Subject: ADD'l INFO FOR FERC STAFF VISIT 12/7
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked]
Date: Wed, 6 Dec 2000 04:28:00 -0800 (PST)

NOTE TO STEVE, RICK, JOE AND JIM -- ENRON CONTINUES TO HAVE ISSUES WITH 
INTERCONNECTION.  THE FERC STAFF INVESTIGATION ALSO SAID THAT INTERCONNECTION 
POLICY (OR LACK THEREOF) CAN BE USED IN A DISCRIMINATORY MANNER.  DO NOT NAME 
VEPCO, BUT THIS IS A VERY RECENT EXAMPLE THAT YOU MAY WANT TO DISCUSS AT 
LUNCH.  The developers are working to fix this with VEPCO commercial people, 
so I have not been asked to call FERC yet.

---------
I discussed this with developer, Reagan Rorschach today.  Enron was working 
with VEPCO to site an IPP (Enron owned) in VEPCO.  We did not come to terms 
on the PPA this summer.  Enron would like to keep its ability to site the 
plant with the associated queue position.  VEPCO basically has "tied" our 
queue position to a PPA with VEPCO and, therefore, kicked Enron out of the 
queue when we did not execute a PPA.

VEPCO recently filed interconnection procedures with FERC that have not been 
approved yet (these procedures were not in place when we got in the 
queue--there were only very general "ask to interconnect" procedures then).  
The only place that any "milestones" are mentioned is in the Interconnection 
Agreement (which, of course, VEPCO and Enron never executed).  In addition, a 
generator can lose its queue stop for "material changes" to the project.  
Several parties protested this very loose terminology, but we do not know 
what FERC will say.  By way of comparison, Consumers recently filed 
procedures that state "material changes" mean increases in MWs > 15% or 
increasing the in service date by more than 6 months.  This issue will be 
significant because if we get our queue spot back (which I think we should), 
we may change the configuration (or a purchaser could change).  I think that 
reductions in MWs or more stable configurations should not be considered 
"material changes."  Reagan is going to speak with the commercial VEPCO 
people and I'll call their attorney if necessary.

In any event, this again is an example of the kind of problems independent 
generators continue to face until FERC establishes some general procedures or 
an interconnection rulemaking.

Tom Chapman
12/04/2000 09:31 PM
To: Sarah Novosel/Corp/Enron@ENRON, Christi L Nicolay/HOU/ECT@ECT
cc:  

Subject: Interconnection Issues

Sarah and Christi--

I have been working with Jeffrey Keenan and Reagan Rorschack on a power plant 
in NC.  This plant is in the VEPCO service territory, and so they want to 
interconnect with VEPCO.  Originally, they were working on a PPA with VEPCO, 
but this PPA fell apart in October.  VEPCO now claims that because the deal 
fell apart, our plant should be removed from the queue.

If we are removed from the queue, we will fall behind a 640 MW plant in the 
same area of northern NC.  This is of great concern to the developers because 
they are afraid that there will be no move available transmission in this 
area of the grid.  

They are looking at a number of possible avenues of recourse.  They have 
started to talk with me regarding handling this on a state level with the NC 
PSC.  But, I think that this is probably a federal issue.

Do you think that this should be handled on a federal level or on the state 
level?  Please let me know ASAP.  Thank you.

Tom Chapman

IF you need more information, let me know.