Enron Mail

From:christi.nicolay@enron.com
To:tom.chapman@enron.com, steven.kean@enron.com, joe.hartsoe@enron.com,james.steffes@enron.com, richard.shapiro@enron.com
Subject:ADD'l INFO FOR FERC STAFF VISIT 12/7
Cc:sarah.novosel@enron.com
Bcc:sarah.novosel@enron.com
Date:Wed, 6 Dec 2000 04:28:00 -0800 (PST)

NOTE TO STEVE, RICK, JOE AND JIM -- ENRON CONTINUES TO HAVE ISSUES WITH
INTERCONNECTION. THE FERC STAFF INVESTIGATION ALSO SAID THAT INTERCONNECTION
POLICY (OR LACK THEREOF) CAN BE USED IN A DISCRIMINATORY MANNER. DO NOT NAME
VEPCO, BUT THIS IS A VERY RECENT EXAMPLE THAT YOU MAY WANT TO DISCUSS AT
LUNCH. The developers are working to fix this with VEPCO commercial people,
so I have not been asked to call FERC yet.

---------
I discussed this with developer, Reagan Rorschach today. Enron was working
with VEPCO to site an IPP (Enron owned) in VEPCO. We did not come to terms
on the PPA this summer. Enron would like to keep its ability to site the
plant with the associated queue position. VEPCO basically has "tied" our
queue position to a PPA with VEPCO and, therefore, kicked Enron out of the
queue when we did not execute a PPA.

VEPCO recently filed interconnection procedures with FERC that have not been
approved yet (these procedures were not in place when we got in the
queue--there were only very general "ask to interconnect" procedures then).
The only place that any "milestones" are mentioned is in the Interconnection
Agreement (which, of course, VEPCO and Enron never executed). In addition, a
generator can lose its queue stop for "material changes" to the project.
Several parties protested this very loose terminology, but we do not know
what FERC will say. By way of comparison, Consumers recently filed
procedures that state "material changes" mean increases in MWs < 15% or
increasing the in service date by more than 6 months. This issue will be
significant because if we get our queue spot back (which I think we should),
we may change the configuration (or a purchaser could change). I think that
reductions in MWs or more stable configurations should not be considered
"material changes." Reagan is going to speak with the commercial VEPCO
people and I'll call their attorney if necessary.

In any event, this again is an example of the kind of problems independent
generators continue to face until FERC establishes some general procedures or
an interconnection rulemaking.






Tom Chapman
12/04/2000 09:31 PM
To: Sarah Novosel/Corp/Enron@ENRON, Christi L Nicolay/HOU/ECT@ECT
cc:

Subject: Interconnection Issues

Sarah and Christi--

I have been working with Jeffrey Keenan and Reagan Rorschack on a power plant
in NC. This plant is in the VEPCO service territory, and so they want to
interconnect with VEPCO. Originally, they were working on a PPA with VEPCO,
but this PPA fell apart in October. VEPCO now claims that because the deal
fell apart, our plant should be removed from the queue.

If we are removed from the queue, we will fall behind a 640 MW plant in the
same area of northern NC. This is of great concern to the developers because
they are afraid that there will be no move available transmission in this
area of the grid.

They are looking at a number of possible avenues of recourse. They have
started to talk with me regarding handling this on a state level with the NC
PSC. But, I think that this is probably a federal issue.

Do you think that this should be handled on a federal level or on the state
level? Please let me know ASAP. Thank you.

Tom Chapman



IF you need more information, let me know.