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					                                      DRAFT

         PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
                                                                ID#2769
ENERGY DIVISION                                                 RESOLUTION E-3848
                                                                     October 2, 2003

                               R E S O L U T I O N

       Resolution E-3848. Southern California Edison Company (SCE)
       request for approval as reasonable Amendment No. 2 to the Power
       Purchase Contract between Southern California Edison Company
       and Ormesa Geothermal (QFID No. 3010) and Contract Termination
       Agreement between Ormesa Geothermal II (QFID No. 3012) and
       Southern California Edison. Approved.

       By Advice Letter 1726-E filed on August 1, 2003.
        __________________________________________________________

SUMMAR Y

Southern California Edison Company (SCE) requests approval for Amendment
No. 2 to the Power Purchase Contract between Southern California Edison
Company and Ormesa Geothermal (QFID No. 3010) and Contract Termination
Agreement between Ormesa Geothermal II (QFID No. 3012) and Southern
California Edison as reasonable. Specifically, SCE's Restructuring Advice Letter
Filing (RALF) would consolidate power purchase agreements (PPAs) for two
viable adjacent geothermal Qualifying Facilities (QF) projects (the Ormesa
Geothermal Project and the Ormesa Geothermal II Project), owned by the same
developer, into a single restructured contract. This resolution approves SCE's
request.

SCE requests that the Commission adopt a resolution at the earliest possible
time, but, by no later than November 1, 2003, so that, after taking into account
the 30-day period for applications for rehearing, 1 a condition of finality may be
achieved by the December 1, 2003 deadline agreed upon by SCE and Ormesa.
SCE requests the following findings:

1 Filing of a timely application for rehearing is a jurisdictional requirement for further
review of Commission decision in the courts. Pub. Util. Code Section 1731(b).




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      (1) Approve Amendment No. 2 as reasonable in all respects;
      (2) Approve the Termination Agreement entered into concurrently with
          and pursuant to Amendment No. 2 as reasonable in all respects; and
      (3) All payments made pursuant to Amendment No. 2 and the
          Termination Agreement are fully recoverable in SCE’s retail rates
          subject only to review by the Commission with respect to
          reasonableness of SCE’s administration of the QFID 3010 PPA, as
          amended by Amendment No. 2.

BACKGROUND

The Commission sought to encourage QF contract restructuring in its Preferred
Policy Decision, D.95-12-063, as modified by D.96-01-009, by proposing an
incentive mechanism to encourage the restructuring of QF contracts so that total
transition costs might be reduced. Specifically, shareholders would be allowed
to retain 10% of the net ratepayer benefits resulting from a renegotiation.

In D.96-12-088 (the Roadmap 2 Decision), the Commission stated its interest in
"establishing a generic and possibly expedited process by which we can assess
the reasonableness of [QF] contract restructuring in a manner which respects the
principles outlined in our Preferred Policy Decision" (D.96-12-088, p.79).

In 1998, the Commission adopted the Restructuring Advice Letter Filing (RALF) 2
process in D.98-12-066:

      "The restructuring Advice Letter [filing] process attached as Attachment B
      to this decision, shall be adopted subject to the modifications and
      clarifications set forth in Section 7 of this decision. " (D.98-12-066, Ordering
      Paragraph 1).

The Commission adopted the RALF process with modifications that were not
included in Attachment B to D.98-12-066 but were instead set forth in the



2Restructuring Advice Letter Filing ("RALF") Procedure For Review of QF Contract
Restructurings.




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decision. The Commission included the following provisions in the adopted
RALF process:

    "We will require that a statement of support or neutrality from ORA be
     attached to any restructuring Advice Letter filing. We will not limit the use
     of the restructuring Advice Letter in any other way, such as by dollar size
     or by type of QF (including affiliates of utilities). (D.98 -12-066, p.27, and
     Conclusion of Law 9)
    "While an ORA statement must be included with the restructuring Advice
     Letter, any other party may file a protest to the Advice Letter in the proper
     timeframe. We believe the procedural safeguards set forth in Attachment
     B, as modified by the following discussion, will ensure fairness in
     addressing the protests. Energy Division will review such protests (a nd
     any responses), and prepare a Resolution for the Commission pursuant to
     Section 9 of Attachment B [to D.98-12-066]. However, we modify Section 9
     so that Energy Division, at its discretion, may advise the utility that the
     matter is too complex and should be filed as an Application. Energy
     Division may also advise the utility to file an Application even if there are
     no protests, should the Division determine that there are complexities to
     the filing that the Division does not believe it is in the best position to
     resolve. The Energy Division should discuss any such recommendation
     with the Coordinating Commissioner for QF matters before advising the
     utility to file an Application." (D.98-12-066, p.17)
    "We do not adopt Section 4 in Attachment B addressing confidentiality.
     Confidentiality issues shall be consistent with the current practice for
     utility Advice Letters." (D.98-12-066, p.28).

As described in SCE AL 1726-E, the Ormesa Geothermal and Ormesa
Geothermal II Projects are geothermal QFs located in Imperial County,
California. SCE’s power purchases from Ormesa Geothermal and Ormesa
Geothermal II are currently made in accordance with the terms and conditions of
the Ormesa Geothermal and Ormesa II (QFID 3012) PPAs, which were entered
into pursuant to the Public Utility Regulatory Policies Act of 1978 (PURPA),
FERC’s regulations implementing PURPA (18 C.F.R. § 292.101 et seq. (2002)), and
decisions and orders of the Commission implementing PURPA in California.
These PPAs account for approximately 65.3 MW of installed electric geothermal
generating capacity. SCE states that the PPAs are based on Commission-
approved standard offer forms and all provide for 30-year terms. The Ormesa
Geothermal agreement was entered into on July 18, 1984 and the Ormesa


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Geothermal II agreement (QFID 3012) on June 13, 1984. These agreements will
expire in 2017 and 2018, respectively. Energy deliveries by the Projects during
2002 collectively totaled approximately 374,085,000 KWh.




NOTICE

Notice of AL 1726-E was made by publication in the Commission’s Daily
Calendar. Southern California Edison states that a copy of the Advice Letter was
mailed and distributed in accordance with Section III-G of General Order 96-A.

PROTESTS

Advice Letter AL 1726-E was filed on August 1, 2003. The protest period ended
August 21, 2003. No protests were filed.


