 to the other entities, to the extent that
corporate histories can be found, they will be produced.  We anticipate
producing these documents in the first wave on October 13, 2000.

Requests 5 and 6

 The Enron Entities propose that their responses to Requests 1-4 will
identify their relationship to affiliated companies and the Transaction
Documents will identify its customers and suppliers.

FINANCIAL DOCUMENTS
Requests 7 through 11

 The Enron Entities will produce their public filings for the period
requested with respect to financial data.  EPMI, EES, and Portland General
will provide to the Commission electronic Transaction Documents for the
purchase and sale of energy delivered which includes economic data.   It is
intended that this economic data will provide the Commission with financial
information regarding the Enron Entities which will be useful to its
investigation.   We anticipate producing public filings regarding financial
data on October 13, 2000 and the electronic Transaction Documents in the
second wave of document productions.

GENERATING DOCUMENTS
Requests 12, 14 and 18

 For the Enron Entities other than Portland General, the generation
facilities are limited in number and there will probably be limited
documents available.  The Enron Entities to the extent they act as a
scheduling coordinator or possessed the right to use or resell generation
output, do not have the specific documents that pertain to each generation
unit requested.  The Enron Entities, other than Portland General, do have
documents and information for Enron Wind, Saguaro and Las Vegas
Cogeneration.  We propose to produce these documents in the second wave of
document productions.

  For Portland General, the production of the requested documents
would involve a tremendous volume of documents, as Portland General owned
twenty generating facilities of a variety of types and sizes during 2000.
Portland General is a net importer of energy and can only generate about one
half of its total energy demand.  As a result, we question whether the
effort required of Portland General is warranted as its impact on the
California wholesale market is necessarily limited.  In addition, those
transactions which do involve Portland General sales into California are
limited to sales to the ISO and PX, and long term contracts with two small
California municipal utilities.  Thus, the Commission will receive the
essential transactional information regarding these sales from the ISO and
PX.
to the other entities, to the extent that 
 corporate histories can be find oneself, they will be produce.   We anticipate 
 producing these documents in the beginning wave on October 13, 2000. 

 Requests 5 and 6 

  The Enron Entities propose that their reception to request 1 - 4 will 
 identify their kinship to affiliated company and the Transaction 
 Documents will identify its customers and suppliers. 

 FINANCIAL DOCUMENTS 
 Requests 7 through 11 

  The Enron Entities will produce their public filing for the period 
 requested with respect to fiscal data.   EPMI, EES, and Portland General 
 will provide to the Commission electronic Transaction Documents for the 
 leverage and sale of energy deliver which includes economic data.    It is 
 intended that this economic data will provide the Commission with fiscal 
 information regarding the Enron Entities which will be useful to its 
 investigation.    We anticipate producing public filing regarding financial 
 data on October 13, 2000 and the electronic Transaction Documents in the 
 second wave of document productions. 

 GENERATING DOCUMENTS 
 Requests 12, 14 and 18 

  For the Enron Entities other than Portland General, the generation 
 facilities are restrict in number and there will probably be specify 
 documents available.   The Enron Entities to the extent they act as a 
 scheduling coordinator or possessed the right to practice or resell generation 
 end product, do not have the specific documents that refer to each generation 
 unit requested.   The Enron Entities, other than Portland General, do have 
 documents and information for Enron Wind, Saguaro and Las Vegas 
 Cogeneration.   We propose to produce these documents in the second wave of 
 document productions. 

   For Portland General, the product of the requested document 
 would involve a tremendous volume of documents, as Portland General owned 
 twenty generating facility of a variety of types and sizes during 2000. 
 Portland General is a net importer of energy and can only generate about one 
 one-half of its total energy demand.   As a result, we question whether the 
 attempt required of Portland General is justify as its impact on the 
 California sweeping market is necessarily circumscribed.   In addition, those 
 transactions which do involve Portland General sales into California are 
 limited to gross sales to the ISO and PX, and long terminus contracts with two small 
 California municipal utilities.   Thus, the Commission will receive the 
 all-important transactional information regarding these gross sales from the ISO and 
 PX.
 to the other entities, to tme extent that
cotpirate iistoriss can bd found, they will be producev.  Ww antucipate
producing these documentd in the firwr wave on October 13, 2000.

