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Strategic Actions for Regulatory Approval and Support in RTO Implementation

Implement a comprehensive strategy to meet with key stakeholders, obtain buy-in, and advance regulatory approval for RTO initiatives. Utilize scorecards, engage Enron leadership, manage expectations, and foster collaboration with industry and regulatory bodies.

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Strategic Actions for Regulatory Approval and Support in RTO Implementation

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  1. Suggestions for RTO-01 Push • Meet with Dave Delainey and Kevin Presto to obtain “buy in” for the regulatory structure. • Meet with traders/originators (as invited by Kevin, Tim, and Janet)(late afternoon dinner meeting). Use the “score card/RTO list” as a guide for discussion and consensus on positions. Ask Steve Kean and Jeff Skilling to attend, at least after the discussion for agreement on position.

  2. Manage Expectations • Enron will not get everything, but can advance the ball forward better than any other company -- 1998 Petition for Rulemaking -- 1999 Order No. 2000 -- 2000 FERC Staff Investigations -- 2001 Some (or more) of ENA’s market needs

  3. Enron Washington Meetings • Ken Lay, Jeff Skilling, Dave Delainey, John Lavorato (Kevin, Janet) meet with FERC Commissioners • Meet with DOE • Meet with DOJ

  4. Pursue Combined Strategy on Sector Meetings • Continue intra-industry dialogue and joint pleadings (DENA, Dynegy, VEPCO, etc.) • Continue to push state contacts (All state PUCS and AGs, etc. have intervened in RTO filings -- know their positions and why) • Work with Industrial groups • Work with Residential/Environmental groups

  5. Establish Increased “FERC-Open” Lines • FERC access to EOL • FERC access to information through Enron Regulatory Attorneys and contacts like Donna Fulton

  6. “PECO” THEM • Use industry/residential groups that feel outraged that the utility can do this to them -- utility-merchant’s use of native load exception -- utility refusal to hedge on a forward basis with contracts below current rates

  7. Create RTO Support Teams • Various teams responsible for details • Report directly to Jim Steffes

  8. RTO Support Teams Jim Steffes ENA/EIM East Ron McNamara Christi Nicolay West Steve Walton Mary Hain DC Joe Hartsoe Sarah Novosel Donna Fulton Etrans Jeff Brown/ Ron Tapscott (contract from ENA) Florida Dan Staines Midwest Mike Roan Southeast Joe Connor Tom Chapman SPP Ron McNamara Northeast Howard Fromer Dan Allegretti Tom Hoatson Regulatory Groups Assisting Effort

  9. Ideas for New RTO Support Teams • RTO Support Teams are copied by the regional persons on a significant emails on specific RTO policy/actions/issues/”PROGRESS” • Emails to other regulatory persons and commercial groups should contain asummary of the details of regulatory person’s analysis and attached document, if applicable [[may need some additional analysts/associates’ assistance]] • Reg. Persons should have meetings/conference calls with regulatory persons and commercial groups for each region, as needed • More floor visits (calls) to floor in the afternoon • Call/page Christi/Mary/Sarah with any “big regional scoop” (utilities entering/exiting RTOs, etc.) • “Control the documents”

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