FW: EPSA MBR Paper

FYI
-----Original Message-----
From: Comnes, Alan=20
Sent: Friday, November 09, 2001 12:26 PM
To: Steffes, James; Novosel, Sarah
Subject: FW: EPSA MBR Paper

FYI
-----Original Message-----
From: Neason, Judy [mailto:Judy.Neason@williams.com]
Sent: Friday, November 09, 2001 9:41 AM
To: 'Erin Perrigo'; fallonr@dsmo.com; mfgildea@duke-energy.com; Steve.Hunto=
on@dynegy.com; acomnes@enron.com; dennis.capella@exeloncorp.com; jeffrey.ro=
ark@mirant.com; jack.hawks@neg.pge.com; jadillon@pplweb.com
Cc: Julie Simon; Sheridan, Amy; Goldberg, Alex; Thuston, Tim
Subject: RE: EPSA MBR Paper

Erin,=20
Thanks for the advance copy of the paper. While there are a number=
of very good points made in the paper, Williams has a fundamental problem =
with EPSA endorsing a new market power test that is more stringent than we =
think is necessary. We would recommend that EPSA support the Limited Compe=
ting Supplier Test, or perhaps simply take the position in option 5 (no tes=
t for bid-based markets operated by an ISO or RTO). We simply believe that=
EPSA should not be "negotiating with itself" at this juncture. That is, w=
e should not assume that the majority of the Commissioners are with Massey.=
We should use this paper to argue to the other Commissioners and staff th=
at if they move off Hub and Spoke, they only need to move incrementally, no=
t dramatically. In making this recommendation we recognize that this may n=
ot be enough for FERC and we may not like what we end up with. But William=
s is simply not prepared to support a position we really don't agree with i=
n the hope that we can avoid an even worse result. I particularly recall L=
inda Breathitt's reservations about these issues (voiced at the meeting a m=
onth ago) and am hopeful that we can influence Wood and Brownell in this re=
gard.

The language that reiterates EPSA's position that FERC's primary fo=
cus should be on getting market design right is very well done. Also the a=
rguments on why it would be disastrous to condition our market based rate a=
uthority is well done and timely.

We recognize that EPSA has been working on this issue for weeks now=
, but this is not a simple issue and we have needed this time to think it t=
hrough. We appreciate your efforts and believe this is an important issue =
for EPSA. Thanks, Judy Neason

-----Original Message-----=20
From: Erin Perrigo [ <mailto:EPerrigo@epsa.org<]=20
Sent: Thursday, November 08, 2001 10:06 AM=20
To: fallonr@dsmo.com; mfgildea@duke-energy.com;=20
Steve.Huntoon@dynegy.com; acomnes@enron.com;=20
dennis.capella@exeloncorp.com; jeffrey.roark@mirant.com;=20
jack.hawks@neg.pge.com; jadillon@pplweb.com; Neason, Judy=20
Cc: Julie Simon=20
Subject: EPSA MBR Paper=20

Attached is the last draft of the MBR paper from Boston Pacific. We are no=
t sending it to the entire group at this point - but would like provide tho=
se who have been most active an opportunity to see it one more time. We'd =
like to have all comments by tomorrow, COB.

-Erin=20

Erin N. Perrigo=20
Manager of Policy=20
Electric Power Supply Association=20
1401 New York Ave., NW=20
11th Floor=20
Washington, DC 20005=20
p) 202.628.8200=20
f) 202.628.8260=20
eperrigo@epsa.org