Spreadsheet: james_steffes__12873__GAC 0901 Report
Sheet: Sheet1

Government Affairs Activities as of September 1, 2001
Name/Project | Activity Type (Deal Support, Regulatory Risk, and [NAME]) | Commercial Contact | Financial Impact (incl. best guess) | Key Issues/ Background | Strategies | Next Steps
[NAME]
QF Buyout study | Deal Support | [NAME] | Potential benefits are $100 million +; Enron share in multi million range | Given current forward curve; QF contract buyouts look promising.  Utility interest may be heightened given current rate and credit pressures | Assist commercial team on a screening curve analysis.  Develop project types that are most promising from a buyout perspective; consider similar approach in Nevada; keep an eye on impacts on "in-California" and renewable production to prevent political backlash | Presentation to Edison to gain utility support
PNW Refund Case | Regulatory Risk | Belden | $10s of millions | case per July 25 FERC refund order | primary objective is to minimize refunds because the "benchmark" is ill supported and because changing rules after the fact is bad for competitive power markets.  More tactically: verify refund numbers computed by CAISO; make sure that sales made above benchmark are properly netted from sales made above benchmark; make a full showing of outstanding receivables owed to Enron by California parties | testimony due in September; hearings in October
Calif. Refund Case | Regulatory Risk | Belden | $100s of millions | case per July 25 FERC refund order; refund claims here are primarily made by Tacoma, Seattle, Port of Seattle, and CDWR | primary objective is to minimize refunds because the "benchmark" is ill supported and because changing rules after the fact is bad for competitive power markets.  More tactically: keep California out of the case; verify refund numbers computed by plaintiffs make sure that sales made above benchmark are properly netted from sales made above benchmark (so called ripple claims).  Call for further hearings if ripple claims are not fully heard. | Hearings early September; possible future hearings
CAISO Price mitigation compliance | Regulatory Risk | Belden | small immediate impact but CAISO rules keep Enron from participation | CAISO has implemented various aspects of the FERC rule incorrectly: it is not requiring a creditworthy buyer (I.e., CDWR to buy the full net short position), it is requiring thermal units to make power available at a loss | rehear FERC decisions and protest CAISO compliance filings.  Provide information to media | monitor and respond as appropriate
CAISO Price mitigation compliance: generation service customer assistance | Regulatory Risk | [NAME] | $millions | CAISO and FERC require cost justification for "above-cap" sales | assist clients in making filings on their own behalf | monitor market activity and assist in cost support as necessary
Oregon Direct Access | Advocacy/Deal support | Calger, Burkle, Malowney | new market: multi million | Oregon's version of direct access begins Q2 02 | Understand evolving rules and pursue profitable strategies | collaborate with commercial counterparts to develop deal opportunities
RTO West | [NAME] | Belden, Crandall | improved wholesale access worth $10 millions | RTO West to make compliance filing on 12/1/01 FERC has supported the concept of one Western RTO | Push RTO West formation without creating a public utility backlash; pursue policies that are compatible with strategies in the East | development of workable congestion management model ([NAME]); December 1 filing.
Redetermination of "Market Power" for purposes of granting market based rate certificates | [NAME] | Belden | not immediate but impact of losing market based rate authority is large | Massey (and, later Brownell and Wood) have expressed the desire to re-examine the current "hub and spoke" method of determining if markets are sufficiently competitive to allow for a finding of no market power and the issuance of market based rate certificates | push for transmission open access to ensure the most numerour and competitive markets as possible | EPSA Conference 9/13/01