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Enron Mail |
CONFIDENTIAL
Sue, I talked to Tim Belden briefly about this filing. He thinks it is a bit of a losing battle but is supportive or a coalition (e.g., WPTF or IEP) protest. Other comments from him were: (As you noted) the ISO should require PG&E and SCE to file letters of credit, rather than state that they did not come forward. The DWR should not be setting the terms of what it will take to provide credit; the ISO (and FERC) shoudl be.\ If DWR is given access to nonpublic data and real time trading information. other creditworthy parties that are net short should also be afforded similar access. Hope this helps. Alan -----Original Message----- From: Mara, Susan Sent: Monday, May 14, 2001 3:00 PM To: rcarroll@bracepatt.com; Sanders, Richard; Christian Yoder/HOU/ECT@ECT; gfergus@brobeck.com; Steffes, James; jklauber@llgm.com; Dasovich, Jeff; Hall, Steve C.; Tribolet, Michael; Belden, Tim; Ngo, Tracy; Nicolay, Christi Cc: Alvarez, Ray; Comnes, Alan Subject: ISO Compliance Filing on Credit May Need Protest On May 11, the CA ISO made a "compliance filing" for the April 6 order on credit worthiness in the real-time market. Whereas the FERC order REQUIRED the ISO to get creditworthy parties -- the ISO portrayed it as an obligation of the buying party. Therefore, the ISO's letter says that the ONLY party to come forward to provide credit support was DWR -- and because of DWR's "fiduciary obligation to conserve the finite resources that have been placed at its disposal", DWR REQUIRED access to the ISO's control room floor and non-public data. This is outrageous and just shows that the ISO has, in effect, become a state-run, vertically-integrated utility. Question -- do we want to protest this? Or sit by and see what the generators do? If we want to comment, it would be due June 1. Sue Mara Enron Corp. Tel: (415) 782-7802 Fax:(415) 782-7854
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