Spreadsheet: james_steffes__12949__EES -REPORTNEW
Sheet: Sheet1

ENRON ENERGY SERVICES
GOVERNMENT AFFAIRS REPORT
Support Type | Deal Name | Responsible  Person | Impact ($[NAME]) | Background / Key Issues | Updated | Strategies/Comments/Next Actions
Regulatory Risk | RISK Analytics -Ibrahim
 | URM Process | [NAME] | 112 | Determination, implementation and testing of URM regulatory support | 2001-10-05 00:00:00 | Ongoing
 | EES - Kingerski
 | Retail Tariff Open Positions | [NAME] | -300 | Enron currently has retail tariff short position of 250??MM mwh throughout 30 Utilities in North America.   #1 = [NAME], #2 = ComEd, #3 = PG&E, #4 = …... | 2001-10-05 00:00:00 | Monthly review of largest positions.
 | Gulf Power Rate Case | [NAME] |  | Gulf Power has filed a rate increase that will affect EWS retail positions.  Key deal is with ECS for supply of compression services to FGT. | 2001-10-05 00:00:00 | Reviewing case filing and developing case strategy.  Case involves interests of EWS, ECS, FGT and EGM.
 | Nevada position; development of rules re:  AB 661--ablity to sell new electric resources to customer | PJK, [NAME] | ? | AB 661 was pased in the spring of this year.  It allows customers to leave NPC and Sierra if their departure doesn't "harm" other customers and if they purchase power from "new electric resources" | 2001-10-05 00:00:00
 | SW Gas Rate Case | [NAME] |  | SW Gas has billed EES $8 million or so in imbalance fees because gas scheduled to be delivered into SW was curtailed by El Paso. | 2001-10-05 00:00:00 | [NAME] filed and hearing was conducted.  Negotiations were conducted but without much success.  Awaiting AZ PUC decision.  Case in Briefing stage.  Also trying to get better transportation rules.
 | Georgia Power Rate Case | [NAME] |  | GP has filed a plan to implement automatic rate increases and refund certain weather-related revenues. | 2001-10-05 00:00:00 | Hearings begin 9/10.  Enron will file testimony to help support book position and advocate for weather risk management.  Working with weather desk to quantify illustrative weather products.
 | TX Implementaion Cases | [NAME] |  | Implementaiton dockets still open on how stranded costs will be handled. | 2001-10-05 00:00:00 | Monitoring.  Big issue is whether negative stranded costs will be allowed.
 | IL Rate cases | [NAME] |  | [NAME] and IP have both filed rate cases that would increase rate to shopping customers by more than to non-shoppers. | 2001-10-05 00:00:00 | Providing technical and case maangement support to EWS and [NAME].  Testimony has been filed in [NAME] case.  IP strategy is to object that increase is illegal and violates restructuring law.
 | CA PUC cases | [NAME] [NAME] |  | PUC continues to debate and study how to assess rate increases and when to kill direct access. | 2001-10-05 00:00:00 | Providing technical and case management support to GA West Group as appropriate.  San Diego rate increase implemented without affect to Direct Access; based on 9/20 PUC order.
 | Marketing Affiliate Rule NOPR | Lawner/Cantrell | 58 | The NOPR was issued on September 27.  A team, lead by [NAME] and [NAME], will develop comments. | 2001-10-05 00:00:00 | Team is holding initial meeting 10/5.
 | ENA/EES - Steffes
 | SE RTO mediation | [NAME] | a new market for the SE for EES and EPMI | monitor and provide technical support for arguments related to proposed operating and scheduling procedures that would discriminate against non-operator entities | 2001-10-05 00:00:00 | Provide comments and NERC related information to SE RTO Mediation team
 | RTO Scheduling Process Waiver | [NAME] | If unchecked, RTOs would be able to apply NERC rules to justify the need for retaining multiple control areas | limit control-area operating utilities ability to leverage NERC reliability requirements to justify multiple control areas within RTOs | 2001-10-05 00:00:00 | Restrict any changes to NERC policies from presecribing RTO - control area structural relationships .  [NAME] for the use of the CACTF Reliability Moddel in describing RTO - Control area relationships to minimize control area authority.
