Susan Mara

Susan J. Mara served as Enron’s Director of Regulatory Affairs for California, based in the company’s San Francisco office. During the critical period of California’s electricity deregulation and the subsequent 2000-2001 energy crisis, she functioned as Enron’s primary liaison to the California Public Utilities Commission (CPUC), California Independent System Operator (ISO), and coordinated the company’s participation in state regulatory proceedings. Working alongside Jeff Dasovich, who focused on legislative and political intelligence in Sacramento, Mara managed the technical regulatory work that underpinned Enron’s California strategy. She reported to James Steffes and Richard Shapiro in the Government Affairs organization, while maintaining close coordination with Steven Kean, Vice President of Government Affairs.

Mara’s email correspondence appears across multiple archives in the Enron corpus, with 1,007 emails preserved in Jeff Dasovich’s archive, 1,293 in Steven Kean’s archive, and 67 in James Steffes’ archive, spanning October 1999 through December 2001. Her communication volume peaked during the height of the California energy crisis, with 164 emails in May 2001, 158 in June, and 170 in July.

Career at Enron

Director of Regulatory Affairs, California

Mara held the title of Director of Regulatory Affairs with responsibility for California regulatory matters. She was based in San Francisco, initially affiliated with Enron Energy Services before moving under the North America organizational structure.

Her responsibilities encompassed a broad portfolio of California regulatory engagement. She managed Enron’s positions before the CPUC, tracked California ISO proceedings, coordinated external legal resources, and served as the company’s primary point of contact for technical regulatory matters in the state. Where Dasovich provided political intelligence and legislative tracking, Mara handled the detailed regulatory filings and procedural work that shaped Enron’s participation in California’s restructured electricity markets.

Managing External Legal Resources

One of Mara’s key functions was coordinating the use of outside legal counsel for California regulatory proceedings. She managed a system of “RCRs” (Resource Commitment Requests) that controlled authorization and spending on external legal resources. An October 12, 1999 email to her regulatory affairs colleagues explained the process:

“The attached updated table includes all the approved RCRs for CA, FERC and other. It also includes all the RCRs I know about in the rest of the West. No other work is approved that requires use of outside resources. Further, our attorneys have been advised that, even if a matter is approved, they have no authorization to spend money on that matter until they obtain approval from the Enron lead.”

She developed a color-coded tracking system, noting: “I continue to use the unfortunately garish color coding of yellow for FERC, blue for CPUC, and green for non-CA state matters.”

Her correspondence shows extensive coordination with outside counsel, particularly Ronald Carroll at Brace Patt, who received 110 emails from Mara.

California ISO Congestion Management Reform

Mara led Enron’s engagement in the contentious debates over California ISO congestion management reform in 2000, a technical but commercially significant issue that affected how market participants would be compensated for transmission constraints. Her May 16, 2000 email to Steven Kean summarizing the various stakeholder positions revealed both her command of the technical details and her strategic coordination role:

“Attached are cryptic summaries of the current positions. WPTF, APX, ISO and IEP are all fairly similar. Enron is working with those parties to develop a common proposal. The ‘Reform Coalition’ (RC) is Hogan, sponsored by Sempra, with ORA/TURN/UCAN (they are all nuts), Reliant, Southern and Williams. Without the gens, they were going nowhere. Southern has already left the coalition. We and others have put a full court press on to Reliant (the source of the problem is John Stout in Houston). The word is that Reliant will also leave – we’re hoping for a big splash saying both Southern and Reliant have left.”

Mara played a central role coordinating coalition politics around ISO market design. She tracked not just the technical positions of various parties but also the internal dynamics of competing coalitions, working to peel away support from positions unfavorable to Enron’s interests.

Direct Access and Retail Market Defense

Mara was a fierce defender of direct access, the mechanism by which large customers could purchase electricity from competitive suppliers rather than incumbent utilities. When California lawmakers began considering restrictions on the retail market, she mobilized opposition. Her February 24, 2000 email regarding proposed legislation demonstrated her unequivocal stance:

“Paul, We see what you refer to as ’the Cavanaugh/Edison bill’ as a re-play of AB 1421 from last year. That bill will destroy the retail market. We opposed 1421 and we’ll oppose any son of 1421. We do not want to see it tied to any aggregation bill, the public goods charge extension or anything else.”

