Re: Cal ISO Amendment 30

Thanks. Please continue to include me on all the FERC related ditties. Mary
agree that we don't need to file separately?

Susan J Mara@EES
09/28/2000 06:04 PM

To: Mary Hain/HOU/ECT@ECT@ENRON
cc: <mary.hain@enron.com<@ENRON, <snovose@enron.com<@ENRON, Paul
Kaufman/PDX/ECT@ECT@ENRON, James D Steffes/HOU/EES@EES, Tim
Belden/HOU/ECT@ECT@ENRON, Robert Badeer/HOU/ECT@ECT@ENRON, Jeff
Richter/HOU/ECT@ECT@ENRON, carrrn@bracepatt.com@ECT@ENRON,
rcarroll@bracepatt.com, Jeff Dasovich/NA/Enron@Enron, Mona L
Petrochko/SFO/EES@EES
Subject: Re: Cal ISO Amendment 30

WPTF has just voted to file a protest on Amendment 30 (the ISO is asking to
be able to buy power for itself in the forward market). I agreed to fund as
did 4, maybe 5, others. The discussion was not exactly as you describe below
but I will be able to have lots of input on the filing, and am sure I can get
the points included. Therefore, I recommend that Enron NOT make a separate
filing on this.

Here is what WPTF voted on: Ask FERC to limit ISO procurement only to the
super peak product that has already been developed by the APX and require
that the price caps end in 6 months; if the ISO wishes to renew the price
caps it would have to file 60 days in advance of the 6-month deadline.

Mary Hain@ECT
09/28/2000 12:28 PM
To: Susan J Mara/SFO/EES@EES
cc: <mary.hain@enron.com<@ENRON, <smara@enron.com<@ENRON,
<snovose@enron.com<@ENRON, Paul Kaufman/PDX/ECT@ECT, James D
Steffes/HOU/EES@EES, Tim Belden/HOU/ECT@ECT, Robert Badeer/HOU/ECT@ECT, Jeff
Richter/HOU/ECT@ECT, carrrn@bracepatt.com
Subject: Cal ISO Amendment 30

Sue- in WPTF's protest of Amendment 30, is WPTF proposing to make the
following arguments? If not we need to have Ron give an estimate for an RCR
and draft a protest.

Amendment 30, which would allow the Cal ISO to do limited forward contracting
and to allocate the costs thereof to under/overschedulers (protests due
Oct.2)the traders would like to say that the ISO should not be in the forward
market, rather the IOUs should be in the forward market and should be
incented to do so. Rather than doing anything to fix this failure to hedge
and underscheduling by the IOUs, this filing would further amplify the
problem by concentrating even more transactions with the ISO and lead to the
slippery slope to the ISO running the entire market.

Since, the filing also creates other problems. Through the proposal to do
bilateral deals without first receiving bids, the ISO moved itself out of
compliance with Order No. 2000 (assuming it ever complied) by starting to
violate the independence characteristic - the FERC's first minimum
characteristic for an RTO. Under this, the RTO is required to be independent
of market participants. Order No. 2000 defines a market participant as any
entity or its affiliate that buys or sells electric energy in the RTO's
region or in any neighboring region that might be effected by the RTO's
actions.

Further, the ISO is already buying out of market and this move would further
complicate existing problems that we have with OOM.

In addition, although the filing claims that it's request is limited, yet
there is no time limitation. Further, the limitation seems to have little
real effect.

Enron Capital & Trade Resources Corp.

From: "Ronald Carroll" <rcarroll@bracepatt.com<
09/19/2000 03:23 PM

To: <mary.hain@enron.com<, <smara@enron.com<, <snovose@enron.com<
cc:
Subject: New California Filings

There have been several recent filings related to California that you may
wish to intervene in and/or protest:

1. CAISO proposal to extend price cap (ER00-3673-000) (due Oct. 5);

2. CAISO compliance filing with San Diego order to make limited forward
contracting and to allocate the costs for those contracts to SCs whose
forward schedules do not reflect their actual real-time demands.
(ER00-3636-000) (due Oct. 2);

3. City of Vernon filing to join ISO (EL00-105-000) (due September 29).
This filing triggers the CAISO's TAC charge effective 1/1/01;

4. Complaint by Cities of Anaheim, Azusa, etc. regarding the CAISO's
collection of OOM incurred to meet system reliability and to require the
CAISO to abide by the cap in Neutrality Adjustment Charge.

Please let me know as soon as possible if you wish to intervene in and/or
protest any of these filings. Thanks. Ron