8-28-00 CCC Response by qihao0824

VIEWS: 1 PAGES: 16

									                                                        [W&C Draft: (Los Angeles) August 28, 2000]


                            BEFORE THE PUBLIC UTILITIES COMMISSION
                                 OF THE STATE OF CALIFORNIA


Order Instituting Rulemaking Into Implementation
of Pub. Util. Code § 390                                          R.99-11-022




                                           RESPONSE OF
                                CALIFORNIA COGENERATION COUNCIL
                       TO PETITION OF SOUTHERN CALIFORNIA EDISON COMPANY
                               FOR MODIFICATION OF DECISION 96-12-028




                                                      Jerry R. Bloom
                                                      Gregory S.G. Klatt
                                                      WHITE & CASE LLP
                                                      633 W. Fifth Street
                                                      Los Angeles, CA 90071
                                                      Telephone: (213) 620-7700
                                                      Facsimile: (213) 687-0758

                                                      Attorneys for CALIFORNIA
                                                      COGENERATION COUNCIL

Dated: August 28, 2000




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                            BEFORE THE PUBLIC UTILITIES COMMISSION
                                 OF THE STATE OF CALIFORNIA


Order Instituting Rulemaking Into Implementation
of Pub. Util. Code § 390                                                      R.99-11-022




                                           RESPONSE OF
                                CALIFORNIA COGENERATION COUNCIL
                       TO PETITION OF SOUTHERN CALIFORNIA EDISON COMPANY
                               FOR MODIFICATION OF DECISION 96-12-028




I.            INTRODUCTION AND BACKGROUND

              Pursuant to Rule 47(f) of the Rules of Practice and Procedure of the California Public

Utilities Commission (the “Commission” or “CPUC”), the California Cogeneration Council

(“CCC”) hereby submits this response in opposition to the petition of Southern California Edison

Company (“SCE”) for modification of Decision (“D.”) 96-12-028 (the “Petition”), filed in

Investigation (“I.”) 89-07-004 on July 28, 2000, and transferred to the above-captioned

proceeding by joint ruling of Administrative Law Judge (“ALJ”) Michelle Cooke and ALJ Janet

A. Econome, dated August 17, 2000. For the reasons set forth below, the Commission should

reject SCE’s Petition.


              D.96-12-028 implements Section 390(b) of the Public Utilities Code. Section 390(b)

provides that, until certain conditions are satisfied, short-run avoided cost (“SRAC”) payments to

qualifying facilities (“QFs”) shall be set using a formula that reflects a starting energy price based

on 12-month averages of pre-January 1, 1996 SRAC prices for each utility (the “Starting Price”),



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increased or decreased monthly based on changes in certain natural gas border prices (the

“Indices”). In D.96-12-028, the Commission followed these precise requirements. Further,

D.96-12-028 included in the formula adopted for each utility a specified constant factor (the

“Factor”), so that the entire Starting Price would not be adjusted to reflect changes in the Indices,

but only that portion of the Starting Price which parties agreed reflected the relationship between

changes in gas border prices and changes in the utility’s avoided cost of energy. The Factor is

the product of a linear regression comparing historical SRAC prices and historical gas border

prices. For SCE, the Factor was set at 0.7067. Re Biennial Resource Plan Update, D.96-12-

028, 69 CPUC 2d 546, 1996 Cal. PUC LEXIS 1089, Attachment 1, at *30 (Dec. 9, 1996).


              In its Petition, SCE contends that due to recent decreases in intrastate gas transportation

rates, the SCE Formula no longer yields results that properly reflect its avoided cost of energy.

SCE Petition at 3-4. Accordingly, SCE proposes to modify the SCE Formula so that it produces

lower SRAC energy payments. Specifically, SCE proposes to make monthly adjustments to the

Factor so as to “offset” the decrease in intrastate transportation rates, notwithstanding that the

Factor has no relationship to the cost of intrastate transportation, which is an integral element of

the Starting Price.


