Subject: RE: Compliance Agreement
From: [email-masked]
To: [email-masked]
Cc: [email-masked]
Date: Wed, 28 Mar 2001 23:53:00 -0800 (PST)

What's this about?  Could you e-mail Dave and I with the background, any 
effect on us, etc.?  Why was Dave on this distribution?
----- Forwarded by Steven J Kean/NA/Enron on 03/29/2001 07:51 AM -----

	David W Delainey@EES
	03/28/2001 08:33 AM
		 
		 To: Steven J Kean/NA/Enron@Enron, Ana Shafer/ENRON@enronxgate
		 cc: 
		 Subject: RE: Compliance Agreement

?????
---------------------- Forwarded by David W Delainey/HOU/EES on 03/28/2001 
08:32 AM ---------------------------

"Michehl R. Gent" <[email-masked]> on 03/25/2001 06:04:51 AM
To: "David Cook" <[email-masked]>
cc: "Dave Delainey" <[email-masked]> 
Subject: RE: Compliance Agreement

David:

Nice job!  Can you imagine the "fun" someone is going to have if a Region,
say SPP, MAIN, MAPP, WSCC, or FRCC, has a major blackout this summer and the
"loyal opposition" "discovers" that said region has refused to sign an
agreement such as this and not implemented the program required by the
agreement.  That may even constitute "willful neglect."  Wouldn't it be even
worst if the "discovery" showed that the region was not signed because the
region wanted to use it's position as a bargaining ploy? (SPP, FRCC, and
WSCC) Oh no, I sound like a wantabe lawyer!

Mike

-----Original Message-----
From: David Cook [mailto:[email-masked]]
Sent: Saturday, March 24, 2001 4:19 PM
To: [email-masked]
Subject: Compliance Agreement

Regional Managers
Compliance Task Force

As we discussed on the conference call on Friday, I have prepared a simple
draft letter of intent for the use of those regions who wish to indicate
support for the regional compliance and enforcement program, but are not
yet in a position to sign the Agreement for Regional Compliance and
Enforcement Programs that the NERC Board of Trustees approved on February
13.

For the benefit of those who were not on the call, I'd like to recap where
things stand at this point.  My apologies if I mischaracterize anyone's
position.  NPCC and ERCOT have signed the agreement.  ECAR has stated it
will sign the agreement at the signing ceremony on March 30.  SPP is
prepared to sign the agreement, but doesn't want to be the only one it its
part of the Eastern Interconnection to do so.  FRCC was not on the call,
but has previously stated that it is prepared to sign so long as at least
six regions sign.  MAPP and MAIN have indicated that they prefer to develop
their program with their own members before they sign the NERC
agreement.  WSCC may need to consider the matter at its Board meeting in
early April.  SERC has the matter under consideration.  I have not heard
from MAAC, but it has a meeting scheduling for March 29.

I want to share with you my concern for the climate in Washington.  In the
past few weeks I have had occasion to speak with a number of people on
Capitol Hill and in the new Administration.  All are very concerned about
what might happen this summer.  If a serious incident occurs, I am quite
sure that Congress will legislate very quickly--whether it will legislate
wisely is a different question.  We have the opportunity with this
agreement for the industry to take charge of its own destiny.  If Congress
acts it may well assign a very central role to the Federal government to
take direct responsibility for reliability.  There are those in the
Department of Energy who are pushing for such a role.   Congressman Barton
is talking of the possibility of emergency legislation, possibly within the
next few weeks.  If the industry pulls together, I believe we can forestall
direct governmental controls, just as in 1965.  If the industry does not
step up, then Congress may well assign the responsibility elsewhere.

The CTG recommended to the Board that a critical mass of six Regions sign
onto the agreement before it goes forward.  For those Regions that are
considering developing their own programs with their members before they
sign the agreement, with the view of having the CAPG determine in advance
whether their programs meets the requirements of the agreement, I ask you
to consider this:  If we don't get a critical mass of Regions to sign, then
the CAPG may not come into existence.

The NERC/Regions agreement is really an undertaking by the regions to work
to develop their own regional compliance and enforcement program with their
members.  My request remains that each of the regions sign the agreement by
the March 30 Board meeting.  That will assure that we are able to make the
governance changes that we have all been working for.  If any region is
unable to sign by March 30, then use of the letter of intent would be a way
to demonstrate support for the program.  That may be enough to satisfy
those who have stated that moving forward on the compliance program is a
condition to their support of the governance changes.

Thanks very much for your consideration of the program and all the work
you've put into this transition so far.  Please let me know if you have
questions or if there is anything that we can do from here to be of
assistance to you.