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Enron Mail |
I will most likely not be able to attend. However, my comment relating to
this issue was a generalization of confidentiality clauses I've used on other interconnect agreements and other contracts, including the "model" interconnection agreement recently submitted to FERC by EPSA. In essence, the issue is that the utility should not have the unilateral right to disclose any information to anyone they want that is sent to them in connection with a DG interconnection. This would include ownership, facility output, markets for energy or capacity or ancillary sevices (if any) and maintenance schedules (these schedules may be coincident with a retail customer's facility maintenance schedule which itself may be confidential information between the generator and retail customer). This information is potentially competitive and should be held confidential. Potential wording for a simplified confidentiality section would be as follows: "Unless compelled to disclose by judicial or administrative process or other provisions of law or as otherwise provided for in this Rule, the Electic Provider shall hold in confidence any and all documents and information furnished by the Electric Customer in connection with the interconnection, provide however, that to the extent it is necessary for the the EP to release or disclose such information to a third party in order to perform the EP's obligation herein, EP shall advise said third party of the confidential provisons of this Rule and use its best efforts to require said third party to agree in writing to comply with such provisions." Bruno Gaillard 04/20/2000 11:47 AM To: Jeff Dasovich/SFO/EES@EES, Tom Hoatson/HOU/EES@EES, Robert Frank/HOU/EES@EES cc: Subject: Siting Committee Hearing - Interconnection Rules Scott Tomashefsky is asking me to present our position on the confidentiality clause in Rule 21 at the CEC Hearing on 4/25. Any thoughts. I hope to be able to respond to him today. Should an Enron rep be present to do so? Me or another? Bob are you coming to Sacramento? ---------------------- Forwarded by Bruno Gaillard/SFO/EES on 04/20/2000 09:41 AM --------------------------- "Scott Tomashefsky" <Stomashe@energy.state.ca.us< on 04/20/2000 07:26:24 AM To: bgaillar@enron.com cc: Subject: Siting Committee Hearing Bruno, I was wondering if you would be willing to speak for 5-10 minutes on Tuesday regarding Section 2.7 of the proposed Rule 21 language (confidentiality of information)? I was hoping you could convey your concerns for the Committee. We have also added language in the report stating the Energy Commission has previously urged positions similar to Enron's at the CPUC, but the CPUC has not accepted them. Please let me know at your earliest convenience. Scott
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