EXHIBIT 99.214

       USING "ZERO PRICED LOADS" TO MITIGATE OVERGENERATION CONDITIONS IN
                                 PX'S DA MARKET

SUMMARY:

This paper describes an approach to allow PX participants to mitigate
overgeneration condition in the Day-Ahead Market by bidding additional demand
(e.g., pump load) at "near-zero" prices rather than curtail generation. The
approach is consistent with PX's current protocols

BACKGROUND:

Based on its existing protocols, should the PX detect overgeneration condition
in the DA market, it will determine the magnitude of total portfolio generation
that must be curtailed by PX participants in order to bring the total supply and
demand in the PX market into equilibrium. Figure 1 schematically demonstrates
the process of mitigating overgeneration condition by the PX.

After the overgeneration management process is completed at the PX, PX
participants submit their individual supply and demand resource schedules. The
sum of the individual supply schedules by each PX participant must match the
total supply portfolio determined for that participant by the PX for that
participant. The same rule applies to individual demand schedules. Hence, the
only approach to mitigate overgeneration condition after the overgeneration
management process is to curtail generation(1).

Some PX participants want to increase their demand rather than curtail
generation when overgeneration condition occurs and energy price is zero. This
paper describes an approach for PX participants to bid additional demand (e.g.,
pump load) at "near-zero" prices (let's, call these zero priced loads or ZPLs)
in order to mitigate overgeneration condition in the Day-Ahead Market and avoid
curtailing generation schedules.

                FIG 1. THE PX OVERGENERATION MANAGEMENT PROCESS

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(1)   This approach prevents potential gaming by PX participants who may
      withhold their demand bids to create overgeneration condition and then
      submit their demand schedules to benefit from zero priced energy after
      overgeneration condition is created.

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APPROACH:

A PX participant who wishes to have additional "zero priced load" (ZPL)
considered for overgeneration mitigation purposes could submit an additional
portfolio bid at "near-zero" price and equal to the magnitude of the ZPL in
addition to its original demand bid. This demand bid will be {$2500, 0}, {$0.01,
0}, {$0, ZPL} - where $0.01 is to satisfy the validation rules in the Trade
Application Software.

   FIG 2a. DEMAND PORTFOLIO BID CURVE FOR A PX PARTICIPANT BEFORE ADDING ZPL

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   FIG 2b. DEMAND PORTFOLIO BID CURVES FOR THE PX PARTICIPANT INCLUDING THE ZPL

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RESULTS:

The overall PX overgeneration process is schematically demonstrated in Figure 3
below after one or more PX participant add their ZPL demand bids to their
overall demand portfolio bid.

 FIG 3. THE PX OVERGENERATION MANAGEMENT PROCESS AFTER ADDING ZERO PRICED LOADS

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It is possible that by adding zero priced loads (ZPLs), the overgeneration
condition will completely disappear and supply and demand portfolio curves will
intersect at a non-zero price, see Figure 4 below. Under these circumstances,
however, the price of energy will always be less than $0.01/MWh.

 FIG 4. THE OVERGENERATION MAY COMPLETELY DISAPPEAR AS A RESULT OF ADDING ZPLS

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