As the California energy crisis intensified in 2001, the CPUC moved toward suspending direct access, a development Mara tracked closely. In June 2001, she forwarded information about CPUC proposed decisions on suspending direct access, with a terse comment that hinted at internal efforts to manage the regulatory process: “I guess our own people were successful in getting the decisions off the web.”

Industry Coalition Coordination

Mara served as Enron’s liaison to multiple industry groups working on California energy policy. Her correspondence reveals coordination with the Western Power Trading Forum (WPTF), the Independent Energy Producers Association (IEP), and APX, the California-based electronic exchange for electricity trading.

She forwarded communications from the IEP, including updates on legislative matters such as windfall profits tax proposals. Her role in these coalitions extended beyond passive information sharing to actively coordinating policy positions, aligning Enron’s position with WPTF, APX, and IEP against competing proposals.

Energy Crisis Response

Peak Crisis Activity

Mara’s email volume during May through July 2001 reflects the demands of the California energy crisis on Enron’s regulatory affairs team. During this period, she was simultaneously tracking CPUC proceedings, monitoring legislative developments, coordinating with industry coalitions, and responding to political investigations.

Legislative Investigations

As political scrutiny of energy market participants intensified, Mara was involved in Enron’s response to subpoenas and document requests. In May 2001, she forwarded a California ISO notice regarding a subpoena from the California State Senate Select Committee to Investigate Price Manipulation of the Wholesale Energy Market, asking her colleagues: “Are we OK with this confidential treatment?” The ISO had indicated it would provide confidential treatment for certain market participant data in response to the subpoena, with a deadline of May 18, 2001.

Key Correspondents

Mara’s correspondence patterns reveal her position at the center of Enron’s California regulatory affairs network, bridging the gap between San Francisco-based operations and Houston leadership.

The heavy concentration of correspondence with Dasovich reflects their complementary roles as the two primary California-based regulatory affairs professionals, while her regular communication with Steffes, Shapiro, and Kean demonstrates her integration into the broader Government Affairs leadership structure.

Post-Enron Testimony

Following Enron’s collapse, Susan Mara testified about the company’s internal culture. According to reports, she described an “anything-goes attitude inside Enron to maximize profits” and stated that trading strategies like “fat boy” were not considered illegal or manipulative by upper management. In a September 14, 2000 recorded conversation, she stated regarding a report for senior executives: “This is the time of year when government affairs has to prove how valuable it is to Ken Lay and Jeff Skilling.”

Her contemporaneous email correspondence in the corpus focuses on legitimate regulatory affairs work, specifically CPUC proceedings, ISO reform, direct access rules, and industry coalition coordination. The email record does not reveal direct discussion of trading strategies or market manipulation, as Mara’s role centered on regulatory policy rather than trading operations.

Email Activity

Mara’s email patterns in the Dasovich archive document the intensification of California regulatory work during the crisis period.

The dramatic decline after August 2001 may reflect organizational changes, shifting responsibilities, or limitations in the available archives. The peak period of May through July 2001 coincides with the most intense phase of California’s direct access suspension debate and related CPUC proceedings.

Data Limitations

Susan Mara does not have her own PST archive in the Enron corpus. All emails are preserved in the archives of colleagues, primarily Jeff Dasovich, Steven Kean, and James Steffes. This means the record captures only outbound emails she sent to these correspondents, not her complete correspondence. Personal biographical details beyond her job title and contact information are limited in the available email evidence.

See Also

• Jeff Dasovich - Director of Regulatory Affairs, California counterpart
• James Steffes - VP Government Affairs, supervisor
• Richard Shapiro - VP Global Government Affairs
• Steven Kean - VP Government Affairs
• California Energy Crisis - The crisis that dominated Mara’s work in 2000-2001

References

This article is based on Susan Mara’s email correspondence preserved in the Enron corpus across multiple archives, including approximately 1,007 emails in Jeff Dasovich’s archive, 1,293 in Steven Kean’s archive, and 67 in James Steffes’ archive, spanning October 1999 through December 2001. Secondary sources consulted include:

• Cambridge Business History Review article on Enron and the California Energy Crisis
• World Socialist Web Site reporting on Enron tape transcripts and testimony