Message-ID: <5311938.1075840058027.JavaMail.evans@thyme> Date: Wed, 3 Oct 2001 12:01:26 -0700 (PDT) From: alan.comnes@enron.com To: tim.belden@enron.com, sean.crandall@enron.com Subject: FW: Teams for Upcoming FERC Proceedings Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: quoted-printable X-From: Comnes, Alan X-To: Belden, Tim , Crandall, Sean X-cc: X-bcc: X-Folder: \ExMerge - Crandall, Sean\Inbox X-Origin: CRANDELL-S X-FileName: Tim, Sean: This is from Rick Shapiro, GA's second in comand. It is a good overview of= everything that's going on at FERC. GAC -----Original Message----- From: =09Dernehl, Ginger On Behalf Of Shapiro, Richard Sent:=09Wednesday, October 03, 2001 8:37 AM To:=09Palmer, Mark A. (PR); Denne, Karen; Philipp, Meredith; Alamo, Joseph;= Allegretti, Daniel; Allen, Joe; Alvarez, Ramon; Arefieva, Maria; Assaf, Li= sa; Bellas, Kirsten; Benson, Eric; Bolton, Scott; Boston, Roy; Briggs, Tom;= Buerger, Rubena; Burns, Stephen; Canovas, Guillermo; Cantrell, Rebecca W.;= Comnes, Alan; Connor, Joe; Cooney, Carolyn; Dasovich, Jeff; Decker, Larry;= Dernehl, Ginger; Dressler, Jean; Floris, Vinio; Frank, Robert; Fromer, How= ard; Fulton, Donna; Guerrero, Janel; Hamilton, Allison; Hardy Jr, John; Haw= kins, Bernadette; Hemstock, Robert; Hetrick, Nancy; Hoatson, Tom; Huang, Ka= ren; Hueter, Barbara A.; Hunter, Bevin; Huson, Margaret; Ibrahim, Amr; Kauf= man, Paul; Kean, Steven J.; Keene, Patrick; Kingerski, Harry; Kishigami, Ki= kumi; Knight, Laurie; Landwehr, Susan M.; Lassere, Donald; Lawner, Leslie; = Leibman, Lara; Leonardo, Sam; Levy, Alberto; Lindberg, Susan; Linnell, Eliz= abeth; Mara, Susan; Maurer, Luiz; McVicker, Maureen; Migden, Janine; Miller= , Terri; Montovano, Steve; Moore, Bill; Nersesian, Carin; Neustaedter, Robe= rt; Nicolay, Christi L.; Nord, Sue; Noske, Linda J.; Novosel, Sarah; Ogenyi= , Gloria; Palmer, Germain; Perez, Carmen; Perrino, Dave; Petrochko, Mona L.= ; Pharms, Melinda; Rishe, Frank; Rizzo, Helen; Roan, Michael; Robertson, Li= nda; Robinson, Marchris; Rodriquez, Andy; Ryall, Jean; Shapiro, Richard; Sh= elk, John; Shortridge, Pat; Staines, Dan; Steffes, James D.; Stransky, Joan= ; Stroup, Kerry; Sullivan, Kathleen; Sullivan, Lora; Thome, Jennifer; Tiber= i, Fino; Twiggs, Thane; Walton, Steve; Warner, Geriann; Yeung, Charles; Yoh= o, Lisa Cc:=09Hiltabrand, Leslie; Radford, Pat Subject:=09Teams for Upcoming FERC Proceedings As you know, the Commission last week issued several important notices and = papers regarding various policy initiatives that the Commission plans to ad= dress over the next few months. These issues are extremely important to En= ron and we have been urging FERC to address and resolve (most) of these iss= ues for many years. There is now a Commission in charge that looks like it= is ready to act, and we need to be ready to respond. =20 In an effort to coordinate our efforts, we have developed coverage teams to= respond to these FERC initiatives. The Washington advocacy group will als= o work closely with all of these teams. If someone is interested in a part= icular issue and was not included on that team, please feel free to call th= e Project Lead to have your name added to the team. All assistance is welc= ome. As you will see on the attached chart, many of the deadlines for resp= onding to these initiatives are within the next few weeks, so the teams nee= d to mobilize and establish a game plan for our responses very quickly. On the attached chart, we have listed in the left column each of the FERC i= nitiatives that will be starting or are currently underway. A "Project Lea= d" has been named for each initiative. The Project Lead will be responsibl= e for developing and initiating a game plan for how Enron will respond in t= he proceeding. The Team Lead will be contacting each of you within the nex= t couple of days to set up processes and procedures for moving forward. Th= e team will be responsible for the initial determination of what issues sho= uld be addressed, what is the best way for Enron to respond to them, and pr= oducing draft comments. Once draft comments are prepared, the comments wil= l be circulated to a much wider group of Government Affairs and commercial = people to ensure that the team has captured all of Enron's important issues= . =20 There is a column of "Inside Counsel" and "Outside Services." In some area= s, we plan to use outside counsel or consultants and in others we do not. = Where we do not list outside counsel, we will rely on our inside counsel to= draft the comments (with significant input from the team members). Please= remember, however, that even if outside services are listed, the RCR proce= ss must still be followed. If applicable, Project Leads should submit the = necessary RCR request as soon as possible. The following is a brief description of each proceeding