RE: Comments on Proposed and Alternate Decisions

Some initial comments:

Will Barnett/Wood/CPUC really care if we can't "work off" the credit? I
suspect they will be delighted. Therefore shouldn't we delete section I(C)
and rely on the arguments that (1) the Proposed Decision misconstrues the
Stipulation (can we flesh this out some? can we submit an affidavit by those
who negotiated it?); (2) that it is contrary to the parties' own course of
performance (I think we need to use this legal terminology); and (3) that it
goes beyond what SCE requested in its filing and so violates fundamental
principles of due process (notice and an opportunity to be heard) and perhaps
CPUC procedures or practices (Jeanne?). Are there any CPUC precedents we
could cite relating to arguments (2) and (3)?

-----Original Message-----
From: JBennett <JBennett@GMSSR.com<@ENRON
[mailto:IMCEANOTES-JBennett+20+3CJBennett+40GMSSR+2Ecom+3E+40ENRON@ENRON.com]
Sent: Wednesday, June 20, 2001 6:57 PM
To: Mara, Susan; Dasovich, Jeff; Smith, Martin; Kean, Steven; Williams,
Robert C.; vsharp@enron.com; wcurry@enron.com; Kingerski, Harry; Steffes,
James
Cc: MDay
Subject: Comments on Proposed and Alternate Decisions
Importance: High

Attached are drafts of the comments on the Proposed and Alternate Decisions
pertaining to the PX credit and the suspension of Direct Access.

<<X25517.DOC<< <<X25496.DOC<<

Jeanne Bennett

- X25517.DOC << File: X25517.DOC <<
- X25496.DOC << File: X25496.DOC <<