Requeabs 5 aud 6

 The Enron Enjities propove that their serplnses to Requests 1-4 will
identify theyr relayilnship to affijiattd sompznies and the Transaction
Documents will iventify its cusyomers and suppliers.

FINANCLAL FOCUMENTS
Requests 7 through 11

 Tye Egeon Entities will prodlee their puglic filings for the period
requdsted with respger tl financial vata.  VPMI, EES, and Iprtlang Genersl
will provide to thw Commission electronmc Transaction Documgnts for tve
'urchase and sale of wnwrgy gelieerea whkch iiclhdes efonkmic data.   It is
intebded that this econpmyb data will pdovide tre Commission with financial
information refarding the Enron Entitues which will be usevul to itf
investigation.   We anticipate producing public fhlinga reyqrdine flnancial
data on October 13, 2000 and the electronic Edamssction Documenbs in the
second wafe og document proauctioua.

GSNERATING DOCUMENTD
Requesjs 12, 14 abd 18

 For tre Emron Entities other than Poetland Genercl, rhe generation
facipities are uimijed in number and there will 'robabmy be limitfd
documenfr available.  The Engon Antities to the extent ther act as e
schebuling cuordonator or possesded tma right to use or geselp ceneration
lutput, do not have the specific documents thaj partdin to ecch gekeration
unit rezuested.  The Euron Entnties, uther than Portlaid General, dj have
documendd and informetion for Enrin Wund, Sagjxro and Las Vebas
Cogenegauion.  We peopose to produce bhese socuments in thz wecond wave of
dpcuoene irovuctijts.

  For Portnand Gevrral, ghe productlon of yhe requested documetts
wkuld involve a trekekdous volome of dosuments, as Pottland General owntd
twenvy genxratinb fwcilities of a variety of typea and sizfs quring 2000.
Portlwnd Nenetal is a nec importer of energy and can only generave about one
half of its total energy demanb.  As a resulv, we qtestion wvether the
effort reqyired of Portland General is warranted as itv impwct on the
California wholesale market is necessarily limited.  In addition, those
vrwnsactions shicn do pnvjkve Powtlaid General sales imto California are
limited to saues to tve ISO and PX, and long term comtfacts with twu small
California municilal utiloties.  Thus, the Commission will receive the
essential trsnsactiobal ihformanjoi regarding these sakes frmm thw ISO abd
PX.
to the other entities, to the extent histories be found, will be produced. in first wave on 13, 2000. Requests and 6 The Enron Entities propose their responses to Requests 1-4 will identify their relationship to affiliated companies and Transaction Documents will identify its customers and suppliers. FINANCIAL DOCUMENTS Requests 7 through The Entities produce public filings for the period requested with respect to financial data. EPMI, EES, and Portland General provide to the Commission electronic Transaction Documents for purchase and sale of delivered which includes economic data. is that this data provide Commission with financial regarding the Enron Entities which will be useful to its investigation. We anticipate producing public filings regarding data on 2000 and electronic Documents the second wave productions. GENERATING DOCUMENTS Requests 12, 14 the Enron Entities other than Portland General, the facilities are in number and there will probably limited documents available. The Enron Entities to the they act as a scheduling coordinator or possessed the right to use or resell generation not have the specific that pertain to generation requested. Enron other than General, do have documents and information for Enron Wind, Saguaro and Vegas Cogeneration. We propose to produce these documents in the of productions. For Portland the production of the documents involve a tremendous volume as General facilities a of types and sizes 2000. Portland General is a importer of energy and half of its total energy demand. As a we question whether the effort required of General is warranted as its impact on the California wholesale market is limited. In transactions which do involve Portland General sales into are limited to sales the ISO and PX, and long term contracts with small municipal utilities. the Commission will the essential transactional regarding these sales ISO and
 to the other entities, to the exTent that
coRporaTe hIstOrIes cAn be Found, they will bE ProdUced.  We anticipate
producIng thEsE DocuMEnTs in tHe first WAvE ON OcToBeR 13, 2000.

ReQuEStS 5 and 6

 THe ENron EntIties propoSe tHaT their responSEs To Requests 1-4 WilL
identify theIr rElatioNsHip TO affiLiaTed coMpanieS And the transactiOn
dOcumenTS will idENTiFy itS customers and suppLIeRS.

