FW: Your edits ,
 Richard,
	Here it is.  It took me a little while to retrieve it from our
system.
Thanks
Gary

-----Original Message-----
From: Seabron Adamson [mailto:seabron.adamson@frontier-economics.com]
Sent: Sunday, April 08, 2001 10:48 AM
To: Alan.Comnes@enron.com; RCARROLL@bracepatt.com;
Richard.B.Sanders@enron.com; Susan.J.Mara@enron.com; Fergus, Gary S.
Subject: Your edits



Alan:

cc: Ron, Richard, Gary and Sue


I am OK with most of these, and will incorporate them ASAP.


On the deleted paras (26-30). My intention was to respond to the assertion
by Sheffrin that large nmbers of bids near the MCP  was indicative of market
power, combined with large number of bids at much higher prices at higher MW
levels (e.g. bid $150/MWh at 200 MW but $300/MWh at 250 MW). The first point
I could easily summarize more succintly, the second I think takes more
effort.

Of course, the fact that large numbers of bids around the MCP were submitted
by importers merely suggests in reality that people are pretty smart, and
new that prices in neighboring markets (e.g. in the NW) would settle at
similar levels. For those of you with an legal anti-trust background, it
merely confirms why the entire analysis is shaky - the fundamental market
definition is wrong (market definition being one of the key elements of
anti-trust economics and law). As even the MSC has agreed, the California
market is not a market on its own, but instead is well-integrated with the
rest of the West. So it is very difficult to look at half a market and come
up with sensible conclusions...

I can try to cut this down, or we can eliminate it altogether. I think it
does help address one of the accusations raised by Sheffrin, but I leave it
to you legal eagles to let me know whether responding to the issue is worth
the tradeoff in terms of the length of the affidavit. Suggestions welcome...


Seabron


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Seabron Adamson
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www.frontier-economics.com

-----Original Message-----
From: Alan.Comnes@enron.com [mailto:Alan.Comnes@enron.com]
Sent: Friday, April 06, 2001 6:59 PM
To: Seabron Adamson; RCARROLL@bracepatt.com;
Richard.B.Sanders@enron.com; Susan.J.Mara@enron.com;
Ray.Alvarez@enron.com; gfergus@brobeck.com
Cc: James.D.Steffes@enron.com
Subject: Answer to CAISO's March 22 Answer Claiming Market Power and
StrategicBidding
Importance: High



All:  We are targeting to file this on Monday, 9 April.

Ron:

I am forwarding to you two files:

The first is a draft of EPMI's answer.  I hope I have made your job easier
by providing you with a first draft..  I expect that you'll do your usual
magic turning it into a legal pleading.

The second is Seabron's affidavit, including my comments. .  Seabron needs
to live by the suggested edits, of course, so he get's veto rights over the
weekend.

Gary, Richard S.:

Please review w.r.t. litigation compatiblity.

Seabron,

Please start with my version and let me know any major issues you have with
my suggested edits.

Tim, Sue, Ray:  Please review.  Tim, make sure you look at paragraphs
26-30.

GAC

(See attached file: 01-04-06 SA Second draft GAC.doc)(See attached file:
Answer  to ISO Reply 040406.doc)


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