RE: ICC- Balancing ,
 I'd say we want tariff language before any investigation.  I don't typicall=
y like investigations.  I like complaints.  My thought is to pre-sell tarif=
f changes to FERC with a broad coalition and then get the Ohio PUC to ask F=
ERC the question.

Jim

 -----Original Message-----
From: =09Migden, Janine =20
Sent:=09Wednesday, August 29, 2001 8:15 AM
To:=09Steffes, James D.
Subject:=09RE: ICC- Balancing

Then I will pursue getting an investigation and if we get one, we can devel=
op the model to push in that case.  I am assuming by model tha you are refe=
rrring to a mechanism that works for the midwest apart from or in conjuncti=
on with the ISO.  I will be with Mike and Jeff Merola tomorrow and will get=
 started on working on this with them.

 -----Original Message-----
From: =09Steffes, James D. =20
Sent:=09Tuesday, August 28, 2001 9:25 AM
To:=09Migden, Janine
Subject:=09RE: ICC- Balancing

We need a model for the entire Midwest independent of the ability to change=
.

Jim

 -----Original Message-----
From: =09Migden, Janine =20
Sent:=09Tuesday, August 28, 2001 9:08 AM
To:=09Steffes, James D.
Subject:=09RE: ICC- Balancing

At this point we dont have draft language and we dont have a settlement wit=
h language that allows us to push the way we can in Ohio.  My thought was t=
o push for an investigation and see within that context how far we could go=
.  At a minimum, if a hearing were to be granted, I think we could end up i=
mproving the balancing rules for IP, CILCO, etc.  Com Ed has the most favor=
able provisions and could end up being the model.  In my discussions with J=
eff Merola and Rogers Herndon, they can work with this however it is not op=
timal.  They need to do a transaction in order to figure out where the bugs=
 are.

 -----Original Message-----
From: =09Steffes, James D. =20
Sent:=09Tuesday, August 28, 2001 8:39 AM
To:=09Migden, Janine
Subject:=09RE: ICC- Balancing

Janine --

If we have draft tariff language, I'd push pretty hard.

Jim

 -----Original Message-----
From: =09Migden, Janine =20
Sent:=09Tuesday, August 28, 2001 7:53 AM
To:=09Shapiro, Richard; Steffes, James D.; Nicolay, Christi L.; Roan, Micha=
el; Stroup, Kerry; Boston, Roy; Hueter, Barbara A.; Landwehr, Susan M.
Cc:=09Shapiro, Richard
Subject:=09ICC- Balancing

On Friday, I participated in ICC Chairman Mathias' Roundtable on the state =
of competition in Illinois.  One of the questions he asked was what the ICC=
 could do to improve competition in Illinois.  I commented that the ICC cou=
ld commence an investigation on the balancing rules of the various utilitie=
s, having pointed out the problem's with ComEd's and the fact that the othe=
r utilities are even worse.  He expressed concern over ICC jurisdiction and=
 opined that to the extent that it impacts retail transactions and adversel=
y affects retail competition, the ICC is within its jurisdiction to order t=
he utilities to file an amended OATT before FERC for FERC's approval.  I pl=
an to follow-up with a letter to him and all the Commissioners and would li=
ke feedback as to how hard I should push on this.  Should the ICC look into=
 balancing (to which I give a less than 50% probability) we would have to b=
e prepared to participate.  I think it would be highly worth the effort, es=
pecially as far as Illinois Power is concerned, however, I would like some =
feedback as to your views in order to guage how hard to push this.

Thanks,
Janine
janine.migden@enron.com