Exhibit 99.402

                            Ancillary Service Issues


- -     Inter-SC Trades of A/S

- -     Self-Provision of A/S by PX Participants

- -     PX Day-Ahead and Hour Ahead A/S Markets

- -     Congestion Management

- -     PX Block Forward A/S Markets




INTER-SC TRADES OF A/S

What does it mean for PX to allow inter-SC trades of A/S when PX does not run DA
and HA A/S markets?

- -     Will PX loads be able to schedule purchases of A/S to meet their A/S
      requirements?

      -     PX must track the amount a participant procures via trade and reduce
            charges for A/S procured from ISO.

      -     What if they buy more than their needs?

            -     Will PX pay them for reducing A/S purchased from ISO to meet
                  requirements of other participants?

            -     What price?

            -     PX must charge other PX participants to recover this cost.

      -     Will PX generators be able to schedule sales of A/S to other SCs?

            -     PX must track the amount a participant sells to other SCs via
                  trade. ISO models the inter-SC sale by increasing the PX A/S
                  requirements and reducing the A/S requirements of the buying
                  SC.

            -     What if generator does not perform (either by not responding
                  to ISO dispatch of A/S capacity or by using capacity sold for
                  A/S to produce real-time energy without ISO instruction)?

                  -     ISO will charge PX for nonperformance. Will PX have
                        systems to charge the generator for this and not spread
                        the ISO charges to PX loads?

      -     What if ISO adjusts the inter-SC trades due to congestion?


SELF-PROVISION OF A/S

- -     What does self-provision cover:

      -     PX participant scheduling A/S capacity from its resources to meet
            the requirements of its loads?

      -     Two PX participants arranging a private deal whereby one participant
            schedules A/S capacity from its resources to meet the requirements
            of the loads of the other?

      -     A PX participant arranging a private deal with another SC to supply
            the A/S capacity requirements of that PX participant's loads via
            inter-SC trade?

      -     What if a PX participant schedules more A/S capacity than it needs
            per its metered demand?

            -     Will PX pay them for reducing A/S purchased from ISO to meet
                  requirements of other participants?

            -     What price?

            -     PX must charge other PX participants to recover this cost.

      -     What if ISO adjusts the self-provision quantities due to congestion?


PX DA AND HA A/S MARKETS

- -     Should the PX run its own DA and HA A/S markets meet it's A/S
      requirements?

- -     What is market structure?

      -     Allow parties to bid A/S capacity and energy prices separate from
            their bids in PX energy markets?

            -     Similar to ISO market but without Rational Buyer
                  complications?

      -     Use PX energy market bids to acquire capacity for A/S and pay
            opportunity cost for A/S capacity?

            -     Raises PX UMCP. What is the impact when Congestion Management
                  causes separate ZMCPs? How is opportunity cost defined then?

- -     How much of it's A/S requirements should PX procure in it's A/S market as
      opposed to ISO A/S markets?

      -     Will PX participants have option to select the market in which they
            want to sell their resource capacity?

      -     What gaming opportunities arise?

- -     What is impact on PX if ISO adjusts PX A/S market quantities due to
      congestion management?

      -     How will price that PX pays for A/S capacity be calculated?


CONGESTION MANAGEMENT

- -     What will be the impact on Congestion Management of the above?

      -     If PX participants hold aside capacity to supply A/S prior to ISO's
            congestion management, the adjustment bid market may be thinned.
            This could drive up usage charges and adversely affect PX ZMCPs.

- -     Should PX only undertake designing DA and HA A/S markets as part of
      simplified Congestion Management?

      -     Simplified CONG would allow PX to incorporate scheduling and trading
            of transmission rights (ETC/FTR) in its DA and HA energy markets and
            enforce interzonal transmission limits.

      -     PX DA and HA market results would be financially binding prior to
            ISO CONG adjustments.

      -     PX could run it's A/S markets after its joint energy/transmission
            markets and so avoid the problem of thinning the adjustment bid
            market. Or, if ISO allows scheduling of ETC and FTRs for A/S as well
            as energy, PX could unify energy, A/S and transmission in a market.

- -     If this is the vision, does it make sense to proceed with self-provision
      and inter-Sc trades as a stop gap measure? May be wasted effort if a final
      integrated PX market is designed.

- -     Or should the resources be directed to design and development of final PX
      market structure that integrates energy, ETC/FTR trading, and A/S?