Message-ID: <15527087.1075852523158.JavaMail.evans@thyme> Date: Wed, 10 Oct 2001 16:55:45 -0700 (PDT) From: d..steffes@enron.com To: dave.perrino@enron.com, l..nicolay@enron.com, john.shelk@enron.com, sarah.novosel@enron.com Subject: RE: Chairman Barton's Draft Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: quoted-printable X-From: Steffes, James D. X-To: Perrino, Dave , Nicolay, Christi L. , Shelk, John , Novosel, Sarah X-cc: X-bcc: X-Folder: \JSTEFFE (Non-Privileged)\Steffes, James D.\Sent Items X-Origin: Steffes-J X-FileName: JSTEFFE (Non-Privileged).pst I think it's a fair statement that Enron doesn't currently support the Bart= on language. On this issue, I would argue that any penalty imposed should = remain the purview of FERC and its procedures. Jim -----Original Message----- From: =09Perrino, Dave =20 Sent:=09Tuesday, October 09, 2001 11:13 PM To:=09Nicolay, Christi L.; Shelk, John; Steffes, James D.; Novosel, Sarah Subject:=09RE: Chairman Barton's Draft Christi, No, my concern was more of an organization like "NERC" imposing financial p= enalties on a grid user. I thought our postion was that an RTO through its= tariff rules or FERC could impose any penalties, but not a reliability org= anization.=20 Thanks, Dave -----Original Message----- From: =09Nicolay, Christi L. =20 Sent:=09Tuesday, October 09, 2001 12:48 PM To:=09Shelk, John; Perrino, Dave; Steffes, James D.; Novosel, Sarah Subject:=09FW: Chairman Barton's Draft I do have a concern from the standpoint that users are ultimately at the sc= heduling mercy of the operator. The operator can cut our schedule. Perhap= s this is referencing something like reserves, where a user/load serving en= tity may have gone under the reserves and it gets some penalty? -----Original Message----- From: =09Perrino, Dave =20 Sent:=09Monday, October 08, 2001 3:42 PM To:=09Nicolay, Christi L. Subject:=09RE: Chairman Barton's Draft Christi, Does=20 "Section 216(e)(1) authorizes an electric reliability organization to impos= e a penalty on the user or owner or operator of the bulk power system if it= finds, after notice and an opportunity for a hearing, that the user or own= er or operator violated a reliability standard. Section 216(e)(2) provides= for notice to FERC of penalties imposed by an electric reliability organiz= ation, and authorizes FERC to affirm, set aside or modify any penalty impos= ed by an electric reliability organization. Section 216(e)(3) authorizes F= ERC to assign enforcement of reliability standards to regional transmission= organizations. Section 216(e)(4) authorizes FERC to enforce reliability s= tandards and impose penalties on user or owner or operator of the bulk powe= r system if FERC finds, after notice and opportunity for a hearing, that th= e user or owner or operator has violated or threatens to violate a reliabil= ity standard and this action affects or threatens to affect reliability of = the bulk power system. Section 216(e)(5) authorizes FERC to take such acti= on as is necessary or appropriate against an electric reliability organizat= ion"=20 Give us heartburn?=20 Just wondering, Dave -----Original Message----- From: =09Nicolay, Christi L. =20 Sent:=09Wednesday, September 26, 2001 12:43 PM To:=09Lindberg, Susan; Comnes, Alan; Perrino, Dave; Walton, Steve Cc:=09Shelk, John; Steffes, James D.; Hueter, Barbara A.; Guerrero, Janel; = Novosel, Sarah Subject:=09FW: Chairman Barton's Draft Susan --Can you check with Ben Jacoby and Fletcher Sturm on the TVA parts a= nd with Rogers Herndon on the retail consumer aggregation parts. West guys--BPA is discussed in this. -----Original Message----- From: =09Shelk, John =20 Sent:=09Wednesday, September 26, 2001 12:37 PM To:=09Nicolay, Christi L.; Lindberg, Susan Subject:=09Chairman Barton's Draft Attached are: (1) highlights summary; (2) section-by-section summary; and (= 3) almost 150 pages of leg text (PDF doc) on Chairman Barton's draft electr= icity restructuring bill. The RTO and bundled/unbundled sections will be p= rovided "soon" (they day) (I am meeting with Mr. Barton's staff in a half h= our), but there are "voluntary RTO" provisions in the incentive pricing sec= tion since they lifted that language from Burr-Sawyer legislation. Mr. Bar= ton has publicly said his addedum will mandate RTO participation at some po= int; I should know more after the meeting. The draft below addresses a var= iety of issues, including TVA, BPA, etc., among others, that we also care a= bout. There is a retail consumer aggregation feature toward the end. If y= ou could look at the summary and section-by-section and let me know particu= lar areas of interest/concern for further review that would be helpful. Ba= rton is taking comments through this week and next week. << File: BartonDraftHighlights092101.doc >> << File: BartonDraftSecBySec0= 92101.doc >> << File: discussion draft september 21.PDF >>