 | DSTAR | [NAME] | Level access to transmission market for EES and EPMI in [NAME] region | Facilitation and implementation of [NAME] with focus on independence of board, simple and functional congestion management and real time energy market(s), and maintaing focus on reduced influence of incumbent PTO's in region. | 2001-09-05 00:00:00 | Actively commenting on Appendices P and Q (Planning and Interconnections.  Developing consensus with other marketing/generating companies to file comments to FERC within the next week about the anti-competitive behavior of PTO's (prior to the DSTAR Tariff
 | FERC Reporting for Natural Gas Sellers into California | [NAME] |  | FERC is requiring reporting of natural gas sales into California, initially for a six-month period beginning 8/1/01 with the intention of extending until 9/30/02. | 2001-10-05 00:00:00 | The report for ENA was submitted on the October 1 due date.  Information for the EES report has to be obtained from the third-party vendor, CSC, and the report will not be completed until at least 10/15.  A letter was sent to FERC advising of the delay.
ADVOCACY | EES - Kingerski
 | AB 661 rule development | PJK, [NAME] |  | AB 661 was pased in the spring of this year.  It allows customers to leave NPC and Sierra if their departure doesn't "harm" other customers and if they purchase power from "new electric resources" | 2001-10-05 00:00:00
 | Ohio Operational Support | [NAME] |  | PUC conducting workshops on implementation issues, such as minimum stay, purchase of receivables, slamming, UDC billing | 2001-10-05 00:00:00 | Reviewing utility filings.  Preparing interventions on behalf of EES.  Meeting with Staff and commissioners as appropriate.
 | Marketing Affiliate Rule | [NAME] |  | FERC is considering revisions to its gas marketing affiliate rule. | 2001-09-05 00:00:00 | Meeting with FERC staff occurred Aug. 28.  A NOPR is expected soon and we will prepare comments.  Working with [NAME] and [NAME].
 | New York Operational Support | [NAME] |  | EDI set to be implemented by year end.  Industry working group involved. | 2001-09-05 00:00:00 | Progress is slow because of utility reluctance.  Enron created [NAME] sub-group to focus support and concerns. EDI is identified by EES as a akey issue.
 | ERCOT retail rules | [NAME] |  | Act as chair of retail rule subcommittee.  Handling integration of retail needs with wholesale market rules. | 2001-10-05 00:00:00 | Working through standardized electronic transactions.  Early problems associated with TX pilot being addressed.
 | TX Operational Support | [NAME] |  | Telemarketing rules, customer lists, registration as a supplier, ballot procedures | 2001-10-05 00:00:00 | Registered to participate in TXU and Reliant areas.  Working to identify applicable telemarketing rules.  Ballot procedure needs to go forward; Staff may be trying to dealy until next year.
 | NV Open Access Implementation | [NAME] |  | Industry subcommittee is writing implementation rules that will be submitted for PUC approval. | 2001-10-05 00:00:00 | [NAME] is member of subcommitte.  Rules need to address how departing customers do not act to detriment of other customers, as required by law.  Initial meetings have been held and rule is being written.
 | [NAME] | [NAME] |  | ACC conducting investigation into hedging practices of utilities. | 2001-10-05 00:00:00 | Participated in first workshop.  More will be scheduled soon.  [NAME] is to promote use of hedging.  Part of national effort, in support of [NAME].
 | El Paso Cases (FERC) | [NAME] |  | Several cases pending involving reallocation of receipt points, system expansion, and demand charge refunds for unavailable capacity. | 2001-10-05 00:00:00 | Comments will be filed Oct 2 on reallocation of receipt points and comments have been filed in other cases. Continuing to monitor as appropriate.  Working with [NAME] and EES/ENA as appropriate.
 | Redetermination of "Market Power" for purposes of granting market based rate certificates | Commercial Contact -Belden | Not immediate, but impact of losing market based rate authority is large | Massey (and later [NAME] and Wood0 have expressed the disire 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. | 2001-09-05 00:00:00 | Push for transmission open access to ensure the most numerous and competitive markets as possible.                                                                                                                                              -Next Step. EPSA Conference 9/13/2001
DEAL SUPPORT | EES - Kingerski
 | AEP compliance in TX with Retail Requirements | [NAME] |  | AEP has not complied with requirements to disclose customer lists or price that large customers will be supplied under starting 1/02. | 2001-10-05 00:00:00 | Informal complaint has been sent to Staff of TX PUC.  Will be scheduling a meeting to further review and discuss.  EES has identified AEP compliance as a key issue.