and the Project Lea= d named for each proceeding: RTO Meetings and Comments to NOPR: Sarah Novosel and Christi Nicolay will = be the Project Leads in this proceeding. The RTO meetings will be held in = Washington from October 15-19, and we hope to have an executive from Enron = make a presentation on one of the panels. Comments will be submitted to FE= RC regarding the appropriate market design for RTOs. This team will also b= e responsible for these comments. Standards of Conduct NOPR: Lisa Yoho will be the Project Lead. Comments a= re due in approximately 45 days. Several issues are raised in this proceed= ing, including a proposal to apply the standards of conduct to a utility's = marketing affiliate buying and selling power to serve native load. This is= a significant action for FERC and we will strongly encourage the Commissio= n to adopt this bold proposal. ICAP Inquiry: Christi Nicolay will be the Project Lead. Chairman Wood has= indicated that he is not very familiar with capacity and reserve requireme= nts, whether they are needed, and what impact such requirements have on the= market. Enron has been a strong opponent of ICAP for many years, and we p= lan to show FERC that ICAP requirements are not needed. We will submit exp= ert testimony on this issue. California Audit and Westwide Price Cap Mitigation: Alan Comnes will be th= e Project Lead. Commissioner Brownell is leading a FERC audit of the Calif= ornia ISO. Although we do not have details of what the audit is intended t= o cover or how expansive it will be, we need to carefully monitor this proc= eeding and have input into the audit process where possible. Furthermore, = a request for rehearing is pending before the Commission regarding the curr= ent price cap mitigation measures. The Commission implemented these caps i= n an effort to limit price spikes in California. California's summer peaki= ng season is over, but the Pacific Northwest's winter peaking season will b= e starting soon, and the mitigation measures currently in effect could disc= ourage power sellers from selling power to the Northwest, where it will be = needed this winter. This team will be responsible for both of these procee= dings. Transmission Constraint and Energy Infrastructure Issues: Steve Walton is = the Project Lead. FERC staff is studying two significant transmission cons= traints - California's Path 15 and the Central East Interface in New York = -- and plans to have the study completed later this year. The Commission p= lans to forward the study to DOE. The Commission stated that this is a hig= h priority for it. In a relating proceeding, the Commission has stated tha= t it will hold four open meetings in different regions of the country to id= entify energy infrastructure issues. The team will also oversee the progre= ss in these proceedings. Revised Public Utility Filing Requirements: Susan Lindberg is the Project = Lead. The Commission has issued a NOPR proposing to require market partici= pants to provide more information than is currently required, including at = least seven additional data points per transaction. This will have a signi= ficant administrative burden on Enron and could require the disclosure of c= ommercially sensitive information. Comments are due on October 5. California Refund Proceeding: Ray Alvarez is the Project Lead. The Commis= sion has ordered power sellers to pay refunds for sales made to the Califor= nia ISO from October 2, 2000 through June 20, 2001, and has established a h= earing proceeding to resolve issues of material fact. =20 Pacific Northwest Refund Proceeding: Bob Frank is the Project Lead. The J= udge in this proceeding issued an initial decision recently finding that re= funds are not warranted in the Pacific Northwest. Briefs will be filed in = response to the decision, and the Commission will review the Judge's order.= =20 Midwest/Alliance RTO Proceeding: Mike Roan is the Project Lead. Various f= ilings are pending before the Commission regarding establishment of two RTO= s in the Midwest - the Alliance RTO and the Midwest RTO. Enron is advocati= ng, consistent with the Commission's recent pronouncements, one single RTO = in the Midwest. The Commission is expected to act on these filings shortly= . Proceedings may be ordered. Northeast RTO Proceeding: Sarah Novosel is the Project Lead. Mediation to= create a single Northeast RTO has concluded and the Judge's report is pend= ing before the Commission. A Commission order is expected on or before Oct= ober 31. Additional proceedings may be ordered. Southeast RTO Proceeding: Christi Nicolay is the Project Lead. Mediation = to create a single Southeast RTO has concluded and the Judge's report is pe= nding before the Commission. A Commission order is expected on or before O= ctober 31. Additional proceedings may be ordered. =20