II.           SUMMARY OF CCC’S OPPOSITION TO SCE’S PETITION

              CCC opposes SCE’s proposal for the following reasons:

        *         SCE’s proposal conflicts with the provisions of Section 390(b). The
historical cost of intrastate transportation is an integral element of the Starting Price as defined in
Section 390(b). As Section 390(b) provides, the Starting Price serves as a base value that is
adjusted monthly to reflect changes in certain border gas price indices. As a base value, the
Starting Price is by definition not subject to modification. Knowing this, SCE does not propose
to adjust the Starting Price to reflect lower intrastate transportation rates. Instead, SCE proposes
to do indirectly what it is not permitted to accomplish directly. Specifically, SCE proposes to
adjust the Factor, which has no relationship to intrastate transportation rates, so that the SCE

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Formula will produce lower SRAC prices just as if the Commission was now changing the
Starting Price to reflect decreases in intrastate transportation rates from the historical rates
incorporated into the Starting Price. Since adjusting the Stating Price to reflect lower intrastate
transportation rates would conflict with the provisions of Section 390(b), so would adjusting the
Factor in order to produce the same results.

        *         SCE’s proposal is technically flawed. The Factor has no relationship to
intrastate gas transportation rates or changes in such rates. The Factor is the product of a linear
regression comparing historical SRAC prices and historical gas border prices and is used in the
SCE Formula to temper the impact of changes in gas border prices on SRAC prices. It would be
contrary to mathematical norms to make adjustments to a mathematically derived constant in
order to manipulate a formula so that it produces desired results.

        *         SCE’s proposal is methodologically unsound and fundamentally unfair.
SCE’s proposal to modify the SCE Formula so that it yields lower SRAC prices is based on the
re-examination of only one of the historical SRAC values reflected in the Starting Price. SCE
ignores other elements of the Starting Price that, if re-examined today, would result in the SCE
Formula producing higher SRAC prices. To be clear, CCC is not recommending that the
Commission revisit the SRAC values reflected in the Starting Price; as noted above, doing so
would conflict with Section 390(b), which requires that the Starting Price be based on historical
SRAC values. CCC is simply pointing out that it is methodologically unsound and
fundamentally unfair for SCE to propose that the Commission selectively focus on changes in
one Starting Price input that would, if updated, reduce SRAC payments, while ignoring other
Starting Price inputs that would, if updated, increase SRAC payments.

        *       SCE’s proposal, if adopted, would undermine efforts by the Commission,
the Governor and others to increase the supply of competitively-priced power in
California. In recent months, the Commission, Governor Gray Davis, the Legislature, the
California Independent System Operator (“ISO”), the California Power Exchange (“PX”), and
even SCE have devoted countless hours to enhancing the available supply of competitively-
priced power for California consumers. Despite the fact that payments to QFs under the SCE
Formula are below current PX prices, SCE seeks to decrease the amount of those payments. If
adopted, SCE’s proposal would weaken price signals, thus discouraging QFs from increasing
production in high demand hours.

III.          SCE’S PROPOSAL CONFLICTS WITH THE PROVISIONS OF SECTION
              390(B).

              The gravamen of SCE’s Petition is that it would have the Commission adjust the SCE

Formula to reflect decreases in intrastate transportation rates from the rates in effect when the

SCE Formula was adopted. SCE Petition at 3-4. SCE does not propose, however, to change the

Starting Price, which is the only element of the SCE Formula that directly incorporates intrastate



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transportation rates. Rather, SCE proposes to modify a wholly unrelated component of the SCE

Formula, the aforementioned Factor, to “offset” the decreases in intrastate transportation rates

from the historical rates reflected in the Starting Price. Id. at 19-20.


