Enron Mail

From:d..steffes@enron.com
To:sarah.novosel@enron.com, linda.robertson@enron.com,richard.shapiro@enron.com, l..nicolay@enron.com
Subject:RE: Meeting with Dan Larcamp/ Marketing Affiliate Rulemaking
Cc:
Bcc:
Date:Wed, 5 Sep 2001 06:24:08 -0700 (PDT)

Before we invite FERC staff to the trading floor, let's set up a gameplan a=
nd run by the trading floor - I don't want a dispute with trading after inv=
iting staff down here.
=20
Jim

-----Original Message-----
From: Novosel, Sarah=20
Sent: Tuesday, September 04, 2001 10:09 PM
To: Fulton, Donna; Kean, Steven J.; Shapiro, Richard; Robertson, Linda; Ste=
ffes, James D.; Kingerski, Harry; Nicolay, Christi L.
Cc: Alvarez, Ray; Briggs, Tom; Lawner, Leslie; Cantrell, Rebecca W.; Kaufma=
n, Paul; Migden, Janine; Montovano, Steve; Ryall, Jean
Subject: RE: Meeting with Dan Larcamp/ Marketing Affiliate Rulemaking


Linda:
=20
You may want to raise the issue of Commissioners and their staffs coming to=
Houston to visit the trading floor when you visit with them with Frevert l=
ater this month.
=20
Sarah

-----Original Message-----=20
From: Fulton, Donna=20
Sent: Wed 8/29/2001 10:36 AM=20
To: Kean, Steven J.; Shapiro, Richard; Robertson, Linda; Steffes, James D.;=
Kingerski, Harry; Nicolay, Christi L.; Novosel, Sarah=20
Cc: Alvarez, Ray; Briggs, Tom; Lawner, Leslie; Cantrell, Rebecca W.; Kaufma=
n, Paul; Migden, Janine; Montovano, Steve; Ryall, Jean=20
Subject: Meeting with Dan Larcamp/ Marketing Affiliate Rulemaking




Leslie Lawner, Becky Cantrell and I met with Dan Larcamp at FERC yesterday =
to discuss the marketing affiliate issue. He agreed with the latest press =
reports that the upcoming rulemaking NOPR, expected to be voted out in Sept=
ember, would not make major structural changes to the industry. The curren=
t document is up to the Commission level and the Commissioners are clearly =
considering the alternatives now. Larcamp said he expected a broadening of=
the current market affiliate rules structure to include all corporate enti=
ties. He did specifically mention that the Commission is not comfortable w=
ith the link between financial and physical transactions and the possibilit=
y for manipulation of market prices in one market (financial) to affect pri=
ces in the other market (physical). He also expects the Commission to blen=
d the gas and power rules, using the best practices of each. Any NOPR that=
is issued will of course have comment dates to allow Enron and all industr=
y participants to comment on any proposed rule changes.

Larcamp indicated that he did not think there were pervasive afilliate disc=
rimination issues in the industry, but said that the Commission needed to a=
ct due to the political pressures they got from the Hill, etc. The El Paso=
case is top on everyone's mind and is of special concern because it affect=
s the California market, both gas and power.=20

Larcamp indicated that he is just now learning what a "Pat Wood" Commission=
is going to want. He indicated that Wood has closer ties to the producer =
community than either of the two former Chairmen. He therefore expects th=
at the Commission will be responsive to that sector in taking a relook at t=
he affiliate rules. However, Larcamp did mention that the only meeting tha=
t he had previously had on the affiliate issue was with the INGAA group (Jo=
e Hartsoe went with them). It is not clear whether the producer community =
has lobbied this issue at the Commissioner level.

We discussed strategy with Dan, how to let the Commission feel more comfort=
able with the marketing affiliate issue. He suggested that he had gained a=
lot by visiting the trading floors (including Enron's). He thought the Co=
mmissioners and their immediate staffs would benefit from similar visits. =
=20

We specifically raised the issue of market prices, and talked about tranpor=
tation costs not equalling basis differentials. We stated that our markete=
rs believed that the prices in the market were determined by market factors=
in the specific areas of delivery rather than basin costs plus transport c=
osts. Dan did indicate some agreement with this concept and thought that m=
ore education at the Commissioner level would be very worthwhile.

If you have any questions, call Leslie, Becky or me.=20