Subject: List of Issues
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Mon, 18 Dec 2000 06:56:00 -0800 (PST)

We have put together the following list of issues for the request for 
rehearing of the FERC's November 15 order.  We would appreciate your input 
about whether to pursue these issues and we will still have to decide who 
will write up the various issues (Alan, Bracewell, WPTF, or EPSA).  Requests 
for rehearing are due on January 14, 2001.

We oppose doing away with the opportunity cost standard under the soft cap 
and not establishing a standard of reasonable profit
$150 cap too low (is there any point in raising this issue again?)
Benchmarks for forward contracts - The FERC should clarify that it will not 
be applying this to anything other than Cal IOU contracts.
The FERC should clarify its statement that "to the extent the IOUs' resources 
exceed their load at various times, they are free to sell any surplus at 
wholesale, pursuant to their Commission-filed rates schedules."  A literal 
interpretation of this sentence will limit liquidity in the market and 
prohibit the IOUs from taking advantage of spreads between where their 
generation and load is located.  We don't care about the IOUs trading options 
but we are concerned about less liquidity.
Commission's findings concerning exercise of market power (and PUC's request 
for protective order) - This issue is a placeholder pending input from 
Richard Sanders and Robin Gibbs.
We oppose the 27-month refund period
We oppose allowing the state a role in governance (WPTF)
The FERC should not have rejected Dynegy & Reliant complaint concerning being 
paid the cost of cover for exports