DISCUSSION

Energy Division has reviewed both the public and confidential versions of SCE
AL 1727-E. SCE AL 1727-E included information required in Section 3 of RALF,
and has complied with the other RALF filing requirements. These requirements
are reproduced here as Attachment 1 to E-3848. Attachment 1 is modified from
the original Attachment B to D.98-12-066 to reflect determinations made in D.98-
12-066.

On July 14, 2003, ORA issued a letter in support of the contract restructuring,
now proposed by SCE in AL 1726-E. The RALF procedure requires a statement
of support or neutrality from ORA be attached to any restructuring Advice Letter
filing.

SCE does not seek any shareholder incentive as a result of this contract
restructuring.

With regard to historical performance, the projects have not experienced any
operational issues such as probation or deration. From 1999 through 2002,




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overall production from the projects decreased slightly, but increased after
ORMAT's 3 reacquisition of the projects, and the subsequent capital improvement
program. As a geothermal QF, Ormesa is not subject to efficiency monitoring
standards.

Section 3f. of the RALF procedure requires disclosure of any significant, pending
legal or regulatory disputes between the utility and the QFs. Upon such request,
SCE informed the Energy Division that there are no disputes of any nature
between Edison and the projects.

With regard to future viability, Ormesa plans to repower some of the units with
newer machinery of the same technology, and requested that Edison concur that
the equipment change-out constituted a repower and not a change of prime
mover. After an engineering review of Ormesa's plans, Edison ultimately
concurred that the equipment change constituted a repower and would not
violate the contract. During the negotiations surrounding contract consolidation,
Ormesa engaged in their capital improvement program, including the
replacement of the project's cooling towers. Ormesa demonstrated to Edison's
satisfaction through its plans and actions that Ormesa was determined to
maintain the viability of the projects either separately or as consolidated.

The primary ratepayer benefit that would result from the proposed contract
restructuring is a one-time, lump sum payment by Ormesa, LLC to SCE. This
payment could be received by SCE as soon as five days after Commission
approval of SCE AL 1727-E. The payment amount is fixed and does not
represent forecasted savings, nor is it tied to an energy index or other variable
rate. Payment would be credited to SCE's 0103 Account for Purchased Power on
behalf of QFID 3012, resulting in the same one-time, lump sum reduction amount
eligible for inclusion in SCE's Energy Resource Recovery Account (ERRA).

Due to the relatively immediate ratepayer benefit that would accrue, the
Commission should approve, as reasonable, Amendment No. 2 to the Power

3 ORMAT Group, an energy company based in Sparks, Nevada, purchased Ormesa
Geothermal I & II in April 2002. The company owns and operates about 30 energy
projects (geothermal, waste heat recovery, and solar), a total portfolio of about 200 MW.
See www.ormat.com




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Purchase Contract between Southern California Edison Company and Ormesa
Geothermal (QFID No. 3010) and the Contract Termination Agreement between
Ormesa Geothermal II (QFID No. 3012) and Southern California Edison.
Accordingly, SCE should be allowed to recover all payments made pursuant to
Amendment No. 2 and the Termination Agreement in SCE’s retail rates, subject
to review by the Commission with respect to the reasonableness of SCE’s
administration of the QFID 3010 PPA, as amended by Amendment
No. 2.

COMMENTS

PU Code section 311(g)(1) provides that this resolution must be served on all
parties and subject to at least 30 days public review and comment prior to a vote
of the Commission. However, since this is an uncontested matter in which the
resolution grants the relief requested. Pursuant to PU Code 311(g)(2 ), the
otherwise applicable 30-day period for public review and comment is being
reduced.


FINDINGS

1. The Commission adopted the Restructuring Advice Letter Filing (RALF)
   process in D.98-12-066. On August 1, 2003, SCE filed Advice Letter 1726-E
   pursuant to the RALF process for approval to consolidate two QF contracts.

2. AL 1726-E was not protested.

3. On July 14, 2003, ORA issued a letter in support of the contract restructuring,
   now proposed by SCE in AL 1726-E.

4. SCE complied with RALF filing requirements.

5. SCE does not seek any shareholder incentive as a result of this contract
   restructuring.

6. The Ormesa QFs have not experienced any operational issues such as
   probation or deration, and project viability is expected to be enhanced
   through capital improvements.




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7. There are no pending legal or regulatory disputes between SCE and the
   Ormesa QFs.

8. The primary ratepayer benefit that would result from the proposed contract
   restructuring is a one-time, lump sum payment by Ormesa, LLC to SCE. This
   payment would be credited to SCE's 0103 Account for Purchased Power on
   behalf of QFID 3012, resulting in the same one-time, lump sum reduction
   amount eligible for inclusion in SCE's Energy Resource Recovery Account
   (ERRA).

9. We should approve, as reasonable, Amendment No. 2 to the Power Purchase
   Contract between Southern California Edison Company and Ormesa
   Geothermal (QFID No. 3010) and the Contract Termination Agreement
   between Ormesa Geothermal II (QFID No. 3012) and Southern California
   Edison.

10. SCE should be allowed to recover all payments made pursuant to
    Amendment No. 2 and the Termination Agreement in SCE's retail rates,
    subject to review by the Commission with respect to the reasonableness
    of SCE's administration of the QFID 3010 PPA, as amended by
    Amendment No. 2.

THEREFORE IT IS ORDERED THAT:

1. Southern California Edison Company's request for approval of Amendment
   No. 2 to the Power Purchase Contract between Southern California Edison
   Company and Ormesa Geothermal (QFID No. 3010) and the Contract
   Termination Agreement between Ormesa Geothermal II (QFID No. 3012) and
   Southern California Edison, as requested in Advice Letter 1726 -E, is granted.

2. SCE may recover all payments made pursuant to Amendment No. 2 and the
   Termination Agreement in SCE's retail rates, subject to review by the
   Commission with respect to the reasonableness of SCE's administration of the
   QFID 3010 PPA, as amended by Amendment No. 2.

This Resolution is effective today.




