List of Issues

We have put together the following list of issues for the request for
rehearing of the FERC's November 15 order. We would appreciate your input
about whether to pursue these issues and we will still have to decide who
will write up the various issues (Alan, Bracewell, WPTF, or EPSA). Requests
for rehearing are due on January 14, 2001.

We oppose doing away with the opportunity cost standard under the soft cap
and not establishing a standard of reasonable profit
$150 cap too low (is there any point in raising this issue again?)
Benchmarks for forward contracts - The FERC should clarify that it will not
be applying this to anything other than Cal IOU contracts.
The FERC should clarify its statement that "to the extent the IOUs' resources
exceed their load at various times, they are free to sell any surplus at
wholesale, pursuant to their Commission-filed rates schedules." A literal
interpretation of this sentence will limit liquidity in the market and
prohibit the IOUs from taking advantage of spreads between where their
generation and load is located. We don't care about the IOUs trading options
but we are concerned about less liquidity.
Commission's findings concerning exercise of market power (and PUC's request
for protective order) - This issue is a placeholder pending input from
Richard Sanders and Robin Gibbs.
We oppose the 27-month refund period
We oppose allowing the state a role in governance (WPTF)
The FERC should not have rejected Dynegy & Reliant complaint concerning being
paid the cost of cover for exports