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Enron Mail |
Here are my thoughts --
1. Agree that offering Transmission Provider waiver given RTO status is premature. 2. Maybe strengthen argument that both unbundled Provider of Last Resort type service and bundled Utility sales service should be included in the affiliate definition. At a minimum, in places like PA, where the Utility sales service is a direct competitor, there should be no difference with any competitive player. In a state like GA, where the Utility sales service is a "monopoly" by statue (i.e., bundled retail), I still think given the ability to cogenerate, it makes sense to have these providers take transmission service similar to our service at wholesale. Maybe make this argument earlier and as the core focus. I fully agree to include these providers in the definition. 3. Leslie, call Christi N. to discuss examples of how Native Load Exemption has caused problems (we've put in earlier filings). 4. The question of "Holding Company, etc." -- We should argue for an exemption. 5. I am also troubled by the "administer" term. FERC should prohibit any "helping" by the Transmission Provider of anyone in the marketplace. Maybe focus FERC on clarifying its positions. 6. Emergency sections -- Keep the language you have that never applied to natural gas industry (and could be a real problem given a CAISO type situation - ask Alan Comnes for thoughts). Probably don't object but want to make sure that if Emergency develops there must a pre-set timeframe for going back to normal business. 7. Everything filed at the FERC related to Standards of Conduct should be posted on the OASIS. I didn't understand the final bullet point comments. Is this policy or a statement of something to come? Jim -----Original Message----- From: Cantrell, Rebecca W. Sent: Friday, November 16, 2001 3:38 PM To: Shapiro, Richard; Steffes, James D.; Nicolay, Christi L.; Novosel, Sarah; Hartsoe, Joe; Turner, AW Cc: Lawner, Leslie Subject: Draft Comments on Marketing Affiliate NOPR Attached for your initial review are Enron Corp. comments on the Marketing Affiliate NOPR (RM01-10). As you will see, this is an incomplete, bare bones version and we can enhance the arguments once it is clear we all agree with them. Leslie has struggled mightily with this in light of the constant changes that have been going on and we are sure more changes will be necessary. Comments must be filed at FERC by December 20. In order to allow adequate time for a couple of redrafts and the concomitant reviews along with the other things that are going on, please advise me or Leslie of any suggestions, concerns or comments you have by COB MONDAY, NOVEMBER 26th. << File: RM01-10 Draft2.doc <<
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