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I certify that the foregoing resolution was duly introduced, passed and adopted
at a conference of the Public Utilities Commission of the State of California held
on October 16, 2003; the following Commissioners voting favorably thereon:




                                                       _________________
                                                       WILLIAM AHERN
                                                       Executive Director




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                    Attachment 1 to Resolution E-3848
                     Formerly ATTACHMENT B to D.98-12-066

               [Modified Here in Attachment 1 to Resolution E-3848
                To Reflect Modifications Set Forth In D.98-12-066]

                                      Revised Exhibit A
        RESTRUCTURING ADVICE LETTER FILING ("RALF") PROCEDURE FOR
               REVIEW OF QF CONTRACT RESTRUCTURINGS

       THIS ATTACHMENT B IS SUBJECT TO THE MODIFICATIONS SET FORTH
                   IN SECTION 7 OF D.98-12-066, INCLUDING:


       "We will require that a statement of support or neutrality from ORA be attached
        to any restructuring Advice Letter filing. We will not limit the use of the
        restructuring Advice Letter in any other way, such as by dollar size or by type of
        QF (including affiliates of utilities). (D.98-12-066, p.27, and Conclusion of Law 9)
       "While an ORA statement must be included with the restructuring Advice Letter,
        any other party may file a protest to the Advice Letter in the proper timeframe.
        We believe the procedural safeguards set forth in Attachment B, as modified by
        the following discussion, will ensure fairness in addressing the protests. Energy
        Division will review such protests (and any responses), and prepare a Resolution
        for the Commission pursuant to Section 9 of Attachment B [to D.98-12-066].
        However, we modify Section 9 so that Energy Division, at its discretion, may
        advise the utility that the matter is too complex and should be filed as an
        Application. Energy Division may also advise the utility to file an Application
        even if there are no protests, should the Division determine that there are
        complexities to the filing that the Division does not believe it is in the best
        position to resolve. The Energy Division should discuss any such
        recommendation with the Coordinating Commissioner for QF matters before
        advising the utility to file an Application." (D.98-12-066, p.17)
       "We do not adopt Section 4 in Attachment B addressing confidentiality.
        Confidentiality issues shall be consistent with the current practice for utility
        Advice Letters." (D.98-12-066, p.28).

    1. The utility will submit a restructuring advice letter to the Commission's Energy
Division which will contain the essential information necessary to establish the
reasonableness of the proposed voluntarily negotiated QF restructuring. Each such
filing, and all protests, responses and replies concerning the filing, shall indicate a


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postal address and (where appropriate) a FAX number or e-mail address at which the
advice letter filer, protestant or respondent, agrees to receive subsequent documents
and notices relevant to the advice letter. Each such filing will be reported in the Daily
Calendar.
   2. Service of the restructuring advice letter shall be as follows:
    On or before the date a restructuring advice letter is submitted for filing, and unless
otherwise directed by Commission order, the utility shall serve the restructuring advice
letter (1) on the Consumer Services Division and the Office of Ratepayer Advocates
(service on these parties may be made by Internet); and (2) on the utility's restructuring
advice letter service list and any other third parties as specified by the Energy Division,
other Commission order, or statute.
    The utility's restructuring advice letter service list shall include the postal and e -mail
address, as appropriate, of persons on the list. The utility shall include on the requested
list any person that requests such inclusion and may periodically confirm the desire of
any currently listed person to remain on the list.
    After the filing of a restructuring advice letter, and pending its disposition, the
utility shall promptly provide a copy of the advice letter to anyone so requesting. Such
provision shall be without charge to anyone who is a current customer for utility
services from the utility, or to anyone receiving the advice letter by Internet.
    3. The restructuring advice letter shall contain the following categories of
information, including all relevant work papers and other relevant supporting
documents:


a. Identification of the QF, location of the QF's generating facility, brief description of
the generating facility size, type of technology and other pertinent or unique
characteristics.

b. Ownership of the QF project and related companies, including affiliate relationships
of the parties involved in the transaction, if any.

c. A detailed description of the historical operational performance of the project,
including historical production and compliance with performance and efficiency
monitoring standards.

d. A summary of the proposed contract restructuring.

e. A summary of the ratepayer benefits.

f. A description of any significant, pending legal or regulatory disputes between the
Utility and the QF, and their resolution or status.


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g. An assessment of the QF's projected economic and operational viability under the
existing contract.

h. A detailed description of ratepayer benefits, shareholder incentive, and sensitivity
analyses.

i. A copy of the QF's existing contract, including any amendments.

j. A copy of the executed or unexecuted restructured agreement for which approval is
sought and copies of all related agreements between the QF and the Utility.
    4. The publicly available version of the restructuring advice letter may be redacted
to delete the following types of confidential information, which redaction would be
approved in advance by the Commission in its orders authorizing the use of the advice
letter process:


a. The schedule of any restructuring payments to be made to the QF, including the total
amount thereof.

b. The Utility's non-public projection of replacement energy and capacity costs.

c. The Utility's projection of future production by and payments to the QF under the
existing contract.

d. Non-public financial and operating data provided on a confidential basis by the QF
to the Utility.

e. The Utility's assessment of the QF's financial and operating viability under the
existing contract.

f. The Utility's analysis of ratepayer savings under expected, best case and worst case
scenarios (except that the projected range of savings under each scenario shall not itself
be deemed confidential).

g. Portions of restructuring agreements that are deemed to be confidential by the parties
and which, if made public, would place the Utility and/or the QF at a competitive
disadvantage.

h. Other information which constitutes a protectable trade secret of a party or which, if
publicly disclosed, would place the Utility or the QF at a competitive disadvantage.
[Deleted per D.98-12-066, p.18]


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   5. The restructuring advice letter shall only take effect upon Commission approval.
   6. Any person may protest or respond to a restructuring advice letter as follows:
    Within 20 days after the date that the advice letter is reported in the Daily Calendar,
the protest or response shall be submitted to the Energy Division and served on the
same day on the utility filing the restructuring advice letter. After filing a protest, and
pending disposition of the restructuring advice letter, the protestant shall promptly
provide a copy of the protest to anyone so requesting.
   A restructuring advice letter may be protested on one or more of the following
grounds:

a. The utility did not properly serve or give notice of the restructuring advice letter;

b. The relief requested in the restructuring advice letter would violate statute or
Commission order;

c. The restructuring advice letter contains material errors, or does not follow the
Commission's approved methodology, if any.