              SCE does not propose to adjust the Starting Price because it knows that such a proposal

would be unlawful under Section 390(b). Section 390(b) provides that until the Commission has

determined that the PX is functioning properly for purposes of determining SRAC payments and

certain other conditions are satisfied, such payments “shall be based on a formula that reflects a

starting energy price, adjusted monthly to reflect changes in a starting gas index price in relation

to an average of current natural gas border price indices.” Section 390(b) provides further that

the Starting Price shall be based on historical SRAC values: “The starting price shall be based

on 12-month averages of recent, pre-January 1, 1996, short-run avoided cost energy prices paid

by each public utility electrical corporation to nonutility power generators.”


              In describing the SCE Formula, SCE notes that the Starting Price adopted in D.96-12-028

reflects a 1995 burnertip gas price of $2.0578 per MMBtu and a 1995 border gas price of

$1.3975 per MMBtu. SCE fails to explain, however, that the 1995 intrastate transportation rate

of $0.66 per MMBtu is simply the difference between these historical burnertip and border

prices. In other words, the 1995 intrastate transportation rate is an integral element of the

Starting Price adopted in D.96-12-028. Since the Starting Price reflects historical SRAC values

and is intended to serve as the base value that is adjusted to reflect changes in SCE’s variable

costs, it is by definition not subject to change. Thus, revising the Starting Price to reflect a

reduction in recent intrastate transportation rates would be fundamentally inconsistent with the

requirements of Section 390(b) and the methodology adopted in D.96-12-028.


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              In sum, SCE’s proposal is nothing more than an attempt to obtain an unlawful reduction

in the Starting Price mandated by Section 390(b) and adopted by the Commission in D.96-12-

028. SCE’s specific proposal is to adjust the aforementioned Factor on a monthly basis so that

the SCE Formula yields SRAC prices that reflect the recent decrease in intrastate transportation

rates. The monthly adjustments to the Factor are intended to produce the same reduction in

SRAC payments that would result from adjusting the Starting Price to reflect lower intrastate

transportation rates. Because adjusting the Starting Price to reflect a decrease in intrastate

transportation rates would conflict with the provisions of Section 390(b), so would adjusting the

Factor so that the SCE Formula yields SRAC prices that reflect a decrease in intrastate

transportation rates from the historical rate incorporated into the Starting Price. Accordingly,

SCE’s proposal should be rejected.


              SCE makes much of the length of time that has passed since the SCE Formula was first

established, arguing that it is the “unanticipated duration of the transition period” that justifies

modifying the SCE Formula as SCE proposes. SCE Petition at 2, 14. SCE cites the Joint

Comments on SRAC reform filed by SCE, CCC and the Independent Energy Producers

Association to support the proposition that the SCE Formula was intended to be in place for only

a very short time and would be subject to modification if that time elapsed without a transition to

market-based pricing. Id. at 7.




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              In making its arguments, SCE glosses over the fact that the Joint Comments reflect a

settlement that was superseded by Section 390(b) and D.96-12-028.1 Specifically, whereas the

Joint Comments provided that the transition to PX-based pricing would occur after 11 months

unless the Commission or a court finds that the PX is not functioning properly, Section 390(b)

expressly provides that the transition shall not take place until the Commission makes an

affirmative determination that the PX is functioning properly. Similarly, whereas the Joint

Comments provide for any party to the settlement to petition the Commission for modification of

the interim methodology if the transition to PX-based pricing does not take place by the end of

1999, under D.96-12-028 the only element of the SCE Formula that may properly be modified to

reflect changed market conditions is the set of gas border price indices used in calculating

increases in SCE’s avoided variable costs. As the Commission stated:


                       As the market continues to evolve, parties may wish to rely on new
                       published indices. [Footnote omitted.] Parties may file petitions to
                       modify this decision if they wish to change the indices adopted
                       herein.


Re Biennial Resource Plan Update, D.96-12-028, 1996 Cal. PUC LEXIS 1089, at *21-22.