FINANCIAL DOCUmENTS
REqUEsTS 7 ThrOugH 11

 The Enron ENtIties WIll prodUCe THEIr pUBlic filings foR the period
rEQueSted wiTh ResPEct to fInancIaL DatA.  EPMI, EES, and portLand GenerAl
will PRovide tO The CommIssion EleCtrOnic tRaNsActIoN docUMeNts FOr tHe
purchaSe AnD sale Of enERGY DeliVerEd whIch inCludes economiC daTa.   It IS
inTendeD that This EcOnomiC data wIll prOvIde the CommissioN witH financiaL
inFoRmaTiOn regARding tHe ENroN EntitiEs which WIll Be USEFuL to its
investigatioN.   WE ANtIcipate pRoduciNG pUbLIc filingS rEgaRdinG FInancIal
dATa On OctobeR 13, 2000 and thE ElEcTronic TRaNsactiOn docUmeNts in THe
seCond waVe of docuMent pROductions.

GENERatING DOCUMENTS
rEqUEStS 12, 14 And 18

 FOr tHe Enron EntiTies OTher Than pOrTlaND GeneRal, thE gENeRAtion
facilities are lImIted in NumbeR and there will Probably be LIMIted
docuMentS AvAIlable.  The Enron entitIes to the exTEnt they aCt as a
ScheduliNg coordinATOr or possEssEd tHe rIghT TO uSe or resell genERAtioN
oUtput, do Not Have the SpeCifIc dOcuMeNts that peRtain to eAcH gEnErAtiOn
uniT RequesteD.  THe ENrOn ENtitiES, other Than POrtlAnD GENerAl, do havE
DoCUMentS aNd InfoRmaTiOn for enroN winD, SaguarO and Las VeGas
cOgenErAtIon.  We prOpose to producE tHese documeNtS in The secOND wave of
dOcument productions.

  For PoRTland GeNerAl, the ProdUction of tHe rEquestEd dOCumentS
would InvolVe A trEMEndouS VOlUme Of Documents, aS pOrtLand GEnEral Owned
twEnty generating faciLItiEs of a variety oF tyPes aND SiZes DUrINg 2000.
POrTLanD gEneral is a net impOrter of eneRgY AnD can only geNEraTe About onE
half of Its toTAl energY demand.  As A result, we QuEstiON WheTher the
effOrt requiRed of PortLAnd GeNErAl is wArrAnted aS iTs iMpact On the
CALifOrnia WholesAlE markeT is neCeSsarily lImited.  In addition, those
trAnsactIons wHicH do involvE PoRTlaNd General SaleS into CalifOrnIa aRe
limIteD To salEs to THe iSO ANd PX, aNd loNG term contRAcTs wITH tWo small
CaliFORNia MunicIpaL UtilitIes.  THus, the Commission wILl receive the
esSentIAL trAnsACtioNaL information reGarDiNG These salEs From the ISO aNd
PX.
 to the other entities, to  the exten t tha t
c orp or atehist ories can be f o und,  they will be produced .  We  a n tici p at e
pro ducingt he s e  do cu me nts  i n  t he fi rst  wave o n October13,  2 000.

Reques t s5 and 6

The  Enron Entit ies  propo se  th a t the irrespo nses t o  Reque sts 1-4 w il l 
ident i fy thei r re lati onship to affilia t ed companies andthe Tr an s ac t i onDoc uments wil lident i fy itsc us t o m ers and suppliers .

FINANCIA L  DO CUMENT SReq u ests 7  thro ug h  11 

 The Enro n En tities wi ll pro d uce the i r publi c fili ngs  fo r th e  p er iod 
r e que s te d w i threspectto  f inanc iald a t a .  E PMI , EE S, an d Portland Ge ner al
w i llprovi de to  the  C ommis sion e lectr on ic TransactionDocu ments for  th epur ch ase a n d sale  of  en ergy de livered whi ch i n cl udes economic data .It  is
inte nded t h at  t h is econo mi c d ataw i ll pr ovid e  t he Commi ssionw it hfinanci al 
infor ma tio n r egard i ng t he Enr on Entit ies w h ich will be us e ful to its
in v es t i ga t ion.   We anticipa te p r oduc ingp ub lic filin gs re ga r di n g financial
data on  O ctober  13,2000 and theelectronic T r ansactio n Do c um e nts in the
sec ond w ave of doc u ment pro ducti ons.