In addition, a restructuring advice letter may be protested on the grounds that the
proposed restructuring is unjust, unreasonable, or discriminatory, provided, however,
that a restructuring advice letter is not subject to protest on these grounds where such
protest would require relitigating a prior order of the Commission.
    The utility filing the restructuring advice letter shall reply to each protest and may
reply to any response. Any such reply shall be submitted to the Energy Division not
later than five business days after the last day to serve a protest or response, and shall
be served on the same day on the person making the protest or response. If there are
multiple protests or responses to a restructuring advice letter, the utility's reply may be
to all such protests and responses.
    The Energy Division may consider a late-filed protest or response. If the Energy
Division considers a late-filed protest or response, it shall notify the utility filing the
restructuring advice letter, and the utility shall have five business days from the date of
issuance of the notice within which to reply to the late-filed protest or response.
   7. The utility filing the restructuring advice letter may make minor revisions or
corrections to the filing at any time before the effective date by filing and serving a
supplement or substitute sheet. The utility shall withdraw the advice letter without
prejudice in order to make major revisions. Supplements, substitute sheets, and
withdrawals shall be filed and served in the same manner and on the same persons as
was the original advice letter.




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   Minor revisions do not automatically extend the protest period. The Energy Division
on its own motion or at the request of any person, may issue a notice extending the
protest period. Any protest during the extended period shall be confined to the
substance of the revision.
    8. A supplement to a restructuring advice letter may be used to make minor
revisions. The following revisions are examples of what commonly, but not necessarily,
qualify as minor: a modification in response to a protest; a language clarification; or a
later effective date. The supplement shall bear the same identifying number as the
original advice letter but shall have a letter suffix "A" for the first supplement, "B" for
the second supplement, etc.
   9. Upon completion of the protest, response and reply period, the Energy Division
will have 40 days within which to review the proposed restructuring to determine
whether the information provided under paragraph 2 above and in response to any
protest establishes that the proposed restructuring is reasonable under the
Commission's standards and should be approved.
   "Energy Division will review such protests (and any responses), and prepare a
   Resolution for the Commission pursuant to Section 9 of Attachment B. However,
   we modify Section 9 so that Energy Division, at its discretion, may advise the utility
   that the matter is too complex and should be filed as an Application. Energy
   Division may also advise the utility to file an Application even if there are no
   protests, should the Division determine that there are complexities to the filing that
   the Division does not believe it is in the best position to resolve. The Energy
   Division should discuss any such recommendation with the Coordinating
   Commissioner for QF matters before advising the utility to file an Application."
   (D.98-12-066, p.17)


When such review has been completed, and within such 40-day period, the Energy
Division will prepare and submit to the Commission for consideration at the
Commission's next public meeting which is at least 10 days thereafter a proposed
resolution either approving or rejecting the restructuring advice letter. (To facilitate this
process, the utility may submit a proposed form of resolution as part of the advice letter
package.) A proposed resolution approving the restructuring advice letter shall make at
least the following finding:


       (a) That the restructuring is reasonable;

       (b) That all payments to be made pursuant to the restructuring shall be recovered
       by the utility through its Annual Transition Cost Proceeding or other mechanism
       authorized by the Commission, subject only to the utility's prudent
       administration of the restructuring agreement.


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The Commission may then adopt the proposed resolution or modify it in whole or in
part. After the Commission has acted on the resolution, its action will be reported in the
Daily Calendar and the resolution will be served on the utility filing the restructuring
advice letter, the affected QF and on any person filing a protest or response to the
restructuring advice letter.
    10. Pursuant to Public Utilities Code Sections 1731 to 1736 and Rules 85 to 86.7 of the
Commission's Rules of Practice and Procedure, the utility filing the restructuring advice
letter, the affected QF, or any person filing a protest to the restructuring advice letter
may apply for rehearing of a resolution approving or rejecting the restructuring advice
letter pursuant to paragraph 9 above. The application for rehearing shall set forth
specifically the grounds on which the applicant considers the resolution to be unlawful.
Other than the affected QF, a person filing a response does not have standing to apply
for rehearing.
    The application for rehearing shall be submitted to the Commission's Docket Office,
which will assign a docket number to the application, and with the Energy Division. If
the applicant is the utility filing the restructuring advice letter, it shall serve all persons
filing protests or responses to the restructuring advice letter. If the applicant is the
affected QF or a person filing a protest, the applicant shall serve the utility and all other
persons filing protests or responses to the restructuring advice letter.
    11. If the Commission's final resolution does not approve the proposed restructuring
in its entirety, then the terms of the agreement between the utility and the QF will
determine whether or not the restructuring effort will terminate or whether the
proposed restructuring will be resubmitted for consideration through a formal
application process. Also, subject to its agreement with the QF, the utility will have the
right to withdraw a restructuring advice letter without prejudice at any time prior to
Commission action on the draft resolution prepared by the Energy Division, or to
pursue a formal application process in lieu of the advice letter procedure.
    12. Nothing in the restructuring advice letter filing procedure shall preclude the
utility from electing not to use the advice letter process.




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SCE AL 1726-E/WSM

STATE OF CALIFORNIA                                                                     GRAY DAVIS, Gover

PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298




September 22, 2003                          Commission Meeting Date: October 2,
2003                                        ID#2769


              TO: PARTIES IN R.99-11-022 and SOUTHERN CALIFORNIA
                  EDISON COMPANY ADVICE LETTER 1726-E,
                  QUALIFYING FACILITY (QF) CONTRACT
                  AMENDMENT BETWEEN THE UTILITY AND ORMESA
                  PURSUANT TO THE RESTRUCTURING ADVICE
                  LETTER FILING (RALF) PROCEDURE.

              Enclosed is draft Resolution E-3848 of the Energy
              Division. It addresses Southern California Edison
              Company Advice Letter 1726-E for approval as
              reasonable Amendment No. 2 to the Power Purchase
              Contract between Southern California Edison Company
              and Ormesa Geothermal (QFID No. 3010) and Contract
              Termination Agreement between Ormesa Geothermal II
              (QFID No. 3012) and Southern California Edison.

              The draft Resolution will be on the agenda at the October
              2, 2003 Commission meeting. Since this is an
              uncontested matter in which the resolution grants the
              relief requested, pursuant to PU Code 311(g)(2), the
              otherwise applicable 30-day period for public review and
              comment is being reduced. The Commission may then
              vote on this draft Resolution or it may postpone a vote
              until later.

