Message-ID: <30762365.1075846667893.JavaMail.evans@thyme> Date: Mon, 10 Jul 2000 01:40:00 -0700 (PDT) From: mbaldwin@igservice.com To: susan.scott@enron.com Subject: RE: brief Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: "mbaldwin" X-To: X-cc: X-bcc: X-Folder: \Susan_Scott_Dec2000_June2001_1\Notes Folders\All documents X-Origin: SCOTT-S X-FileName: sscott3.nsf Susan , Good morning. Here are my thoughts for additional items to be included in the Transwestern Opening Brief. 1)Assurance that all intrastate capacity will be made available : Socal shareholders are put at risk for Backbone transmission capacity revenue & any unutilized capacity will be made available to the market. This seemed to be of particular interest and sensitivity to the judge. Further, placing the utility at risk for unused resources was a listed promising option. 2)Existing Socal noncore customers are given 2 unique opportunities to select their receipt points & the core intrastate set asides guarantee that the core is fully protected : this suggest the transition will be smooth. Developing clear procedures for allocating capacity was an additional promising option. 3) On the topic of implementation, can we say in TW's experience the timeline outlined in the CAS is viable . While Socal will have to "create" an unbundled backbone system, the CAS allows sufficient time for Socal, Socal customers and other interested parties to be prepared and fully participate in the unbundled backbone system. Call when you have a chance. Mark,IGS > -----Original Message----- > From: Susan.Scott@enron.com [mailto:Susan.Scott@enron.com] > Sent: Saturday, July 08, 2000 3:04 PM > To: Jeffery.Fawcett@enron.com; Mbaldwin@igservice.com > Cc: Steven.Harris@enron.com > Subject: brief > > > OK, I'm liking this a little better. Tell me honestly what you > think of my > minimalist approach. The purpose of a brief is really to instruct the > judge on the law (here, there really isn't any beyond the really routine > stuff the judge works with every day, so there's no need), and/or > to sum up > for the judge why the evidence proves the legal conclusions you hope she > will adopt. To that end, I've restated Jeff's testimony as concisely as > possible, adding page cites to avoid sounding redundant. I believe that's > all our judge will need or want here. However, please feel free to > embellish where you think we need it. It is not likely that SoCal will > "carry our water" on these issues--not that we'd want them to. Also, > please let me know what you think we should say about the implementation > phase (see my note at the end of the draft). > > Since Judge Biren specifically stated she wants executive summaries to put > in front of the Commissioners, I am going to write one. It will be less > than 1 page. I'll send that to you when I think it's good enough. > > My apologies that this is so last-minute. Other than being really busy > with FERC business, I have no excuse except perhaps that I've been missing > my muse for the past week... Glad you're coming back Monday, Jeff! > > (See attached file: brief.doc)