Most industrials do not need EWG filings

We were wondering if industrials would need to file "expedited" EWG filings
in order to take advantage of the ImPower order and the FERC order on Interim
Reliability measures issued Wed. (see separate email with details of relaxed
filing requirements for industrials).

Per Dan Watkiss, if an on-site generator is wholly-owned by the parent
corporation and is not owned by a separate generating company, then there are
no holding company issues and no EWG filing is needed. Therefore, this is a
fact specific issue when we do an on-site generator deal, but in most cases
EWG filings will not be necessary.