              When the Commission votes on a draft Resolution,
              it may adopt all or part of it as written, amend,
              modify or set it aside and prepare a different
              Resolution. Only when the Commission acts does
              the Resolution become binding on the parties.



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      Parties may submit comments on the draft
      Resolution.

      An original and two copies of the comments, with a
      certificate of service, should be submitted to:

      Jerry Royer
      Energy Division
      California Public Utilities Commission
      505 Van Ness Avenue
      San Francisco, CA 94102
      fax: 415-703-2200

      A copy of the comments should also be submitted
      to:

      Wade McCartney
      Energy Division
      California Public Utilities Commission
      770 L Street, Suite 1050
      Sacramento, CA 95814
      email: wsm@cpuc.ca.gov

      Any comments on the draft Resolution must be
      received by the Energy Division by close of
      business on Friday September 26, 2003. Those
      submitting comments must serve a copy of their
      comments on (1) the entire service list attached to
      the draft Resolution, including the R.99-11-022
      service list, (2) all Commissioners, and (3) the
      Director of the Energy Division, on the same date
      that the comments are submitted to the Energy
      Division.

      Comments shall be limited to five pages in length
      plus a subject index listing the recommended


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SCE AL 1726-E/WSM

        changes to the draft Resolution. Comments shall
        focus on factual, legal or technical errors in the
        proposed draft Resolution. Comments that merely
        reargue positions taken in the advice letter or
        protests will be accorded no weight and are not to
        be submitted. There will be no reply comments on
        the draft resolution.

        Late submitted comments will not be considered.



        Don Lafrenz
Energy Division


Enclosure

Service List – Parties in SCE AL 1726-E and R.99-11-022




                                       17
Resolution E-3848                    DRAFT                          October 2, 2003
SCE AL 1726-E/WSM

                               CERTIFICATE OF SERVICE


      I certify that I have by mail this day served a true copy of Draft Resolution E-
      3848 on all
      parties in these filings or their attorneys as shown on the attached list.

      Dated September 19, 2003 at San Francisco, California.


                                             ____________________
                                                 Jerry Royer




                                        NOTICE

               Parties should notify the Energy Division, Public Utilities
                    Commission, 505 Van Ness Avenue, Room 4002
                 San Francisco, CA 94102, of any change of address to
                 insure that they continue to receive documents. You
                must indicate the Resolution number on the service list
                             on which your name appears.




                                        18
Resolution E-3848                 DRAFT               October 2, 2003
SCE AL 1726-E/WSM


 ROGER BERLINER                               JONATHAN M. WEISGALL
 MANATT, PHELPS & PHILLIPS, LLP               V.P. LEGISLATIVE & REGULATORY
 County of Las Angeles                        AFFAIRS
 1501 M STREET, N.W., SUITE 700               CALENERGY COMPANY, INC.
 WASHINGTON, DC 20005                         1200 NEW HAMPSHIRE AVE., NW, SU
                                              300
 JAMES ROSS                                   DOUGLAS L. ANDERSON
                                              WASHINGTON, DC 20036
 RCS CONSULTING, INC.                         VICE PRESIDENT AND GENERAL
 MIDSET COGENERATION COMPANY                  COUNSEL
 500 CHESTERFIELD CENTER, SUITE 320           CE GENERATION, LLC
 CHESTERFIELD, MO 63017                       302 SOUTH 36TH STREET, SUITE 400
                                              OMAHA, NE 68131
 ANDREW N. CHAU                               DAVID M. NORRIS
 TRACTEBEL POWER, INC.                        ASSOCIATE GENERAL COUNSEL
 1177 WEST LOOP SOUTH, SUITE 900              SIERRA PACIFIC POWER COMPANY
 HOUSTON, TX 77027                            6100 NEIL ROAD, PO BOX 10100
                                              RENO, NV 89520

 HOWARD CHOY                                  KEVIN MC SPADDEN
 ENERGY MANAGEMENT DIVISION                   ATTORNEY AT LAW
 MANAGER                                      MILBANK, TWEED, HADLEY & MC CL
 COUNTY OF LOS ANGELES                        601 S. FIGUEROA STREET, 30TH FLOO
 INTERNAL SERVICES DEPARTMENT                 LOS ANGELES, CA 90068
 1100 NORTHEASTERN AVENUE
 DAN WOODS
 LOS ANGELES, CA 90063                        TANDY MCMANNES
 WHITE & CASE LLP                             KJC CONSULTING COMPANY
 Smurfit Stone Container Corporation,/Delta   KRAMER JUNCTION OPERATING
 Power Co./Willamette Industries,             COMPANY
 Inc./E.F.Oxnard, Inc.                        2938 CROWNVIEW DRIVE
 633 WEST FIFTH STREET, SUITE 1900            RANCHO PALOS VERDES, CA 90275
 SUSAN ROSSI
 LOS ANGELES, CA 90071-2087                   ERIC J. ISKEN
 ATTORNEY AT LAW                              ATTORNEY AT LAW
 CALIFORNIA POWER EXCHANGE                    SOUTHERN CALIFORNIA EDISON
 CORPORATION                                  COMPANY
 70 SOUTH LAKE AVE 910                        2244 WALNUT GROVE AVENUE
 PASADENA, CA 91101-4960                      ROSEMEAD, CA 91770




                                     19
Resolution E-3848           DRAFT               October 2, 2003
SCE AL 1726-E/WSM

 JAMES B. WOODRUFF                      THEODORE ROBERTS
 SOUTHERN CALIFORNIA EDISON             ATTORNEY AT LAW
 COMPANY                                SEMPRA ENERGY
 2244 WALNUT GROVE AVENUE, SUITE 342,   SAN DIEGO GAS AND ELECTRIC
 GO1                                    COMPANY
 ROSEMEAD, CA 91770                     101 ASH STREET, HQ 12B
 EDWARD E. MADDOX                       NORMAN J. CA 92101-3017
                                        SAN DIEGO, FURUTA
 BUSINESS DEVELOPMENT MANAGER           ATTORNEY AT LAW
 SEAWEST WINDPOWER, INC.                DEPARTMENT OF THE NAVY
 1455 FRAZEE ROAD, SUITE 900            2001 JUNIPERO SERRA BLVD., SUITE 6
 SAN DIEGO, CA 92108-4310               DALY CITY, CA 94014-3890

