Subject: *** INTERRUPTIBLE CUSTOMERS CAN PARTICIPATE IN ISO A/S PROGRAM ***
From: [email-masked]
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Cc: [email-masked]
Date: Thu, 15 Jun 2000 09:56:00 -0700 (PDT)

Load is up in CA and so is the potential for selling load curtailment 
products to customers.

BOTTOMLINES:

PG&E has asked the CPUC to approve participation of E-19 and E-20 Direct 
Access customers in the ISO A/S load participation pilot program (filed June 
7).

SCE has asked the CPUC to approve that all customers on its Large Power 
Interruptible tariff can participate in the ISO A/S load participation pilot 
program (filed June 7).

FERC approved the ISO's Load Participation pilot progam and pricing on June 
14, 2000, calling it an innovative program.

This appears to be a total GREEN LIGHT for Enron to move forward with 
customers.

PROCESS:

The utilities filed advice letters.  Comments are due on June 27.  Unless you 
tell us otherwise, we plan to file and seek expedited treatment. (The CPUC 
has no required timetable in which to respond.)  We expect the CPUC to 
approve them -- there is pressure from many fronts to DO something about load 
participation in the market.  Both have asked for a July 17 effective date.

DETAILS:

SCE's is a much better document and makes a good case for CPUC approval, even 
though the the customers are already benefitting from providing the utilities 
with the option to curtail during system emergencies. SCE proposes the 
following approach to prevent "double-dipping" by the customers:  If the ISO 
directs SCE to activate its load curtailment program during the time period 
that the customer has an accepted bid from the ISO in the A/S market, SCE -- 
working with the ISO -- will adjust the customer's bill to avoid double 
payments.  SCE provides no more information, but, on principal, this seems 
fair to me.  We'll have to watch to see what the proposed procedure would be.

PG&E doesn't say much except that it is "unable" to offer this to bundled 
customers (oh, gee -- must be more of those "system constraints") until 
"later" (unspecified).  I would expect large customer groups to argue about 
that -- but it gives us the opportunity to push direct access.  PG&E didn't 
have much to offer on the "double-billing" issue -- it said either PG&E could 
change the customers bill or the ISO could adjust its payment.

FERC threw out all the protests by various parties (e.g., MWD, M-S-R, other 
munis) and approved the ISO's proposal.  The big issues were:  supposed 
improper allocation of demand relief program costs (ISO allocates it to all 
SCs based on metered demand during all hours of the program);q request to 
charge those who are out of balance for most of the costs; the need to file 
pro forma agreement in advance (FERC said ISO doesn't have to); and the 
supposed overly restrictive program participation. If you want to know more 
about the order, give me a call.

Have fun!

Sue Mara