FW: Draft of Hogan/Harvey Paper on FERC's Market Based Rate ,
 -----Original Message-----
From: 	bounce-alliance_info-90961@listserver.eei.org@ENRON   On Behalf Of "The Alliance of Energy Suppliers" <alliance@eei.org>
Sent:	Tuesday, December 18, 2001 4:22 PM
To:	Alliance Information
Subject:	Draft of Hogan/Harvey Paper on FERC's Market Based Rate     Initiatives Impacts and Remedies


Please review the attached documents and provide us comments by COB  tomorrow, Wednesday, December 19, to assist in finalizing EEI  and the Alliance of Energy Suppliers  filing in the Market Based Rate  proceedings.  Attached you will find a market assessment and impact  predictions of noted economists, Bill Hogan and Steve Harvey.  
 
If you have any questions, please do not hesitate to contact us at alliance@eei.org  or (202) 508-5098
 
 
EEI's Comments/Recommendations on Hogan/Harvey  Paper
The theoretical discussion (from the second full paragraph on page 3  through the end of page 5) should be moved to the end as a technical  appendix.  I'm concerned that if it stays in its current place, readers  will be thrown off track and maybe even stop there.
 
The last two paragraphs of section III.A. are very hard to read (page  7).  Whether they are necessary is a question I have not yet  considered.
 
Their advisement against price caps (see section V.i. at pages 19-20) will  run counter against some of our wires members.
 
Their recommended alternatives (section VI, pages 20-23) are only loosely  tied to my work request.  I am uncomfortable with proposals related to  plant divestiture for large sellers (pages 21-22) and minimum interconnection  standards (page 22.)
 
On another front, a comment came in suggesting that the definition of  incremental cost should include accelerated (physical) depreciation.
 
Tonja Wicks
Manager, Energy Supply Policy
Alliance of Energy  Suppliers
Edison Electric Institute
Phone: (202) 508-5098
Fax: (202)  508-5600
Fax: (202) 508-5445
 - Acceler1.doc 
 - EEI Mar1.doc 
 - Alliance of Energy Suppliers.vcf
vkaminski@aol.com