FYI
---------------------- Forwarded by Richard Shapiro/HOU/EES on 04/05/2000 
01:50 PM ---------------------------
From: Christi L Nicolay@ECT on 04/05/2000 01:49 PM
To: James D Steffes/HOU/EES@EES, Richard Shapiro/HOU/EES@EES
cc: Joe Hartsoe/Corp/Enron@Enron, Sarah Novosel/Corp/Enron@Enron, Charles 
Yeung/HOU/ECT@ECT, Richard Ingersoll/HOU/ECT@ECT 
Subject: Joe's group accomplishments in 2000 SO FAR!!

Per Jim's request for the database.  (I don't know if you want to put the 
values that Kevin is giving into the database).  

 (1)  Completed the negotiations and FERC filing of the Next Hour Market 
scheduling proposal.  When implemented, scheduled for June 2000, this will 
provide one stop shopping for next hour business.  Ties OASIS and TAGGING 
together into one request.  Also if a tranmission provider cuts the 
transmission the PSE only pays for his actual use versus what he originally 
scheduled. This will speed up the ability to schedule the next hour 
non-firm.  This order is an important recognition by FERC that its OATT did 
not cover hourly, which we complained about alot at FERC's hotline last 
summer.

 2)  Successful in obtaining the release of all ISN (system information) to 
marketers in the WSCC region.  This was an individual effort by Dick that has 
been benificial for our traders in the WEST.  Successfully prevented the WSCC 
Operating Committee from taking action that would have reversed this effort.  

 3)  Assisted in getting the initial control areas in SERC approved last year 
and preventing ATC changes this year and OC changes that would have negated 
the Control Area effort.

 4)  Dick served as Co CHAIR of the ISO committee that put the SPP contract 
in place that eliminated MW mile pricing in SPP and will serve as the basis 
for SPP's RTO.   

 5) Dick was appointed to the NERC Control Area Task Force which was formed 
as a result of our the success of the Enron Control Areas in TVA and have so 
far been successful in keeping this effort so that it is non punitive.  This 
has turned into a very positive process that may result in a new 
configuration of the NERC relibiability effort.

 (6) Dick's made comments to ENTERGY that helped push Entergy into filing 
their new scheduling procedure (ultimate source and sink) with FERC.  This 
was initially going to be implemented unilaterally March 1 without a FERC 
filing and Enron would have been forced into an after the fact complaint 
situation at FERC where we are not allowed to get damages that we would have 
incurred in the meantime (See Comm. Massey's concurrence in Aquila v. Entergy 
about the lack of incentive to file complaints).  Kevin Presto said that 
winning the protest at FERC (due 4/12) would be worth $100 MM.

 (7)  On 2/2, TECO revised its proposed generator imbalance charge from 
minute by minute to hourly accountability (notably, TECO revised its proposal 
before FERC issued an order based on the EPSA protest herein.) We worked with 
EPSA to file an EPSA protest to TECO,s proposal.  We didn,t like TECO's 
proposal but had commercial concerns about filing a protest in our own name 
(since Enron is working with TECO on a project).   We were able to get EPSA 
to protest this issue in TECO's initial filing.  Enron is planning to site 
generation in Florida, but we don't have the value on this win yet.

             (8)  FERC issued a NOPR on January 28 proposing to revise the 
way it assesses annual charges to public utilities.  Enron, along with 
several other participants (Dynegy, Koch, APX, Citizens, NP Energy, Sonat and 
Williams), filed a petition for rulemaking with FERC in August, 1998, 
requesting FERC to revise its methodology for assessing annual charges, 
arguing that FERC's current system of assessing annual charges on sales for 
resale of power discourages trading, impedes reliance on competitive markets 
for power, and could create competitive advantages for utilities over new 
power marketers entering the market.  We proposed that FERC either assess its 
costs on transmission only, or reallocate the amounts that it collects 
through sales transactions versus transmission transactions.  Although FERC 
does not grant our petition and in fact dismisses it as moot, the petition 
served its purpose.

In the NOPR, FERC notes that because most of its time is spent on 
transmission issues (a point that we made in the Petition), it is appropriate 
to assess costs only on the MWh of electric energy transmitted in interstate 
commerce by public utilities.  Under the current assessment system, FERC 
divides its costs between transmission and sales.  Now FERC is proposing to 
collect its costs solely through transmission.  FERC justifies this change 
because it spends most of its time on transmission issues, and because 
transmission providers can collect the fees through transmission charges 
assessed to users of the grid.  FERC proposes to asses its costs to 1) 
unbundled wholesale transmission; 2) unbundled retail transmission; and 3) 
bundled wholesale power sales.  Bundled native load transactions will 
apparently avoid assessments of any FERC-related costs; however, EPSA and 
Enron are protesting this issue at FERC.  (Jim Steffes has been working on a 
calculation of additional value.)

 (9)  Interconnection Policy ) Utilizing EPSA efforts, including Sarah's 
meeting with FERC, we got the policy statement we urged FERC to put forth (in 
the forum we suggested, i.e., an existing proceeding) in the Tennessee Power 
order where FERC said interconnection procedures should follow the pro forma 
tariff, including that a generator doesn't have to request transmission and 
interconnection at the same time.  We worked with EPSA to draft the "Model" 
interconnection agreement that EPSA filed at FERC in the Entergy 
interconnection proposal.

 (10)  AEP/CSW order ) approved the merger but accepted intervenors, 
testimony showing market power and conditioned merger on an independent 
calculation of ATC postings (which we proposed) and independent market 
monitor soon after the merger occurs with RTO participation by 12/15/01.  
Kevin Presto said the independent ATC calculation is worth $20 MM to Enron.  
(Note: we are going to propose MAIN instead of SPP, which AEP chose.).  Kevin 
said that AEP's ATC calculation can trump all interfaces in ECAR, so this has 
a positive effect not just on AEP, but on all of ECAR.

 (11) MAPP ) FERC further order on refunds.  MAPP refused to refund monies 
that it was unable to collect from a non-jurisdictional member transmission 
owner, NPPD.  EPMI filed a protest to MAPP,s refund report, arguing that MAPP 
was ordered to make full refunds and it violated that order.  FERC agreed 
with Enron and rejected MAPP,s refund report.  FERC said MAPP must refund the 
full amount to transmission customers, whether or not it was able to collect 
that money from NPPD.  Results in another $50,000 of refunds for EPMI.

 (12)  Sarah is working on the PGE sale.