Subject: Re: Draft Energy legislation
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Tue, 12 Jun 2001 23:26:00 -0700 (PDT)

Tom --

My comments on the legislation called the "Electric Energy Regulatory 
Coordination and Reliability Act" -

1. Why did we exclude the Federal power marketing administrations, TVA, 
etc.?  Are those facilities regulated in a different section?

2. Why do we limit the FERC's authority (on pg 8) from regulating 
"transmission in intrastate commerce"?  This is a loophole that could be 
abused by many parties.

3. I am very concerned about the "independence" language (pg 10).  Today NERC 
has an "independent" Board of Trustees that is elected by the Stakeholders.  
Would NERC meet this criteria?  If it would, then the lanaguage needs to be 
strenghthened.  

4. We should add something that authorizes the FERC to implement a 
"Reliability Standards Fee" onto each Transmission Provider.  One of the key 
problems with NERC today is that the funding vehicle still resides with the 
Regional Councils and therefore with the IOUs.  The NERC Board of Trustees 
has no method to raise funds except to get approval of the Stakeholders.  
This will become the key problem very soon.  The total NERC budget is $12 MM 
/ year.  This is nothing if allowed into rates.

Thanks,

Jim