There are a few other issues we need to look into:

Larcamp told Hartsoe and I after the meeting that FERC may clarify that the 
price caps and reporting obligations apply only to bids into the PX and ISO 
-- ie no bilateral transaction will be subject to the requirements.  He asked 
if knowing this would change any of our views (esp peaking plants, though I 
suspect it's already too late for that).  My gut reaction is that so long as 
the market continues to clear through the centralized exchanges this 
"exemption" for bilateral transactions won't matter much, but let's think it 
through.  Is EOL or APX an alternative?
Massey specifically asked us to address forward markets in our comments.  
Specifically, "has FERC done everything it can to encourage forward market 
development?"  In addition to any other points we might make, I think we 
should argue that "PJMing" the market won't facilitate and may even hinder 
forward market development.  Also, we should advocate actions by FERC that 
take away second-guessing by the CPUC in order to reduce utility fears about 
contracting forward.
We have to give the Commission a way out on price caps.  We need to think 
through whether there is something we can live with here, or we should take 
the approach I took in my testimony:  FERC should encourage the state to 
provide rate protection for selected customer classes by putting those 
requirements up for bid (ie get the utility out of the commodity business as 
much as possible).
Finally, on governence issues we should argue for a narrowe role for the ISO 
as a way of diffusing the emotional governence debate.  Analogy:  if the ISO 
is simply the air traffic controller all parties will simply be interested in 
retaining the most technically competent people (not hiring or appointing 
their lackies or friends).  So long as the ISO has a role in setting prices, 
acquiring supplies or running the market, it is destined to be controversial 
and highly politicized.  Those functions should be left to the market.



	Mary Hain@ECT
	11/10/2000 11:13 AM
		 
		 To: Steven J Kean/NA/Enron@Enron, Harry Kingerski/NA/Enron@Enron
		 cc: 
		 Subject: Comments on FERC November 1 order


---------------------- Forwarded by Mary Hain/HOU/ECT on 11/10/2000 09:20 AM 
---------------------------
________________________


To: Christian Yoder/HOU/ECT@ECT, steve.c.hall@enron.com, Richard Sanders, 
Susan J Mara/SFO/EES@EES, Mona L Petrochko/NA/Enron@Enron, 
jdasovic@ees.enron.com, Paul Kaufman/PDX/ECT@ECT, James D 
Steffes/NA/Enron@Enron, Joe Hartsoe@Enron, Sarah Novosel/Corp/Enron@ENRON, 
James E Keller/HOU/EES@EES, Mike D Smith/HOU/EES@EES, Harry 
Kingerski/HOU/EES@EES, Dennis Benevides, Tim Belden/HOU/ECT@ECT, Robert 
Badeer/HOU/ECT@ECT, Jeff Richter/HOU/ECT@ECT, Alan Comnes/PDX/ECT@ECT, Steve 
Kean, Richard Shapiro, Tim Heizenrader/PDX/ECT@ECT
cc: carrrn@bracepatt.com, dwatkiss@bracepatt.com
From: Mary Hain/HOU/ECT
Date: 11/09/2000 05:19:03 PM
Subject: Comments on FERC November 1 order

For purposes of our discussions, Alan and I have put together an outline of 
issues raised in the FERC meeting today that we might consider putting in our 
comments to FERC.  Our written comments would also include the issues we have 
already raised in our white paper and our oral comments at FERC.  Of course 
to the extent we have discussed things in our white paper we could simply 
cite the paper.  Given the potentially long list of issues to be addressed, I 
haved left a voice mail asking Seabron if he is available to help Alan.