RE: Response to Public Staff Data Request

Here's a suggestion for the equipment question:

ENA and its affiliates have contractual rights to numerous turbines, several
of which can satisfy the technical and scheduling requirements of this
project, and some of which are already manufactured. In the case of turbines
still in the manufacturing process, ENA has firm commitments for delivery,
backed by liquidated damages clauses and other financial incentives.

"Duncan, Allyson" <aduncan@kilstock.com< on 08/25/2000 07:40:52 AM
To: "Fine, Jonathan" <JFine@kilstock.com<, "'Reagan'" <Rorschak@enron.com<,
"'John Moore'" <John.Moore@enron.com<, "'Heather Kroll'"
<Heather.Kroll@enron.com<, "'Kay Mann'" <Kay.Mann@enron.com<, "'Ozzie Pagan'"
<Ozzie.Pagan@enron.com<, "'Tom Chapman'" <Tom.Chapman@enron.com<, "'Jeffrey
Keenan'" <Jeffrey.Keenan@enron.com<, "'Reagan.Rorschach@enron.com'"
<Reagan.Rorschach@enron.com<
cc: "Grigg, Mary" <mgrigg@kilstock.com<

Subject: RE: Response to Public Staff Data Request

I have received material from Reagan in response to Question No. 5--thanks.
Reagan, do you have problems providing the total project cost under seal?
We can file as is, but I expect the public Staff will want to follow up.
Also, we do have the cost data, and are filing that under seal. I have
indicated that we will file the supporting documentation next Tuesday. The
only thing we are awaiting to day is the paragraph explaining that turbines
are indeed available.

I did want to call your attention to the fact that I took a sentence out of
the response to No. 17 regarding Enron's intent to operate the plant as a
merchant facility after the expiration of the PPA. You have been very
straightforward about that and it is clear from the rest of the answer.
However, given the Commission's skittishness about merchant facilities, I
would rather not highlight it.

We would like to file the responses by the end of the day, with the
exception of the supporting documentation on the cost data.

-----Original Message-----
From: Fine, Jonathan
Sent: Thursday, August 24, 2000 4:18 PM
To: 'Reagan Rorschach'; John Moore; Heather Kroll; Kay Mann; Ozzie
Pagan; Tom Chapman; Jeffrey Keenan
Cc: Duncan, Allyson; Grigg, Mary
Subject: Response to Public Staff Data Request

Attached is the latest draft of our responses to the Public Staff's data
requests. Please let us know of any suggested revisions or other comments
you may have. Once cost data (Request No. 1), other facility data (Request
No. 5) and some more information regarding the turbine purchase source
(Request No. 11) is received, we will file the responses shortly thereafter.
Intervention deadline is Sept. 8.

We did just a few minor edits of what John and Heather e-mailed to us --
nothing substantive.

Question: Do you need us to set up "Edgecombe Development Co., LLC" here as
a NC LLC? Just let me know. We have some folks that can do that for you
quite efficiently.

Look forward to your comments. Thank you.

Jonathan M. Fine
Kilpatrick Stockton, LLP
3737 Glenwood Ave., Ste. 400
Raleigh, NC 27612
TEL: (919) 420-1700
FAX: (919) 420-1800
http://www.kilstock.com