Message-ID: <14179928.1075858662469.JavaMail.evans@thyme>
Date: Thu, 25 Oct 2001 09:30:07 -0700 (PDT)
From: stacey.bolton@enron.com
To: richard.ring@enron.com
Subject: RE: ma rps
Cc: elliot.mainzer@enron.com
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I can discuss for about 10 minutes.  See below.
=20
Stacey Bolton
Environmental Strategies
Enron Corp
713-853-9916 direct=20
713-303-2632 cell=20
stacey.bolton@enron.com <mailto:stacey.bolton@enron.com>
=20

-----Original Message-----
From: Ring, Richard=20
Sent: Thursday, October 25, 2001 10:55 AM
To: Bolton, Stacey
Cc: Mainzer, Elliot
Subject: RE: ma rps


Stacey,
=20

Elliot and I would like to discuss a few issues with you regarding the MS R=
PS Comments.  What time do you think that you will have to discuss?
=20
=20
<http://www.energy.ca.gov/renewables/documents/index.html#greenpower>
=20
=20
=20
F-1:  Need to require that all current renewable facilities, including all =
current existing boimass facilities are certified prior to the start date R=
PS  - i put that in the comments, however MA might have a really hard time =
certifying any renewable facilities outside of MA that don't submit an appl=
ication.=20
=20
F-5:  Not sure that I understand the issue surrounding compliance on a prod=
uct level - let's discuss  -
Product v. Company.  If it's a straight company requirement, you could theo=
retically roll all of your RPS requirements into one product and sell for p=
remium.  Further, not all MA customers would show that they are getting ren=
ewables.=20
=20
F-7:  While we are very pleased with the Division's inclusion of banking, w=
e do not understand the need to restrict the limit on how much Supplier's a=
re allowed to bank as the shelf life for Renewable Energy Credits is alread=
y limited to the two compliance periods immediately following.  We would al=
so ask that you not limit the ability for Suppliers to transfer banked Rene=
wable Energy Credits during the allowed compliance periods.  We feel that t=
he Division should encourage as much liquidity as possible in the Renewable=
 Energy Credit market.  We understand the Division's concern regarding tran=
sferable banking and potential problems with market power, however, we feel=
 that the GIS Administrator is charged with closely monitoring potential ma=
rket power situations.  We would prefer that the Renewable Energy Credit ma=
rket be allowed to operate as indicated above from the beginning and if it =
is determined that market power issues exist then appropriate changes to th=
e market can and should be implemented.  We feel that markets operate best =
with few restrictions.   Okay.  Good.  I'll substitute.=20
=20
F-9: Section 4. Not sure I understand the difference between the percentage=
 of sales versus the actual MWh's - let's discuss
=20
F-9: Section 5. Not sure that this language makes sense - let's discuss=20

-----Original Message-----
From: Bolton, Stacey=20
Sent: Thursday, October 25, 2001 7:17 AM
To: Ring, Richard; Mainzer, Elliot; Rishe, Frank
Subject: ma rps
Importance: High


all -=20
attached are the draft comments.  pls get me comments by noon.  frank, got =
your vm.  yes, we are submitting it as supplement to our oral comments tomo=
rrow.  richard, can you please attach the CEC website.  I'm have awful diff=
iculties with my dial up.
=20
thanks,
stacey
