temporary duty free basis, tools of the trade and equipment essential to the provision of

those services.

Temporary entry of business persons and specialists: Energy services companies employ

many people with highly specialized skills and should have the right to the temporary

entry of essential personnel necessary to provide a covered service.

Once these broad principles are agreed, then a compatible regulatory system must be adopted to

achieve:

Transparency in the formulation, promulgation and implementation of rules, regulations,

and technical standards.

Non discriminatory third party access to and interconnection with energy networks and

grids.

An independent regulatory system separate from and not accountable to any supplier of

energy services.

Transparent, objective and timely procedures for the allocation of scare network

resources, such as transmission capacity and rights of way.

The ESC appreciates this opportunity to comment to the docket.  If further information is

required, please contact the undersigned.

Brian T. Petty                                                                              Tim Richards

Co Chair                                                                                      Co Chair

International Association of Drilling Contractors                       General Electric

202 293 0670                                                    

     202 637 4407

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