Subject: Re: GIR Testimony from Indicated Producers -Open Season Testimony -Suggested Change
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Date: Tue, 2 May 2000 10:12:00 -0700 (PDT)

With regard to your open season testimony, I would remove the last paragraph
(noted below) on market concentration

"As noted above, the concentration limit applies only in the primary market.
There are currently no controls in these rules against market concentration in
the secondary market.  While the unconstricted nature of the secondary market
will facilitate more and new entrants in the capacity market, this fluid 
quality
nevertheless creates a risk of concentration, insofar as capacity that was
awarded in the initial Open Season may be assigned to any creditworthy market
participant and without market share limits.  Indeed, the Comprehensive
Settlement does not provide for a mandatory electronic bulletin board for
secondary market trades and, accordingly, tracking secondary market trades 
would
be complicated and administratively infeasible.  Nonetheless, the Commission
should remain cognizant of the risk of market concentration and commit to
respond to any such complaints raised by market participants."

With all due respect, it is a rather transparent attempt to get the Commission
to focus on on the secondary market issue. We agreed to exclude secondary 
market
acquisitions as a measure of market concentration. The above paragraph signals
the Commission that this is a problem and dilutes the value of the testimony.