 DIANE I. FELLMAN                       ROBERT FINKELSTEIN
 ATTORNEY AT LAW                        ATTORNEY AT LAW
 LAW OFFICES OF DIANE I. FELLMAN        THE UTILITY REFORM NETOWRK (TU
 234 VAN NESS AVENUE                    711 VAN NESS AVE., SUITE 350
 SAN FRANCISCO, CA 94102                SAN FRANCISCO, CA 94102

 John M Chamberlain                     EVELYN KAHL
 CALIF PUBLIC UTILITIES COMMISSION      ATTORNEY AT LAW
 CPUC OFFICE OF RATEPAYER               ALCANTAR & KAHL, LLP
 ADVOCATES                              ENERGY PRODUCERS AND USERS
 LEGAL DIVISION                         COALITION (EPUC)
 505 VAN NESS AVENUE ROOM 4107          120 MONTGOMERY STREET, SUITE 22
 LINDA SHERIF
 SAN FRANCISCO, CA 94102                ANN C. SELTING
                                        SAN FRANCISCO, CA 94104
 ATTORNEY AT LAW                        GRUENEICH RESOURCE ADVOCATES
 ALCANTAR & KAHL LLP                    Sonoma County Water Agency
 COGENERATION ASSOCIATION OF            582 MARKET STREET, SUITE 1020
 CALIFORNIA (CAC) and EPUC              SAN FRANCISCO, CA 94104-5311
 120 MONTGOMERY STREET, STE 2200
 DIAN M. GRUENEICH
 SAN FRANCISCO, CA 94104                ALICE REID
 ATTORNEY AT LAW                        PACIFIC GAS AND ELECTRIC COMPA
 GRUENEICH RESOURCE ADVOCATES           77 BEALE STREET
 582 MARKET STREET, SUITE 1020          SAN FRANCISCO, CA 94105
 SAN FRANCISCO, CA 94104-5311




                              20
Resolution E-3848                 DRAFT             October 2, 2003
SCE AL 1726-E/WSM

 CHARLES R. MIDDLEKAUF                       BRIAN CRAGG. ATTORNEY AT LAW
 PACIFIC GAS AND ELECTRIC COMPANY            GOODIN MACBRIDE SQUERI RITCHIE
 LAW DEPARTMENT                              DAY LLP
 77 BEALE STREET, B30A                       CAITHNESS ENERGY/LUZ SOLAR
 SAN FRANCISCO, CA 94105                     PARTNERS LTD.,VIII&IX
                                             505 SANSOME STREET, SUITE 900
 JAMES D. SQUERI, ATTORNEY AT LAW            JERRY R. BLOOM, CA 94111
                                             SAN FRANCISCO, ATTORNEY AT LAW
 GOODIN MACBRIDE SQUERI RITCHIE &            WHITE & CASE LLP
 DAY LLP                                     CALIFORNIA COGENERATION COUN
 MONSANTO CO.                                (CCC)
 505 SANSOME STREET, SUITE 900               THREE EMBARCADERO CENTER, SUI
 SAN FRANCISCO, CA 94111                     2210
 JOSEPH M. KARP, ATTORNEY AT LAW             LINDSEY HOW-DOWNING,
                                             SAN FRANCISCO, CA 94111 ATTORNE
 WHITE & CASE LLP                            LAW
 Smurfit Stone COntainer Corporation,        DAVIS WRIGHT TREMAINE LLP
 f.k.a.Jefferson Smurfit Corporation(U.S.)   CALPINE CORPORATION
 THREE EMBARCADERO CENTER, SUITE             ONE EMBARCADERO CENTER, SUITE
 2210                                        SAN FRANCISCO, CA 94111
 JEFFREY GRAY
 SAN FRANCISCO, CA 94111                     SARA STECK MYERS, ATTORNEY AT
 DAVIS WRIGHT TREMAINE                       ENRON WIND CORP., CENETER FOR
 Dynamis Incorporated                        ENERGY EFFICIENCY AND RENEWAB
 ONE EMBARCADERO CENTER STE. 600             TECHNOLOGIES (CEERT)
 SAN FRANCISCO, CA 94111-3611                122 - 28TH AVENUE
                                             SAN FRANCISCO, CA 94121
 SETH HILTON, ATTORNEY AT LAW                NANCY RADER, EXECUTIVE DIRECTO
 MORRISON & FOERSTER LLP                     CALIFORNIA WIND ENERGY
 EL PASO MERCHANT ENERGY, L.P.               ASSOCIATION
 101 YGNACIO VALLEY ROAD, SUITE 450          1198 KEITH AVENUE
 WALNUT CREEK, CA 94596-7032                 BERKELEY, CA 94708

 R. THOMAS BEACH                             PATRICK MCDONNELL
 PRINCIPAL CONSULTANT                        AGLAND ENERGY
 CROSSBORDER ENERGY                          TXU ENERGY SERVICES
 WATSON COGENERATION COMPANY                 2000 NICASIO VALLEY
 2560 NINTH STREET, SUITE 316                NICASIO, CA 94946
 BERKELEY, CA 94710




                                    21
Resolution E-3848           DRAFT             October 2, 2003
SCE AL 1726-E/WSM

 JIM CROSSEN                          STEVE FELTE, GENERAL MANAGER
 AUTOMATED POWER EXCHANGE, INC.       TRI-DAM PROJECT & POWER AUTHO
 TECHMART                             PO BOX 1158
 5201 GREAT AMERICA PARKWAY, SUITE    PINECREST, CA 95364-0158
 552
 SANTA CLARA, CA 95054
 ROBERT BEACH                         JOHN J. PREVOST
 SONOMA COUNTY WATER AGENCY           PACIFIC LUMBER COMPANY
 739 MIRAMAR STREET                   125 MAIN STREET
 WINDSOR, CA 95492                    SCOTIA, CA 95565