              Thus, D.96-12-028 expressly provides for parties to petition the Commission to modify

the index mechanism that is used to adjust the base value—i.e., the Starting Price—to reflect

changes in gas border prices. It does not provide, however, for the modification of any other

________________________

1
        Ironically, while touting the importance of the Joint Comments to support its position in the
        Petition, SCE, in its opening brief for Phase 1 of this very proceeding, repudiates the
        settlement reflected in the Joint Comments based in part on the fact that the settlement was
        superseded by Section 390(b). See SCE Opening Brief at 20-21.



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element of the SCE Formula. That is consistent with the fact that, under Section 390(b), the

other elements of the SCE Formula are intended to serve as base values and, thus, are by

definition not subject to change.


IV.           SCE’S PROPOSAL IS TECHNICALLY FLAWED IN THAT THE FACTOR HAS
              NO RELATIONSHIP TO CHANGES IN INTRASTATE GAS RATES.

              Manipulation of the SCE Formula as SCE proposes is not only in conflict with the

provisions of Section 390(b), but also is technically flawed. The Factor is the product of the

linear regression of historical gas border prices versus historical SRAC prices. That regression

revealed that the relationship between changes in gas border prices and changes in SCE’s

avoided cost of energy was 0.7067 to 1. The Factor is used in the SCE Formula as a

mathematical constant that tempers the impact of increases in gas border prices on SCE’s

avoided energy costs. In contrast, intrastate transportation rates are an element of the Starting

Price, which serves as a base value in the SCE Formula. Thus, intrastate transportation rates are

related to the Factor only because historical transportation rates are incorporated into the

historical SRAC prices used in the linear regression that produced the Factor. As noted above,

updating those rates now and re-running the linear regression that calculated the Factor would

change not only the Factor, but also the Starting Price, in violation of Section 390(b).


              Conspicuously absent from SCE’s Petition is any argument that the Factor no longer

accurately reflects the relationship between changes in border gas prices and changes in SRAC

prices. Rather, SCE proposes to adjust the Factor for the sole purpose of manipulating the SCE

Formula to yield results that are consistent with the reduction in intrastate transportation rates

from the historical rates reflected in the Staring Price. It would be contrary to mathematical

norms to adjust a mathematical constant (the Factor) to effect changes in an unrelated component

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(the Starting Price) of a mathematical formula (the SCE Formula) so that the formula produces a

desired result (for SCE, lower SRAC prices). Accordingly, SCE’s proposal should be rejected.


V.            SCE’S PROPOSAL IS METHODOLOGICALLY UNSOUND AND
              FUNDAMENTALLY UNFAIR IN THAT IT IGNORES ELEMENTS OF THE
              SCE FORMULA THAT IF RE-EXAMINED TODAY WOULD RESULT IN THE
              SCE FORMULA YIELDING HIGHER SRAC PAYMENTS.

              Even if the law permitted modifying the SCE Formula as SCE proposes, and even if the

Factor had some mathematical relationship to changes in intrastate gas transportation rates, it

would be methodologically unsound and fundamentally unfair to modify the SCE Formula to

reflect one updated data point (i.e., recent decreases in intrastate transportation rates) while

ignoring changes in the other SRAC values reflected in the SCE Formula. As SCE notes in its

description of the SCE Formula, the Starting Price reflects other historical SRAC values in

addition to the 1995 intrastate transportation rate. SCE Petition at 8. Some of those values have

increased over the last four years. If the Commission were to go down the dubious path of

adjusting the SCE Formula to account for lower intrastate transportation rates, intellectual

integrity would require the Commission to re-examine other SRAC values that are incorporated

into the Starting Price and, thus, affect the amount of SRAC payments.


