin wants to hold off filing this RTO pleading until after our meeting with 
Kevin on Thurs. at 4:00.


   
	
	
	From:  Christi L Nicolay                           11/14/2000 06:29 PM
	

To: dwatkiss@bracepatt.com, sbuchheit@bracepatt.com, Mark 
Palmer/Corp/Enron@ENRON, James D Steffes/NA/Enron@Enron, Sarah 
Novosel/Corp/Enron@ENRON, Joe Hartsoe/Corp/Enron@ENRON, Donna 
Fulton/Corp/Enron@ENRON, Richard Shapiro/NA/Enron@Enron, Steven J 
Kean/NA/Enron@Enron, asettanni@bracepatt.com
cc:  

Subject: SE RTO protest w/ press info.

Dan--  Please put the attachment into filing format in order to make a filing 
in each of the current RTOs this Thursday 11/16.  Then, our detailed protests 
will be made on Monday 11/20, as planned.

Mark Palmer asked that you forward the Thursday filings to your press 
contacts with a statement that unless properly structured, the RTO filings 
could end up being "Really Terrible Options."

Also, we will decide probably Friday or Monday on whether we file this 
attachment in FPL's current request for market based rates continuation, 
Docket ER97-3359-003 due Monday 11/20, so please prepare that filing.

We can also file the attachment in Ameren when FERC notices Ameren's recent 
request to quit MISO to join Alliance (rather than filing in Ameren Docket 
No. ER00-2687 as a request for rehearing (due 12/1)).  Thanks.
---------------------- Forwarded by Christi L Nicolay/HOU/ECT on 11/14/2000 
05:02 PM ---------------------------
   
	
	
	From:  Christi L Nicolay                           11/14/2000 06:19 PM
	

To: Shelley Corman/ET&S/Enron@ENRON, David Fairley/HOU/ECT@ECT, Ben 
Jacoby/HOU/ECT@ECT, David W Delainey/HOU/ECT@ECT, Kevin M Presto/HOU/ECT@ECT, 
Mark Palmer/Corp/Enron@ENRON, Steven J Kean/NA/Enron@Enron, Richard 
Shapiro/NA/Enron@Enron, Donna Fulton/Corp/Enron@ENRON, James D 
Steffes/NA/Enron@Enron, Ron McNamara/NA/Enron@Enron, Robin 
Kittel/NA/Enron@Enron, Joe Connor/NA/Enron@Enron, Dan Staines/HOU/ECT@ECT, 
Jeff Brown/NA/Enron@Enron, Tom Chapman/HOU/ECT@ECT, Tom 
Hoatson/NA/Enron@Enron, Janine Migden/NA/Enron@Enron, Kerry 
Stroup/NA/Enron@Enron, Janet R Dietrich/HOU/ECT@ECT, John J 
Lavorato/Corp/Enron@Enron
cc:  

Subject: FPL and the SE RTO protests

Attached is the proposed protest that EPMI would file next Monday 11/20 
against FPL in its request for continuation of market based rates for its 
wholesale merchant function and affiliates.  EPMI has already filed detailed 
protests (unlike the attached generic protest) against AEP, Entergy and 
Southern due to problems with each utility's OASIS system.  EPMI plans to 
file this generic protest in other large vertically integrated utility 
requests for continuation of market based rates.  The attachment now includes 
a reference to Staff's investigation that states participation in an RTO, 
without the proper safeguards, including the elimination of the native load 
exception, will not necessarily reduce the utilities' ability to discriminate 
against third parties.  Plus, there is a reference that Staff found a 
perception that the SE is the worst area for discriminatory practices.

Please let me know if you have an issue with EPMI making this filing in FPL's 
proceeding.

Also, note:  EPMI plans to file this generic protest this Thursday in the 
current RTO proposals -- SPP, Entergy transco, Florida RTO, Southern, Grid 
south.  Then on Monday 11/20, EPMI will be filing its specific protests of 
other aspects of each RTO filing.