 | EDI development and implementation in NY | [NAME], [NAME] |  | EDI is being developed by all market players, including Enron. We are making sure appropriate standards are adopted in a very narrow timeframe. EDI implementation has one of the highest priorities for pursuing large commercial operations in NY. | 2001-10-05 00:00:00 | Enron is actively participating in the development, testing and implementation of the EDI standards. We have created an ESCO/Marketer working group to focus support and concerns.
 | New York Operational Support | [NAME], [NAME] |  | Enrollment of new customers in ConEd's territory has experienced billing problems. | 2001-10-05 00:00:00 | EES and GA are in the process of executing a Billing Agency Agreement (which includes bill testing, security/parental guarantee, etc.). GA is facilitating this process which is expected to be completed before mid-October.
 | EDI and regulatory issues in BG&E (Maryland) | [NAME] |  | EES has plans to enter the BG&E market territory. [NAME] is being offered in a limited basis. | 2001-10-05 00:00:00 | GA is researching on this even though further EDI development and implementation is unlikely in the near future. Other regulatory/commercial issues are also being researched (v.g. Internet-based systems replacing VANs).
 | Equity Office Properties | [NAME] |  | EES is evaluating a large-scale distributed generation initiative with this existing commodity customer. | 2001-10-05 00:00:00 | Ongoing analysis/evaluation of regulatory issues.
 | Oregon Market Opening | [NAME] |  | Market for large customers opens in Oregon, spring 2002 | 2001-10-05 00:00:00 | Meeting conducted with EWS and EES Origination to explain regulatory rules.  Helping identify future opportunities and rate obligations.
 | Market Analyses | [NAME] [NAME] |  | EES has requested market analysis reports for Central Hudson. | 2001-10-05 00:00:00 | Reports being prepared.  Effort being supported by [NAME].
 | SW Gas Case in NV | [NAME] [NAME] |  | SW has proposed a rule that would require transporting gas customers to stay with the utility for 5 years if they return to utility service. | 2001-10-05 00:00:00 | Testimony will be filed.  Case will be handled internally except for small amount of outside legal support.
 | Elba Island LNG | [NAME] |  | EGM trying to deliver LNG to Southern Gas At Elba with El Paso Mktg as receiver.  Liquification costs are point of contention. | 2001-10-05 00:00:00 | Identifying appropriate level of costs that Southern should charge.  Costs have been modelled.  May need to address through FERC proceeding.  EGM is eager to address these issues.
 | East Coast - Montavano
 | NUI Corp | [NAME] | $0.2. | Signed a seasonal Delivery Service (SDS) agreement with NUI through GA discussions with the company, after EES had lost the original bid for this service. | 2001-09-05 00:00:00
 | Midwest - Migden
 | Ormet Project/Ohio | [NAME] |  | Meeting on the Belmont County, Ormet project went well.  Enron's coal plant development group is preparing an application and we will be exploring with the Ohio Air Quality Dev't Authority both traditional and creative new financing structures. | 2001-09-05 00:00:00 | Arrange follow-up meeting, pursue other projects in Ohio
Legal Issues | ALL
 | Negative CTC Claim | [NAME] | -580 | SCE and PG&E owe Enron for Negative CTC accrued since March 2000.    This is a result of the operation of the legislated frozen tariff and high wholesale market prices that exceeded the tariff. | 2001-09-05 00:00:00 | 1.  PG&E recovery tied into PG&E Bankruptcy.  2.  PG&E and SCE have not returned net bill amount to EES' customers.  3.
 | NE Pool / NYISO Load Curtailment Programs | EES |  | We are developing forms and supporting their implementation to offer customers the availability to participate in NEPOOL and NYISO Load Reduction Programs. | 2001-09-05 00:00:00
 | Telemarketing | EES |  | Finalizing telemarketing programs fro Texas, new Jersey, and New York | 2001-09-05 00:00:00
 | Structual Supply | EES |  | Advising EES corporate development in connection with the potential of aquiring power from verious IPP's in order to meet the retail load of EES' customers. | 2001-09-05 00:00:00
 | Muni Acquisition | EES |  | Advising EES corporate development in connection with potential opportunities for EES to provide its products to municipal utilities. The Municipalities would then resell these products to their customers. | 2001-09-05 00:00:00