CITATION TO WPTF’S COMPLAINT	ISSUE/
ARGUMENT	CITATION TO DOCUMENT IN EXISTING PROCEEDING	

Complaint at 6-8.	The GMC is unduly discriminatory and anticompetitive because it requires Complainants to subsidize the rates of customers with Existing Contracts. 	•	“Request of Enron Power Marketing, Inc. For Clarification, Or in the Alternative, Rehearing” (“Enron Rehearing”) at 4.
•	“Initial Comments of Enron Power Marketing, Inc. Opposing Offer of Settlement” (“Enron Comments”) at 3,       9 n.8.	
•	Complaint at 8.	•	Incumbent customers only pay 50% of what Complainants must pay in GMC charges.	•	Enron Comments at 3, 8.	

•	Complaint at 11-12.	•	In order to protect Complainants, FERC should grant Section 206 refund protection to the rates in Docket No. ER99-473-000.	•	Enron Rehearing at 1, 3-4.
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Complaint at 13.	FERC should establish a refund effective date at the earliest possible time.	•	Enron Rehearing at 1, 4.
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Complaint at 12-13.	FERC should set for expedited hearing the determination of the reasonableness of the GMC rates effective January 1, 1999, and the appropriate amount of refunds.	•	Enron Comments at 9 & n.7.	
•	Complaint at 9-10.	•	The GMC is not just and reasonable, and may be excessive based on a study facilitated by the ISO, which compares the administrative costs of 5 ISOs.	•	Enron Rehearing at 4 n.3.
•	Enron Comments at 8 & Attachment A.
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Complaint at 10-11.	The extended GMC violates the April 1998 Settlement in Docket Nos. ER98-211-000, et al., because the ISO failed to file new GMC rates effective January 1, 1999.  	•	Enron Rehearing at 4-5, 6.
•	Enron Comments at 4.	
•	Complaint at 12.	•	The April 1998 Settlement is binding on the parties as well as the Commission.  	•	Enron Rehearing at 6.
•	Enron Comments at 10 & n.10.