COMUNICACIÓN DEL NORD POOL

We have been asked to comment on the proposed MOR design, to summarize our
impressions concerning the visit last week to Colombia and XM/CREG and to give
recommendations on a high level for the future development of the Colombian Power
market.

Our comments and recommendations are based upon the explanations given to us by
XM and CREG as well as the papers "Colombia Firm Energy Market" dated 18th
December 2006 and "Colombia's Forward Energy Market" dated 27th July 2007.

The comments and recommendations are by no means complete and reflect the first
impression we achieved during the visit and the reading of the documents.

* Price signal
 We believe in the price's ability of serving as a price signal for both generation
and consumption in means of being able to increase the system's efficiency.

 The price determination must thereby too the highest possible degree reflects
the marginal generation's unit costs and consumptions' preferences in the
system. In this regard our experience shows that the two-price system (Day-
Ahead-Market for energy plus Balancing Power Market for capacity) based on
hourly values is the best way of achieving this.

* Two price system

 An energy price is determined a day-ahead (spot price) for each operational

hour and a capacity price for imbalance power price is determined in real-time
for each operational hour.

 Participation in a two price system: the day-ahead price shall reflect the
marginal costs for generating the expected consumption. Thereby the
companies selling to not hourly metered end-users (retailers) estimate their
users' total consumption and purchase this price independently in the spot
market. The consumption estimate should - as Cramton also suggests - be
based on a profile. The profile should be the result from estimated total load
minus grid losses minus estimated hourly metered consumers' consumption.
Each retailer should be obliged to purchase his customers consumption.

Hourly metered users should purchase either directly from the spot market or
indirectly through a retailer each of their 24 hours of estimated consumption.
The spot market should be voluntary and thus bilateral physical products
should be allowed to complement the spot market's hourly products.

Any deviation between estimated (thus contracted consumption/generation)

and physical exchange with the grid should be handled in real-time through a
balancing power market. In such a market the System Operator has the
 generators' balancing capacity in a merit order list available for balancing the
system. The needed balancing capacity should determine the balancing costs
(marginal unit = imbalance power price). All imbalances (contracted against
metered) should be valued by this price and credited or debited
(surplus/deficit).

* Price quality
 Our understanding of Crampton's forward energy market is that there is a high
risk of achieving "wrong prices" in the auctioned products.
Each price will include many risks such as volume risk, price risk, unavailability
risk, time risk and more.

 We believe in the ability of a reference price and a thereto belonging

derivatives market to enable efficient risk management.

 Crampton's forward market disables corrections in the case of wrong forecasts

regarding the reference price and the fundamental factors influencing the
estimated reference price. A derivatives market serves the same purpose as
Crampton's forward market (hedging), but allows the participants to correct
any wrong hedges through possible multiple trading of the same product
(opening and closing of contracts, partly or total volumes).

 Crampton includes a volume risk by only allowing consumption shares and not
specific MWh/h. This implies that generators will include a risk premium in the
contract price for coverage of this risk. This again means a "dirty price"
including elements it shouldn't include.

* Transparency

 Any generator or consumer will contribute positively to a high quality of the

reference price if given correct information about the system (all factors able to
influence the spot market price). If provided with sufficient amounts of
information the participant will to a higher degree be able to decide upon
correct and efficient usage of his own resources (generation or consumption).

 The short term influence of transparency will influence the spot price through
generation adaptation and the long term influence will give price signals to
consumption development and investments.

* Zonal pricing / zonal market area - only one area in Colombia

 We agree with Crampton that Colombia should be operated - in means of

market - as a one-zone-market-area. This will reduce the possibility for market
abuse by market dominant companies.
* Competition

 The Colombian market shares by generation companies (Crampton's report on

forward energy market) show that competition and transparency can be a
strong barrier for abusing market power. There is no company able to
contribute with much more than 20% market share, thus it will in a transparent
scenario be very difficult to influence the prices and very easy to determine any
attempt of doing so.

* Risk management participant

 Please see price quality

* Risk management market operator

 A contract with high risks influences negatively the risk any Clearing House or
Settlement House is opposed to. This is the case with Crampton's forward
contracts. It will definitely boost the transaction costs and thus the electricity
price.

* Transaction costs

 Please see risk management

* Load following products

 Our comment is that a load following product decreases the system's efficiency
to a large degree. It is never an efficient solution when generators have to
follow load of their customers. It results in an inefficient system resource
usage. Hourly products in a spot market support the efficiency in the systems
resource usage too a much higher degree by enabling any consumer to buy his
hourly needed volumes from that hour's cheapest suppliers.

* Volume risk

 Please see price quality

* Flat rate versus volatility

 Our believe is that a volatile market influences in a positive way the

participants' behavior. Volatile hourly values support the participants' short
term decisions concerning their resource usage. Average long term prices
support long term developments of the system (investments). Regulated, thus
not-hourly metered consumers, are not opposed to volatile hourly prices, they
will only see average prices. The derivatives market will allow volatile prices
due to dry or wet seasons to be smoothened. Derivatives will still be able to
produce a price signal in form of higher prices in dry seasons and lower prices
 in extremely wet seasons, which we consider as positive influence on the usage
of resources, not as a negative signal.

* Derivatives market

 We consider derivatives - if a reference price with good quality can be

determined - as the best suitable tool for risk management. Europe's
experience (Germany, Nordic, France, Switzerland, Austria, Netherlands,
Belgium) supports this statement strongly.

* Demand response

 We are 100% confirm with Crampton's statement that demand is able to

respond on energy prices with demand change (page 12, 5.2.4, Colombia's
Forward Energy Market, 2007). Our experience is that consumption in the long
run reacts to high prices (both higher peak hour prices and seasonal high
prices) through more efficient use of consumption resources and changing of
demand patterns (demand management).

I hope this is good reading for you ... since a forward market as Crampton suggests
would take away all your volumes in the existing DAM. You would be left with a small
market with no price signal at all. Crampton's market would give you turnover at each
auction, but that is only each "year" and once a time for the questioned volume ...
which is not many TWhs .

Sverre