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Enron Mail |
Several comments:
Sec. 407 How is the determination made of whether a market is competitive and who makes the determination? It looks like in this section, revocation of MBRs occurs at the time the complaint is filed and the remedy is revocation of MBRs. However, in a later section (411) it looks like the remedy is mitigation. Sec 408 It is not clear to me that generator here includes on-site or DG that you want to resell partially or all into the wholesale market (See (f)(2). Also, in b1(D)(2), affords an opportunity for an evidentiary hearing. If the utility is wrong and clearly violating the rule, then hotline should be able to remedy, not go to evidentiary hearing. FERC can order a hearing now, but doesn't have to. In ©(2) directly below, the order is issued if all the requirements are met (using "and"). Can it say "or" because simply adding a generator because the market needs more peaking capacity may not be "encouraging overall conservation or energy or capital" (unless the argument is gen added instead of trans or something like that) Sec 411 What is significant period of time, etc? This is where it looks like the remedy is mitigation plan, no refunds? Sec 413 Market transparency--Not sure what "sale price of each sale" means? does this include structured deals? simply real time sales? What is "updated as frequently as practicable"? Sec 414 ((b)(3)--Would add "RTO" after control area operator or transmitting utility. We hope to bid to RTO, not control areas. Sec 512 Public Benefits Charge looks like tax on all MWs gened whether from an IPP or rate based generator.(Lloyd Will is reviewing this). Sec 523 statement about Known energy sources sold at wholesale. We typically portfolio source and don't know which generator the power coming from. This section may be ok when taken in context with the renewable credits, but I don't know enough about the credit program, so just raising the issue. Sec 604 the requirement for real-time metering and pricing seems to practically require the real time transparent pricing that we want.(I sent the EES traders and DG guys this part on net metering, etc.) Thanks! -----Original Message----- From: Shelk, John Sent: Thu 9/6/2001 5:17 PM To: Steffes, James D.; Nicolay, Christi L.; Briggs, Tom Cc: Subject: FW: Bingaman bill language Finally, here is a version that you should be able to open in MicrosoftWord (the Hill uses Word Perfect too often). Our apologies for problems with the earlier versions we sent. -----Original Message----- From: Cooney, Carolyn Sent: Thursday, September 06, 2001 6:03 PM To: Shapiro, Richard Cc: Shelk, John Subject: Bingaman bill language See if you can open this version. Please let us know. Thanks <<division B - version 0.9.doc<<
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