Meeting at FERC with Andrea Wolfman

Two weeks ago, EPSA had a FERC Outreach meeting with FERC's Office of Markets
Rates and Tariffs staff to discuss issues of importance to EPSA members. Jim
Steffes attended the meeting on behalf of Enron. During the meeting, one of
the issues raised was the lack of comparable transmission service between
network and point to point service. Several staffers (including Don Gelinas)
expressed interest in ways that FERC could address this comparability
problem. After the meeting, Julie Simon met with Andrea Wolfman (head of
Market Oversight) and Andrea also expressed an interest in the issue.

Julie scheduled a meeting with Andrea and Ginny Strasser for today for EPSA
members. I attended the meeting, along with representatives from Williams,
Duke, Dynegy, Mirant, and Reliant. We told Andrea and Ginny that now that
FERC has issued its order on California, it's time to focus on the rest of
the country, and we have real problems, one being lack of comparable
transmission service -- namely, that utilities have network service and we
have point to point service.

While a lot of the conversation was based on generators' problems in
interconnecting to the grid (due to the problems with using point to point
rather than network service), we also discussed that this is a problem for
all transmission customers, not just generators. Andrea asked if providing
some kind of new "Network Plus" type of service would also require
elimination of the native load exception. We explained that while the native
load exception must be eliminated, there is still a need for a Network Plus
type service because network is a superior service to point to point, and
utilities will still have access to this superior service, even when the
native load exception is eliminated. The point of this meeting was not to
ask FERC to deal with the native load issue in this meeting -- Julie felt
that because Don Gelinas expressed interest in solving the network problem,
that we should respond to his interest, rather than trying to get our entire
agenda passed all at once.

Andrea seemed receptive to our ideas and suggested that we need to educate
FERC staff. She also noted that if the Commissioners make this a priority of
theirs, that FERC staff will be much more willing to learn the issue and find
a way to solve the problem.

EPSA is going to work on a position paper on this new type of service. At
the Function 8 (seams issues) Technical Conference yesterday, both Pat Wood
and Nora Brownell were interested in the comparability issue and ways to
address it. So, we need to get the Commissioners on board with the idea
(Massey is already there, which he indicated in his concurrence in the
Entergy Source and Sink order) and begin to educate FERC staff.

Please let me know if you have any comments or ideas. I will circulate the
EPSA draft position paper once I receive it.

Sarah