 DALE W. MAHON                        MATTHEW V. BRADY, SPECIAL COUN
 CENTRAL HYDROELECTRIC                MATTHEW V. BRADY & ASSOCIATES
 CORPORATION                          Central Hydroelectric Company
 9951 GRANT LINE ROAD                 2339 GOLD MEADOW WAY, SUITE 230
 ELK GROVE, CA 95624-1411             GOLD RIVER, CA 95670

 DOUGLAS K. KERNER                    ROBERT ELLERY
 ATTORNEY AT LAW                      SIERRA PACIFIC INDUSTRIES
 ELLISON, SCHNEIDER & HARRIS          19794 RIVERSIDE AVENUE
 INDEPENDENT ENERGY PRODUCERS         ANDERSON, CA 96007
 ASSOCIATION (IEP)
 2015 H STREET
 MICHAEL ALCANTAR, ATTORNEY AT
 SACRAMENTO, CA 95814                 DON SCHOENBECK
 LAW                                  RCS, INC
 ALCANTAR & KAHL LLP                  COALINGA COGENERATION COMPA
 COGENERATION ASSOCIATION OF          900 WASHINGTON STREET, SUITE 780
 CALIFORNIA                           VANCOUVER, WA 98660
 1300 SW FIFTH AVENUE, SUITE 1750
 C. FAIRLEY SPILLMAN
 PORTLAND, OR 97201                   KAY DAVOODI
 AKIN, GUMP, STRAUSS, HAUER & FELD,   NAVY RATE INTERVENTION OFFICE
 LLP                                  WASHINGTON NAVY YARD
 1333 NEW HAMPSHIRE AVENUE, NW        1314 HARWOOD STREET SE
 WASHINGTON, DC 20036                 WASHINGTON NAVY YARD, DC 20
                                      5018




                              22
Resolution E-3848               DRAFT                October 2, 2003
SCE AL 1726-E/WSM

 MAURICE BRUBAKER                            JANET DOYLE
 BRUBAKER & ASSOCIATES                       KRAMER JUNCTION COMPANY
 PO BOX 412000                               1636 AJAX LANE
 ST. LOUIS, MO 63141                         EVERGREEN, CO 80439


 CLIFF ROCHLIN                               ED J. WHELESS
 SOUTHERN CALIFORNIA GAS COMPANY             DIVISION ENGINEER
 SEMPRA ENERGY                               COUNTY SANITATION DIST. OF L.A.
 555 W. FIFTH STREET, ML 22A1                COUNTY
 LOS ANGELES, CA 90013                       SOLID WASTER MANAGEMENT DEPT
                                             PO BOX 4998
 JOHN COSTANZO                               DANIEL W. DOUGLASS
                                             WHITTIER, CA 90607-4998
 KRAMER JUNCTION COMPANY                     ATTORNEY AT LAW
 1778 FISK COURT                             LAW OFFICES OF DANIEL W. DOUGL
 THOUSAND OAKS, CA 91362                     6303 OWENSMOUTH AVENUE, TENTH
                                             FLOOR
                                             WOODLAND HILLS, CA 91367-2262
 JACK MCNAMARA                               CASE ADMINISTRATION
 GEO-ENERGY PARTNERS-1983 LTD.               SOUTHERN CALIFORNIA EDISON
 PO BOX 531                                  COMPANY
 AGOURA HILLS, CA 91376                      2244 WALNUT GROVE AVENUE, R00M
                                             ROSEMEAD, CA 91770

 JOHN W. LESLIE                              ANDY FRIEDL
 ATTORNEY AT LAW                             CP KELCO
 LUCE, FORWARD, HAMILTON & SCRIPPS,          2025 E. HARBOR DRIVE
 LLP                                         SAN DIEGO, CA 92113
 Coral Energy Resourced, LLC/Engage Energy
 US,L.P.
 CHRIS SMITH
 600 WEST BROADWAY, SUITE 2600               ROBERT TURNER
 CORAL ENERGY RESOURCES, LLC
 SAN DIEGO, CA 92101                         COASTAL MERCHANT ENERGY LP
 4320 LA JOLLA VILLAGE DRIVE                 PO BOX 17097
 SAN DIEGO, CA 92122                         SAN DIEGO, CA 92177




                                  23
Resolution E-3848            DRAFT           October 2, 2003
SCE AL 1726-E/WSM

                                     ERIC WILLS, PRESIDENT
 MITSUBISHI POWER SYSTEMS, INC.
                                     SUNRAY ENERGY, INC.
 100 BAYVIEW CIRCLE, SUITE 4000
                                     20668 PASEO DE LA CUMBRE
 NEWPORT BEACH, CA 92660
                                     YORBA LINDA, CA 92687


 JAMES L. MCARTHUR                   EDWARD G. CAZALET, CHAIRMAN
 DAI OILDALE, INC                    AUTOMATED POWER EXCHANGE
 3300 MANOR DRIVE                    5201 GREAT AMERICA PARKWAY
 BAKERSFIELD, CA 93308               SANTA CLARA, CA 94054


 JUDY PECK                           KEENAN O'BRIEN
 SEMPRA ENERGY UTILITIES             PACIFIC GAS AND ELECTRIC COMPA
 601 VAN NESS AVENUE, SUITE 2060     245 MARKET ST., MAIL CODE: N12E
 SAN FRANCISCO, CA 94102             SAN FRANCISCO, CA 94102


 WILLIAM BLATTNER                    JACK MCGOWAN
 ADMINSTRATOR STATE REG. RELATIONS   GRUENEICH RESOURCE ADVOCATES
 SEMPRA ENERGY                       582 MARKET STREET, SUITE 1020
 601 VAN NESS AVENUE, SUITE 2060     SAN FRANCISCO, CA 94104
 SAN FRANCISCO, CA 94102

 JOHN PAPPAS                         ROBERT T. BOYD
 UTILITY ELECTRIC PORTFOLIO          ENRON WIND CORP.
 MANAGEMENT                          444 SOUTH FLOWER STREET, SUITE 45
 PACIFIC GAS AND ELECTRIC COMPANY    LOS ANGELES, CA 94105
 77 BEALE STREET, N12E
 SAN FRANCISCO, CA 94105
 TONY WAKIM                          ARTHUR V. O'DONNELL
 KENNEDY/JENKS CONSULTANTS           CALIFORNIA ENERGY MARKETS
 622 FOLSOM STREET                   9 ROSCOE STREET
 SAN FRANCISCO, CA 94107             SAN FRANCISCO, CA 94110-5921




