From: steven.kean@enron.com
To: dan.leff@enron.com, bill.donovan@enron.com
Date: 2000-11-16 05:57:00+00:00
Subject: Mkt Affiliate Implications: Reorganization of Houston and Omaha
 Facilities Management Responsibilities

fyi
----- Forwarded by Steven J Kean/NA/Enron on 11/16/2000 05:57 AM -----

	Shelley Corman
	11/15/2000 08:58 AM
		
		 To: Steven J Kean/NA/Enron@Enron, Vicki Sharp/HOU/EES@EES, Drew 
Fossum/ET&S/Enron@ENRON, Maria Pavlou/ET&S/Enron@ENRON, Michael 
Moran/ET&S/Enron@ENRON
		 cc: 
		 Subject: Mkt Affiliate Implications: Reorganization of Houston and Omaha 
Facilities Management Responsibilities



Enron Energy Services is presently a marketing affiliate of several of the 
Enron pipelines because EES: (1) buys/sells gas; and (2) holds transport 
contracts on our pipelines.  

Under the FERC's standards of conduct, the pipelines cannot: (1) share 
transportation information or shipper information with EES; (2) must function 
independently and keep separate books and records.  Generally, I don't see 
the FERC having any problem with mechanical, electrical, air-conditioning 
types of services.  However; there are 2 specific concerns that arise with 
respect to the described arrangement under the FERC's marketing affiliate 
standards of conduct:

1. Records -- FERC has ruled that giving a marketing affiliate "access" to 
transportation and shipper records (including something as simple as file 
room access) is deemed to be impermissibly sharing the information with a 
marketing affiliate in violation of the standards. Thus, it seems to me that 
EES will explicitly not be able to perform any records management function 
for NNG, TW or NBPL.

2. Billing -  FERC scrutinizes intercompany charges carefully.  In a recent 
Kinder-Morgan consent order, the FERC used payroll and intercompany charge 
records to make the case that the pipeline and marketing affiliate did not 
operate separately.  It would be helpful if any EES facility management 
charges/allocations come from Enron Facility Services (not EES) --  leaving 
us room to argue that the facility management subsidiary involves separate 
functions and staff than the EES subsidiary that is a marketing affiliate.




   
	
	
	From:  Steve Kean & Bill Donovan                           11/14/2000 06:36 PM
	

Sent by: Enron Announcements
To: All Enron Houston
cc:  

Subject: Reorganization of Houston and Omaha Facilities Management 
Responsibilities


Responsibility  for daily operations of building support services in the 
Enron Building, Houston leased offices, and Two Pacific Place (Omaha) will be 
transitioning from Corporate to Enron Energy Services (EES) by year-end.  The 
areas affected include facility operations and maintenance of mechanical, 
electrical, and air-conditioning systems; mail delivery;  housekeeping;  
food, copier, and records services.

This transition of services, as presently managed by Enron Property and 
Services Corp. (EPSC), is designed to optimize value to Enron,s Business 
Units by leveraging facility management businesses now offered by EES to 
their commercial customers.  EPSC staff having administrative responsibility 
for these services will report to Enron Facility Services, a subsidiary of 
EES,s Global Energy Services group led by Daniel Leff, President and CEO.

EPSC is responsible for Enron,s internal real estate and office development 
needs, including leasing, space allocations and facility planning, project 
and construction management, furniture systems, and office relocation.  EPSC, 
in its development role, remains a part of Enron Corporate Administration 
Services (ECAS) along with Corporate Security and the Aviation Department, 
reporting to Bill Donovan, Vice President, Corporate Administrative Services.

This alignment of responsibilities offers the opportunity for EPSC to focus 
resources on effective utilization of our existing office space assets and 
managing the development of Houston,s new Enron Center Campus project.