Enron Mail

From:paul.dawson@enron.com
To:structure.group@enron.com
Subject:Market structure group
Cc:steven.kean@enron.com, maureen.mcvicker@enron.com, mark.schroeder@enron.com,fiona.sayers@enron.com, philip.davies@enron.com
Bcc:steven.kean@enron.com, maureen.mcvicker@enron.com, mark.schroeder@enron.com,fiona.sayers@enron.com, philip.davies@enron.com
Date:Fri, 18 Feb 2000 06:27:00 -0800 (PST)

My apologies for not kicking things off earlier, but the regulator here has
conspired to make the last few weeks a bit mad. Consequently, it's taken me
a while to set down some thoughts on how we might get the best out of the
market structure group. Attached below is an initial stab at some "terms of
reference" to describe the scope and objectives of the group. I thought this
might help us to come to a common understanding of what we are trying to
achieve. I'm conscious that the one area that is a bit lacking is
"Deliverables", ie, what will we come up with as the output from this
process? This needn't be a formal "report" - indeed I suspect that
establishing a regular process of information exchange and discussion is
likely to provide more durable benefits.

I'd very much welcome your views on our scope and objective over the next few
days. I'd also welcome a brief update on which issues you are all working as
a way introducing our interest in the topic of market structure. This should
also help to kick-start the process of exchanging ideas. My own contribution
is below.

I've also attached a couple of documents that I think may be useful. One I
prepared for the Federal Energy Commission in Russia as a statement of "What
is a foreign investor looking for in a liberalised market?" It was written
for an audience for whom a competitive electricity market is an alien
concept. For example, we were attempting to change the FEC's mindset that
power marketers were an unnecessary layer of costs - because their "tariff"
added to other participants tariffs would increase prices. As a result it is
very high level and conceptual. However, it has some value as a basic
delineation of where the key market structure issues lie. The other
documents relate to the proposals for New Trading Arrangements in England and
Wales (further information on these reforms can be obtained from the
regulator's website at http://www.ofgas.gov.uk/). While far from perfect,
these reforms provide a good example of wholesale trading arrangement reform
for use elsewhere (for good or bad).

I'll be on vacation next week, but on my return I'd like to set up a video
conference/conference call to discuss how we can take things further. Any
suggestions for agenda items for that would be most welcome.

Regards

Paul



------------------------------------------

UK Electricity

The regulators - Ofgem and the DTI are is undertaking a massive programme of
reforming the electricity market in England and Wales. These reforms have
followed the UK government's moratorium on new gas plant in late 1997 and are
designed to remove perceived "distortions" in the market. The reforms centre
on:

New Electricity Trading Arrangements (NETA) to replace the Pool from October
this year. We have had a significant input into the this process. While
generally supportive of the proposals, we have opposed several undue
restrictions on managing risk.
Plant divestment by major mid-merit generators to increase competition in the
price-setting part of the market. We were instrumental in this process,
following our analysis late in 1997 of the costs of generator market power to
electricity consumers. Divestment has since significantly increased the
liquidity and competition in the wholesale market. Despite this the
regulator is seeking greater powers to intervene in the wholesale market to
prevent market "manipulation". We think this represents an unacceptable
extension of regulatory power and are therefore likely to oppose the
regulator at the Competition Commission enquiry into this.
New transmission access and pricing arrangements. While these reforms may
have limited merit, in general we think they're a waste of time and our
existing asset positions are significantly exposed. The regulator has just
started consulting on this and this is one area that I suspect your
experiences in the US and elsewhere might be useful to me.