
Date: Mon, 2 Jul 2001 08:16:00 -0700 (PDT)
From: charles.yeung@enron.com
To: bill.rust@enron.com, kevin.presto@enron.com, laura.podurgiel@enron.com
Subject: FERC OASIS Business Practice Ruling
Cc: christi.nicolay@enron.com, james.steffes@enron.com, lloyd.will@enron.com,
richard.shapiro@enron.com, andy.rodriquez@enron.com,
sarah.novosel@enron.com
Bcc: christi.nicolay@enron.com, james.steffes@enron.com, lloyd.will@enron.com,
richard.shapiro@enron.com, andy.rodriquez@enron.com,
sarah.novosel@enron.com

Another victory at FERC!

Although Enron did not file a protest in this docket, nor was a signatory t=
o=20
the joint Coral/Dynegy protest, I worked with Dynegy on forming the argumen=
ts=20
against the proposed change to OASIS (first to confirm after scheduling=20
deadline) at NERC.   Dynegy and Enron and a few others voted against the NE=
RC=20
request but lost the vote thus leading to the NERC filing.  In my opinion,=
=20
such a practice would advantage incumbent utilities and their affiliate=20
marketers who tend to buy pre-confirmed Firm service.

One of the main arguments I made at NERC and a chief reason why FERC denied=
=20
the request is cited in the order:

"Dynegy/Coral argues that the proposed standard addresses the problem of=20
unused transmission capacity caused by some customers not confirming accept=
ed=20
transmission requests, but does not address the underlying problem caused b=
y=20
the practice of some transmission providers of delaying their acceptance of=
=20
requests for daily, firm transmission service, even when customers submit=
=20
their requests early. "

FERC further acknowleded:
"If transmission providers would all respond to requests for daily,firm=20
transmission service on a timely basis, then customers would have adequate=
=20
time to confirm before reservations are scheduled, and the MIC's proposed=
=20
business practice might not be needed."

This is the correct message for FERC to send back to NERC - to put the burd=
en=20
on the transmission providers to expedite requests - not penalize the=20
customers for getting OASIS requests in early.=20