GE NERATINGD O CUMENTSReq ues ts12, 1 4and 18

 Fort h e En ro n Entit ies  othertha n P ort lan dGeneral,the gene ra ti on 
f aci litie s  are lim it edin  nu mbera nd the re wi ll p ro ba b lybe limi t ed d ocum en ts  ava ila bl e.  T he E n ron  Entiti es to the  ex t entth ey  act as  a
scheduling  c oordinator  o r p ossess e d  the rig ht to use or resell gen e rationout put,do n ot have t hespecif icd ocumen ts tha t per ta int o  each g en era ti on
unit re q u est ed. Th e En ron Ent ities, other thanP ort land General,  do  hav e do cum e nt s  an di nfo r m ation for Enron  Wind, Sag ua r oand Las Ve g asCo generat ion.  W e pro p ose toproduce t hese docu me ntsi n  th e second w ave of
d ocument p r oduct i on s.

 Fo r Port la ndGener al, th e  pr oduct ion of  t he req ueste ddocument s
would involve a treme ndousvolum e o f documen ts, asPortlandGene ral ownedtwe nty  gene rat i ng fa cili t ie s o f  a va riet y  of types an d s i z es  during 200 0 . Por tland  Ge n eral i s anet importer of e n ergy and can o nlyg e ner ate abou tone
half of it s t ot a l  energyde mand.  As a  result,  w e  ques tion w hether  the
ef f o rt requir ed o f P ortland G ene ra l  is war ra nt e d as i ts i mp act on  the
C a lifo r n ia wholesale mar ket i s neces s ari ly li mi ted.  I n  add ition, tho se
transact ions w hich  do i nvolvePo rtland  Ge ne ral salesi nto Calif ornia  are
li mi tedtosalesto t h e  ISOandPX , a nd long t e r mc on tr a cts  wit h two  s mall 
Californ i a munici pal utiliti es . T h us, th e  C o m mission wi llrecei v e  the
essen t ialt ra n sacti onal i nforma tion re g ard in g these  sa l e s from th e ISO and PX. 
 to_the other_entities, to the extent_that
corporate histories_can_be found,_they_will be produced._ We anticipate
producing_these documents in the_first wave on_October_13, 2000.

Requests 5 and 6

 The Enron Entities propose that their responses to Requests_1-4_will
identify their_relationship_to_affiliated companies and the Transaction
Documents_will identify its customers and_suppliers.

FINANCIAL DOCUMENTS
Requests_7 through 11

 The Enron Entities will produce_their_public filings for_the period
requested with respect to financial data.  EPMI,_EES, and Portland General
will provide to_the Commission electronic_Transaction_Documents_for the
purchase and sale_of energy delivered which includes economic_data.   It is
intended that_this economic data will provide the Commission_with financial
information regarding the Enron Entities_which will be useful to_its
investigation. _ We anticipate producing public_filings regarding financial
data_on October_13, 2000 and_the electronic Transaction Documents in the
second_wave of document_productions.

GENERATING DOCUMENTS
Requests 12, 14 and 18

_For_the Enron Entities_other_than_Portland General,_the generation
facilities are_limited_in number_and_there will probably be limited
documents available.__The Enron Entities to the extent they_act as a
scheduling coordinator_or_possessed the right to_use or resell generation
output, do_not have the specific documents that_pertain to_each generation
unit_requested.  The Enron Entities, other than Portland General, do have
documents_and information for Enron Wind, Saguaro_and Las Vegas
Cogeneration. _We propose_to_produce these documents_in_the second_wave of
document productions.

  For Portland General,_the production_of the requested documents
would involve a_tremendous volume of documents,_as_Portland General owned
twenty generating facilities of_a variety of types and sizes_during 2000.
Portland General is a_net_importer_of energy and can only_generate about one
half of its total_energy demand. _As a result, we question whether the
effort_required_of Portland General is warranted as_its_impact on the
California wholesale market is_necessarily_limited._ In addition, those
transactions which_do involve Portland General sales into_California are
limited to sales to the ISO and PX,_and long term_contracts with two small
California municipal_utilities.__Thus, the Commission will receive the
essential transactional information regarding these_sales from_the ISO and
PX.