EXHIBIT 99.252
ABB
Dr. John G. Reckleff
Executive Vice President
(919) 212-4855
October 28, 1997
Fax: 972-383-5733
Perot Systems Corporation
Attn: Mr. Ed Smith
12377 Merit Drive, Suite 1100
Dallas, Texas 75251
RE: CALIFORNIA ISO
Dear Ed:
As you know, ABB Power T&D Company's President, Ake Almgren, was sent a copy of
the letter dated October 22, 1997 from Jeffrey D. Tranen, President of the
California Independent System Operator, to Mr. H. Ronald Nash of Perot Systems
Corporation. ABB is deeply concerned about the allegations in the ISO letter and
must request certain information and assurances from Perot.
We have taken note of the fact that the ISO's letter was addressed to Perot and
not to the ISO Alliance LLC. Based on this fact, and the allegations contained
in the letter, we believe that the issues that have prompted the ISO's letter
relate solely to actions allegedly taken by Perot and not to any actions of ABB,
Ernst & Young, or the ISO Alliance. Nevertheless, the ISO's allegations
concerning the erosion of the Integrity of the California energy market and the
compromise of the work being performed by the ISO Alliance, suggests that ABB's
interests could be adversely affected by the possible resolution of issues
raised by the letter. These interests of ABB are both its long term interest in
the successful completion of the work under the ISO Contract and the short term
interest of avoiding the cost and disruption to the work of the ISO Alliance
that could result from compliance with some of all of the immediate demands set
forth in the ISO's letter.
In order for ABB to understand the full implications of the ISO's letter, we
propose that we meet together promptly in order for you to provide the following
information and assurances to ABB:
ABB Power T&D Company Inc.
Information Systems Division
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201 S. Rogers Lane Telephone: Telefax:
Raleigh, NC 27610 919-212-4700 919-212-4821
Page 2
1. Confirmation that Perot Systems has not introduced or influenced the
introduction of any changes or modifications to the Scheduling
Applications design or implementation that would create opportunities
for profiting from inefficiencies, congestion, or other potential
weaknesses or shortcomings in the ISO systems;
2. Confirmation or denial, with full supporting documentation and
explanations, of the allegations in the ISO letter concerning the
contact with a representative of San Diego Gas & Electric;
3. A list of all other persons and companies, if any, to whom any
representative of Perot has offered assistance in profiting from
inefficiencies, congestion, or other potential weaknesses or
shortcomings in the ISO systems;
4. Confirmation that Perot Systems, has not, in making any offer of the
type described in the preceding paragraphs, disclosed any information
which is required to be maintained as confidential under any of the
provisions of ISO Contract, as those terms are incorporated into the ISO
Alliance Subcontract with Perot Systems.
Although we regard the allegations of the ISO letter to be of an extremely
serious nature, we fully understand that the allegations have not been
documented or otherwise proven. Nevertheless, if those allegations are
documented or proven, there is a risk that Perot would be in breach of its
obligations as a Subcontractor to the ISO Alliance. By proposing a meeting to
address the points noted above, we wish to give Perot every opportunity to
demonstrate to ABB either that the ISO's allegations are misplaced or, if based
in fact, that Perot will take every action necessary, at its sole expense, to
provide whatever remedy to which the ISO may be entitled.
I will be able to meet with you on Thursday, November 6, 1997. Please let me
know if you can meet at that time.
Sincerely,
/s/ JOHN G. RECKLEFF
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John G. Reckleff
cc: Perot Systems Corporation
Attn: General Counsel
12377 Merit Drive, Suite 1100
Dallas, Texas 75251
Ake Almgren
Philip Curtis