
Date: Tue, 8 Feb 2000 05:31:00 -0800 (PST)
From: kevin.presto@enron.com
To: dtaylor@powersrc.com, michael_h._knapp@aep.com, tgeswein@cinergy.com,
dhils@cinergy.com, rarness@ipalco.com, brad.young@lgeenergy.com,
richard.doying@gen.pge.com
Subject: FW: Enron Control Area Request
Cc: tomk@ecar.org, lloyd.will@enron.com, kevin.presto@enron.com
Bcc: tomk@ecar.org, lloyd.will@enron.com, kevin.presto@enron.com

As you know, Enron does not own transmission facilities and therefore is not
subject to the FERC code of conduct rules with respect to functional
separation of generation and transmission.

However, when Enron established 3 control areas in the SERC region in
June-July 1999, a separate legal entity (Enron SE Corp) was created to
provide the reliability/control area operation function for Enron's Southeast
generation assets.  Although functional separation is not required by FERC,
Enron chose to do so because marketing/trading is indeed separate from the
control area reliability function at Enron.  Additionally, Enron SE Corp. (as
a certified control area) is entitled to ISN and IDC data that is subject to
NERC confidentiality provisions and cannot be disclosed and/or utilized by
the merchant function.

In order to protect the IDC and ISN information consistent with the NERC
Confidentiality Agreement (for ISN data) and the OATI/NERC Non-Disclosure
Agreement (for IDC data), only employees within the control area reliability
function have access to the data.   To highlight the importance of this
confidential information, verbal and written correspondence has been provided
by Enron's legal and regulatory counsel to each control area employee with
specific instructions to keep all required information confidential as set
forth in the NERC Confidentiality Agreement.

I hope this adequately answers your question.  If you have any additional
questions, please feel free to call me at 713-853-5035.

Thanks,
Kevin Presto