                               24
Resolution E-3848           DRAFT           October 2, 2003
SCE AL 1726-E/WSM

 MARGERY NEIS                       EDWARD W. O'NEILL, ATTORNEY AT
 FTI CONSULTING                     DAVIS WRIGHT TREMAINE LLP
 353 SACRAMENTO STREET              ONE EMBARCADERO CENTER, SUITE
 SAN FRANCISCO, CA 94111            SAN FRANCISCO, CA 94111-3611


 SHIRLEY L. WONG                    ALEXANDRE MAKLER, ATTORNEY A
 PACIFIC GAS AND ELECTRIC COMPANY   LAW
 PO BOX 770000, RM. 987 - B9A       CALPINE CORPORATION
 SAN FRANCISCO, CA 94177            PO BOX 11749
                                    PLEASANTON, CA 94588-1749

 ROBERT SZYMANSKI                   STEVE HUHMAN
 POWERWORKS, INC.                   SOUTHERN COMPANY ENERGY
 781 THOMAS LANE                    MARKETING
 WALNUT CREEK, CA 94596             1350 TREAT BLVD. SUITE 500
                                    WALNUT CREEK, CA 94597

 VIDA BENAVIDES                     ROBERT B. WEISENMILLER, PH.D.
 EXECUTIVE DIRECTOR                 MRW & ASSOCIATES, INC.
 C/O NAATA                          VARIOUS INTERVENORS
 4096 PIEDMONT AVE, 312             1999 HARRISON STREET, SUITE 1440
 OAKLAND, CA 94611                  OAKLAND, CA 94612-3517

 REED V. SCHMIDT                    RICHARD MC CANN
 BARTLE WELLS ASSOCIATES            M.CUBED
 1889 ALCATRAZ AVENUE               2655 PORTAGE BAY, SUITE 3
 BERKELEY, CA 94703                 DAVIS, CA 95616


 SCOTT BLAISING                     TONY WETZEL
 ATTORNEY AT LAW                    THERMO ECOTEK CORPORATION
 BRAUN & ASSOCIATES, P.C.           631 HANCOCK DRIVE
 8980 MOONEY ROAD                   FOLSOM, CA 95630
 ELK GROVE, CA 95624




                             25
Resolution E-3848               DRAFT           October 2, 2003
SCE AL 1726-E/WSM

 ANDREW BROWN                           EDWARD J. TIEDEMANN, ATTORNEY
 ELLISON & SCHNEIDER, LLP               LAW
 2015 H STREET                          KRONICK, MOSKOVITZ, TIEDEMANN
 SACRAMENTO, CA 95814                   GIRARD
                                        PLACER COUNTY WATER AGENCY
                                        400 CAPITOL MALL, 27TH FLOOR
 STEVE PONDER                           DAVID R. BRANCHCOMB
                                        SACRAMENTO, CA 95814
 FPL ENERGY, INC., LLC                  HENWOOD ENERGY SERVICES
 980 NINTH STREET, 16TH FLOOR           INDEPENDENT ENERGY PRODUCERS
 SACRAMENTO, CA 95814                   ASSOCIATION (IEP)
                                        SUITE 300 NORTH
                                        2710 GATEWAY OAKS DRIVE
 DOUGLAS E. DAVIE                       Maria E. Stevens
                                        SACRAMENTO, CA 95833
 PRINCIPAL CONSULTANT                   CALIF PUBLIC UTILITIES COMMISSIO
 HENWOOD ENERGY SERVICES, INC.          EXECUTIVE DIVISION
 2379 GATEWAY OAKS DRIVE, SUITE 100     320 WEST 4TH STREET SUITE 500
 SACRAMENTO, CA 95833                   LOS ANGELES, CA 90013

 Amy C Yip-Kikugawa                     Bruce DeBerry
 CALIF PUBLIC UTILITIES COMMISSION      CALIF PUBLIC UTILITIES COMMISSIO
 LEGAL DIVISION                         DIVISION OF ADMINISTRATIVE LAW
 505 VAN NESS AVENUE ROOM 5135          JUDGES
 SAN FRANCISCO, CA 94102                505 VAN NESS AVENUE ROOM 5043
                                        SAN FRANCISCO, CA 94102
 Darwin Farrar                          Edwin Quan
 CALIF PUBLIC UTILITIES COMMISSION      CALIF PUBLIC UTILITIES COMMISSIO
 LEGAL DIVISION                         CPUC - ENERGY DIVISION
 505 VAN NESS AVENUE ROOM 4107          INFORMATION & MANAGEMENT
 SAN FRANCISCO, CA 94102                SERVICES DIVISION
                                        505 VAN NESS AVENUE ROOM 3016
 Gregory A. Wilson                      Pearlie Sabino
                                        SAN FRANCISCO, CA 94102
 CALIF PUBLIC UTILITIES COMMISSION      CALIF PUBLIC UTILITIES COMMISSIO
 CPUC - ENERGY DIVISION                 OFFICE OF RATEPAYER ADVOCATES
 ELECTRIC INDUSTRY & FINANCE            (ORA)
 505 VAN NESS AVENUE AREA 4-A           ELECTRICITY RESOURCES AND PRIC
 SAN FRANCISCO, CA 94102                BRANCH
                                        505 VAN NESS AVENUE ROOM 4209
                                        SAN FRANCISCO, CA 94102



                                 26
Resolution E-3848           DRAFT           October 2, 2003
SCE AL 1726-E/WSM

 BILL JULIAN                        Wade McCartney
 ATTORNEY AT LAW                    CALIF PUBLIC UTILITIES COMMISSIO
 UTILITIES & COMMERCE               NATURAL GAS, ENERGY EFFICIENCY
 STATE CAPITOL, ROOM 2117           RESOURCE ADVISORY
 SACRAMENTO, CA 95814               770 L STREET, SUITE 1050
                                    SACRAMENTO, CA 95814

 JAMES HOFFSIS
 CALIFORNIA ENERGY COMMISSION
 1516 NINTH STREET MS-45
 SACRAMENTO, CA 95814-5504




                             27
Resolution E-3848   DRAFT   October 2, 2003
SCE AL 1726-E/WSM




                     28

				
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