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---------------------- Forwarded by Elizabeth Sager/HOU/ECT on 02/28/2000
10:10 AM --------------------------- "Andy Katz" <AKatz@eei.org< on 02/28/2000 07:42:53 AM Please respond to "Wholesale Electric Contract Standardization Group" <contract@ls.eei.org< To: "Wholesale Electric Contract Standardization Group" <contract@ls.eei.org< cc: (bcc: Elizabeth Sager/HOU/ECT) Subject: Fwd: CFTC Paul Pantano clarified my earlier email about the CFTC proposal. Sorry for the confusion. Andrew S. Katz, Senior Attorney Edison Electric Institute 701 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Voice: 202-508-5616 Fax: 202-508-5673 e-mail: akatz@eei.org Received: from mail02-ord.pilot.net (mail-ord-2.pilot.net [205.243.174.16]) by mail.eei.org; Mon, 28 Feb 2000 08:27:19 -0500 Received: from mwe.com (unknown-106-134.pilot.net [206.189.106.134] (may be forged)) by mail02-ord.pilot.net with SMTP id HAA23507 for <akatz@eei.org<; Mon, 28 Feb 2000 07:25:58 -0600 (CST) From: ppantano@mwe.com Received: by mwe.com(Lotus SMTP MTA v4.6.6 (890.1 7-16-1999)) id 86256893.0049C2F1 ; Mon, 28 Feb 2000 07:25:40 -0600 X-Lotus-FromDomain: MW&E To: akatz@eei.org Message-ID: <86256893.0049C1F2.00@mwe.com< Date: Mon, 28 Feb 2000 08:25:13 -0500 Subject: CFTC Mime-Version: 1.0 Content-type: text/plain; charset=us-ascii Content-Disposition: inline Dear Andy: I want to clarify a misunderstanding in your email to the group. While it is correct that the CFTC proposes to regulate commodities with exhaustible and nearly inexhaustible supplies differently, it has not characterized power as having an inexhaustible supply. In fact, I would expect the CFTC to treat power as having a finite supply at any given time. This means, for example, that power derivatives traded on a multilateral transaction execution facility would not qualify for exemption from the Commodity Exchange Act under the current proposal. I think the EEI and other industry groups should consider attempting to persuade the CFTC to exempt physical and derivative power contracts from certain provisions of the CEA under the CFTC's proposal to consider exemptions on a "case-by-case basis." See, for example, the discussion of DTFs on pages 9 and 10 of the proposal. I hope this clarifies the CFTC's proposal. Regards, Paul Paul J. Pantano, Jr. McDermott, Will & Emery (202) 756-8026 ****************************************************************************** ******* This message is a PRIVATE communication. If you are not the intended recipient, please do not read, copy, or use it, and do not disclose it to others. Please notify the sender of the delivery error by replying to this message, and then delete it from your system. Thank you. ****************************************************************************** *******
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