Message-ID: <31656545.1075861589934.JavaMail.evans@thyme> Date: Fri, 9 Nov 2001 10:26:06 -0800 (PST) From: alan.comnes@enron.com To: james.steffes@enron.com, sarah.novosel@enron.com Subject: FW: EPSA MBR Paper Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: quoted-printable X-From: Comnes, Alan X-To: Steffes, James , Novosel, Sarah X-cc: X-bcc: X-Folder: \JSTEFFE (Non-Privileged)\Steffes, James D.\FERC\FERC MBR Proceeding X-Origin: Steffes-J X-FileName: JSTEFFE (Non-Privileged).pst FYI -----Original Message----- From: Neason, Judy [mailto:Judy.Neason@williams.com] Sent: Friday, November 09, 2001 9:41 AM To: 'Erin Perrigo'; fallonr@dsmo.com; mfgildea@duke-energy.com; Steve.Hunto= on@dynegy.com; acomnes@enron.com; dennis.capella@exeloncorp.com; jeffrey.ro= ark@mirant.com; jack.hawks@neg.pge.com; jadillon@pplweb.com Cc: Julie Simon; Sheridan, Amy; Goldberg, Alex; Thuston, Tim Subject: RE: EPSA MBR Paper Erin,=20 Thanks for the advance copy of the paper. While there are a number= of very good points made in the paper, Williams has a fundamental problem = with EPSA endorsing a new market power test that is more stringent than we = think is necessary. We would recommend that EPSA support the Limited Compe= ting Supplier Test, or perhaps simply take the position in option 5 (no tes= t for bid-based markets operated by an ISO or RTO). We simply believe that= EPSA should not be "negotiating with itself" at this juncture. That is, w= e should not assume that the majority of the Commissioners are with Massey.= We should use this paper to argue to the other Commissioners and staff th= at if they move off Hub and Spoke, they only need to move incrementally, no= t dramatically. In making this recommendation we recognize that this may n= ot be enough for FERC and we may not like what we end up with. But William= s is simply not prepared to support a position we really don't agree with i= n the hope that we can avoid an even worse result. I particularly recall L= inda Breathitt's reservations about these issues (voiced at the meeting a m= onth ago) and am hopeful that we can influence Wood and Brownell in this re= gard. The language that reiterates EPSA's position that FERC's primary fo= cus should be on getting market design right is very well done. Also the a= rguments on why it would be disastrous to condition our market based rate a= uthority is well done and timely. We recognize that EPSA has been working on this issue for weeks now= , but this is not a simple issue and we have needed this time to think it t= hrough. We appreciate your efforts and believe this is an important issue = for EPSA. Thanks, Judy Neason -----Original Message-----=20 From: Erin Perrigo [ ]=20 Sent: Thursday, November 08, 2001 10:06 AM=20 To: fallonr@dsmo.com; mfgildea@duke-energy.com;=20 Steve.Huntoon@dynegy.com; acomnes@enron.com;=20 dennis.capella@exeloncorp.com; jeffrey.roark@mirant.com;=20 jack.hawks@neg.pge.com; jadillon@pplweb.com; Neason, Judy=20 Cc: Julie Simon=20 Subject: EPSA MBR Paper=20 Attached is the last draft of the MBR paper from Boston Pacific. We are no= t sending it to the entire group at this point - but would like provide tho= se who have been most active an opportunity to see it one more time. We'd = like to have all comments by tomorrow, COB. -Erin=20 Erin N. Perrigo=20 Manager of Policy=20 Electric Power Supply Association=20 1401 New York Ave., NW=20 11th Floor=20 Washington, DC 20005=20 p) 202.628.8200=20 f) 202.628.8260=20 eperrigo@epsa.org