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Enron Mail |
Agree. Sounds like a very reasonable way to proceed, and consistent with
what we've said all along, non? Thanks, Harry. Jeanne, while your at it, could you get us a new Governor? Thanks so much. Best, Jeff Harry Kingerski 02/26/2001 04:59 PM To: JMB <JBennett@GMSSR.com< cc: "'Harry Kingerski (E-mail)'" <Harry.Kingerski@enron.com<, "'Jeff Dasovich (E-mail)'" <jdasovic@enron.com<, "'Bob Frank (E-mail)'" <robert.frank@enron.com<, "'Sue Mara (E-mail)'" <smara@enron.com<, "'sstoness@enron.com'" <sstoness@enron.com<, "'Tamara Johnson (E-mail)'" <tjohnso8@enron.com< Subject: Re: Brief in Rate Stabilization Proceeding Jeanne - you shouldn't compromise Enron's prior statements on ending the rate freeze. The most important thing is that we not get a retroactive end of the rate freeze (retroactive to any time before the date of the order). We may also accomplish this through legislation. Regarding the book vs. market valuation, it is less important that we argue for market or book than it is we should clarify for the commission how and why it should be consistent with the new legislation. If new legislation occurs and means that utility generation will be priced at cost for 10 years, then everyone needs to realize that is a fundamentally different construct. DA Customers are not getting the value of these plants through the valuation process so they must have access to that value through the access to retained generation approach. If cost based rates are not legislated, market valuation shoud proceed. What we don't want is for them to legislate cost-based rates and then forget about the value being stripped from DA. Also, seems like it could be a good thing to point out that if they do declare an end to the rate freeze, if it is effective before new replacement legislation is enacted, they've only created another quagmire. I'll call to discuss. JMB <JBennett@GMSSR.com< 02/26/2001 10:32 AM To: "'Bob Frank (E-mail)'" <robert.frank@enron.com<, "'Harry Kingerski (E-mail)'" <Harry.Kingerski@enron.com<, "'Jeff Dasovich (E-mail)'" <jdasovic@enron.com<, "'Sue Mara (E-mail)'" <smara@enron.com<, "'Tamara Johnson (E-mail)'" <tjohnso8@enron.com<, "'sstoness@enron.com'" <sstoness@enron.com< cc: Subject: Brief in Rate Stabilization Proceeding Despite the fact that the hearings will probably continue into Wednesday of this week, the briefs in Phase I of the Rate Stabilization Proceeding are still due this Friday the 2nd. One of the issues before the ALJ is the use of interim versus final market valuation to end the rate freeze. I am very hesitant to say that the rate freeze cannot end on the basis of a Commission approved interim valuation as Enron has, in previous proceedings, taken the position that it can. Please let me know right away if you feel different about this. Along these same lines, the issue of the value of the assets is somewhat at play (at least on an interim basis). Do we want to take a position that the assets need to be market valued (rather than book) thus increasing the rate base for the purpose of cost of service regulation which the assets are now under? Increased generation rate would mean an increased DA credit. However, it may also hurt our claim that we should get a piece of the retained generation. Again let me know as soon as possible about your position. Jeanne Bennett
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