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Rick, I have slowed down a little on this, as the comments are not due until Dec.20 and who knows who/what will be by then. I too think that ENA (notjust EPMI) should file separately from the pipes and PGE. The LDC issue is important to the gas side, and we take the position that the new definition is good. I am not sure I share Lisa's view that the rules allow the retail function of the electrics to continue to operate outsidethe OATT, but I will scrub this.
I have jury duty today but I hope I get back to the office eventually. I cancelled my reservations to Houston for your leadership meeting because I didn't want to pay for tickets if I didn't use them, but if it still looks like a go, I will be there. Just keep me posted. -----Original Message----- From: Shapiro, Richard Sent: Friday, November 09, 2001 7:05 AM To: Lawner, Leslie Subject: FW: Some departing thoughts on the affiliate NOPR FYI -----Original Message----- From: Yoho, Lisa Sent: Thursday, November 01, 2001 1:46 PM To: Shapiro, Richard Cc: Nord, Sue Subject: Some departing thoughts on the affiliate NOPR Rick: Leslie Lawner is drafting our comments in the Standards of Conduct NOPR. She estimates that she'll have a draft ready for distribution on November 13th. The key issue, of course, is the native load issue. I'm assuming we'll hit this hard. Even though FERC is not addressing this issue head on, it is the first time (that I know about) that FERC has expressed an interest in ending the residual - and not insignificant - discrimination that is permitted to exist. My recommendation to the group is that we support FERC's proposal as a good and long-awaited first step, but it is just that - a first step. FERC's proposal would eliminate preferential access to information, but what about preferential access to transmission services? Discrimination will continue until FERC requires all users to be under the same tariff. Just so you know, my recommendation is that Enron support the application of the standards of conduct to affiliated gas LDCs. I have heard through the grapevine that certain pipes/LDCs will strongly oppose this proposal. While I know this isn't our primary issue, I feel it's an important one. Lastly, my recommendation to Steve Kean was that EPMI and our pipes/wires file separate comments. I think this is appropriate for appearance sake (it is an affiliate rulemaking after all), but more importantly because we don't want to dilute our message regarding native load. I wanted to share my thoughts with you before I depart. Thanks for listening! Lisa
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