Interconnection Tax Gross Up and Meters

Most of the current interconnection agreements contain language requiring a
tax gross up and, possibly, purchase of the utility's preferred meter (with
the utility to own the meter.)

First, there may be possible structures to minimize the tax gross up for
contributions in aid of construction (CIAC). Contact ENA tax counsel when
working on these deals.

Second, Enron pipelines have allowed the customer to purchase and own its own
metering equipment, as long as such equipment meets the pipeline
requirements. This would have tax gross up implications because the utility
would own less equipment. Let me know if a utility is requiring metering
equipment and we would rather use and own our own equipment.

Thanks.