Re: Comments on RTO West December 1st Filing

I am back in the office. I assume you are handling this and will let me see
a copy of the draft. Thanks.

Steve Walton
01/05/2001 09:34 AM
To: Mary Hain/HOU/ECT@ECT, Alan Comnes/PDX/ECT@ECT, Sarah
Novosel/Corp/Enron@ENRON
cc: Paul Kaufman/PDX/ECT@ECT
Subject: Comments on RTO West December 1st Filing

I have not gone over the filing in great detail, I have found one thing we
may want to file to address. All the parties except PGE/Sierra/Nevada agreed
to eliminate the export fees. PGE/Sierra/Nevada made a joint filing asking
the FERC to require the RTO West to include export fees and their effect in
the financial modeling of their Stage 2 filing. I think we should consider
filing comments to oppose this requiest from PGE/Sierra/Nevada for the
following reasons:

Elimination of the export fees is a positive step to resolve one of the three
major "seams" issues. With RTO West taking the lead, the other RTOs (CAISO &
DSTAR) can follow suit.
The nature and type of export fee to be used would have to be developed.
This eat up an enormous amount of time on a speculative fee which the
majority of the parties are opposed to including. The delay engendered and
use of limited resources is unconsiounable.

We can reiterate our concerns regarding allocation of rights instead of an
auction and about the potential exclusion of facilities from the RTO West
control. The December 1st filing really doesn't change those things. Since
the comments are due on the 16th and I will be gone all next week, I thought
I had better let you know my views before leaving.

I am including the IPP/Marketers comments for reference.

Steve