Message-ID: <6035036.1075843194320.JavaMail.evans@thyme> Date: Thu, 28 Sep 2000 11:21:00 -0700 (PDT) From: jeff.dasovich@enron.com To: susan.mara@enron.com Subject: Re: Cal ISO Amendment 30 Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Jeff Dasovich X-To: Susan J Mara X-cc: X-bcc: X-Folder: \Jeff_Dasovich_Dec2000\Notes Folders\Sent X-Origin: DASOVICH-J X-FileName: jdasovic.nsf Thanks. Please continue to include me on all the FERC related ditties. Mary agree that we don't need to file separately? Susan J Mara@EES 09/28/2000 06:04 PM To: Mary Hain/HOU/ECT@ECT@ENRON cc: @ENRON, @ENRON, Paul Kaufman/PDX/ECT@ECT@ENRON, James D Steffes/HOU/EES@EES, Tim Belden/HOU/ECT@ECT@ENRON, Robert Badeer/HOU/ECT@ECT@ENRON, Jeff Richter/HOU/ECT@ECT@ENRON, carrrn@bracepatt.com@ECT@ENRON, rcarroll@bracepatt.com, Jeff Dasovich/NA/Enron@Enron, Mona L Petrochko/SFO/EES@EES Subject: Re: Cal ISO Amendment 30 WPTF has just voted to file a protest on Amendment 30 (the ISO is asking to be able to buy power for itself in the forward market). I agreed to fund as did 4, maybe 5, others. The discussion was not exactly as you describe below but I will be able to have lots of input on the filing, and am sure I can get the points included. Therefore, I recommend that Enron NOT make a separate filing on this. Here is what WPTF voted on: Ask FERC to limit ISO procurement only to the super peak product that has already been developed by the APX and require that the price caps end in 6 months; if the ISO wishes to renew the price caps it would have to file 60 days in advance of the 6-month deadline. Mary Hain@ECT 09/28/2000 12:28 PM To: Susan J Mara/SFO/EES@EES cc: @ENRON, @ENRON, @ENRON, Paul Kaufman/PDX/ECT@ECT, James D Steffes/HOU/EES@EES, Tim Belden/HOU/ECT@ECT, Robert Badeer/HOU/ECT@ECT, Jeff Richter/HOU/ECT@ECT, carrrn@bracepatt.com Subject: Cal ISO Amendment 30 Sue- in WPTF's protest of Amendment 30, is WPTF proposing to make the following arguments? If not we need to have Ron give an estimate for an RCR and draft a protest. Amendment 30, which would allow the Cal ISO to do limited forward contracting and to allocate the costs thereof to under/overschedulers (protests due Oct.2)the traders would like to say that the ISO should not be in the forward market, rather the IOUs should be in the forward market and should be incented to do so. Rather than doing anything to fix this failure to hedge and underscheduling by the IOUs, this filing would further amplify the problem by concentrating even more transactions with the ISO and lead to the slippery slope to the ISO running the entire market. Since, the filing also creates other problems. Through the proposal to do bilateral deals without first receiving bids, the ISO moved itself out of compliance with Order No. 2000 (assuming it ever complied) by starting to violate the independence characteristic - the FERC's first minimum characteristic for an RTO. Under this, the RTO is required to be independent of market participants. Order No. 2000 defines a market participant as any entity or its affiliate that buys or sells electric energy in the RTO's region or in any neighboring region that might be effected by the RTO's actions. Further, the ISO is already buying out of market and this move would further complicate existing problems that we have with OOM. In addition, although the filing claims that it's request is limited, yet there is no time limitation. Further, the limitation seems to have little real effect. Enron Capital & Trade Resources Corp. From: "Ronald Carroll" 09/19/2000 03:23 PM To: , , cc: Subject: New California Filings There have been several recent filings related to California that you may wish to intervene in and/or protest: 1. CAISO proposal to extend price cap (ER00-3673-000) (due Oct. 5); 2. CAISO compliance filing with San Diego order to make limited forward contracting and to allocate the costs for those contracts to SCs whose forward schedules do not reflect their actual real-time demands. (ER00-3636-000) (due Oct. 2); 3. City of Vernon filing to join ISO (EL00-105-000) (due September 29). This filing triggers the CAISO's TAC charge effective 1/1/01; 4. Complaint by Cities of Anaheim, Azusa, etc. regarding the CAISO's collection of OOM incurred to meet system reliability and to require the CAISO to abide by the cap in Neutrality Adjustment Charge. Please let me know as soon as possible if you wish to intervene in and/or protest any of these filings. Thanks. Ron