              The IER is a perfect example of an assumed SRAC value that has increased in the four

years since the SCE Formula was adopted. The IER reflects the heat rate of the marginal units

producing power to meet load on the SCE system. The IER is the product of complex production

cost models and, before the Commission established the SCE Formula, its determination was

often the subject of difficult, contentious litigation in SCE’s Energy Cost Adjustment Clause

(“ECAC”) proceedings. For purposes of the SCE Formula, the IER is set at 9,140 Btu per kWh,

the value adopted for SCE in 1995.

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              Since 1995, electric demand in California has grown substantially. At the same time,

there has been relatively little increase in the state’s generation capacity. The recent report of

CPUC President Loretta Lynch and Chairman of the Electricity Oversight Board Michael Kahn

to Governor Gray Davis cites data from the California Energy Commission showing that, from

1996 through 1999, peak demand in the state grew by 5,522 MW, while net generating capacity

additions totaled a mere 672 MW.2 Because the increased demand is being met by essentially

the same stock of plants that existed in 1995, the units that are on the margin today are less

efficient, with higher operating costs and higher heat rates, than the marginal units in 1995. As a

result, the actual IER is certainly much higher than the assumed IER of 9,140 Btu per kWh

incorporated into the Starting Price.


              CCC has confirmed this fact by calculating the IER that is implicit in recent PX prices.

CCC calculated the IER for the SCE system by taking the South-of-Path (“SP”) 15 PX price,

subtracting variable O&M costs ($2 per MWh, as assumed in the SCE Formula), and dividing

the remainder by the delivered cost of gas to electric generators (the Topock border price plus the

applicable intrastate transportation rate).


              Table 1 shows the resulting market IERs, both for the year ending July 2000, and for

calendar year 1999 (a cooler, low-demand year in which there were few concerns over high PX

prices). The market IERs are 30% and 8% higher, respectively, than the IER of 9,140 Btu per

kWh incorporated into the Stating Price.


________________________

2
        L. Lynch, Cal. Pub. Util. Comm’n, California Electricity Options and Challenges Report to
                                                                                           (continued…)

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                                                                 TABLE 1

                                                 Market Heat Rate in the SP15 PX Market

                       Most Recent Year…
                                          SP15              Topock            SoCalGas       Market
                         Month           PX Price          Gas Price          Transport     Heat Rate
                                         $/MWh           $/MMBtu              $/MMBtu       Btu/kWh
                           Aug-99    $       32.80      $      2.58       $        0.44      10,195
                           Sep-99    $        29.28     $         2.93    $         0.45      8,081
                           Oct-99    $        39.88     $         2.71    $         0.44     12,014
                           Nov-99    $        29.64     $         3.08    $         0.45      7,834
                           Dec-99    $        28.19     $         2.36    $         0.44      9,360
                           Jan-00    $        30.05    $         2.38     $         0.44      9,931
                           Feb-00    $        29.93    $         2.55     $         0.45      9,320
                           Mar-00    $        29.02    $         2.59     $         0.45      8,896
                           Apr-00    $        32.80    $         3.02     $         0.45      8,867
                           May-00    $        52.13    $         3.03     $         0.45     14,392
                           Jun-00    $       117.61    $         4.31     $         0.39     24,578
                            Jul-00   $       105.71    $         4.92     $         0.40     19,485
                                                                                 Average:    11,913
                                                                            Increase from     30%
                                                                         9,140 Btu/kWh in
                                                                            SCE Formula:

                       Calendar Year 1999…
                                          SP15              Topock            SoCalGas       Market
                          Year           PX Price          Gas Price          Transport     Heat Rate
                                         $/MWh             $/MMBtu            $/MMBtu       Btu/kWh
                             1999    $        29.27    $         2.32     $         0.44      9,889
                                                                            Increase from      8%
                                                                         9,140 Btu/kWh in
                                                                            SCE Formula:

                       Note: the above market heat rates assume a variable O&M adder of $2 per MWh,
                       Equal to the O&M adder implicit in the SRAC transition formula.




________________________
(…continued)
        Governor Gray Davis, at 36 (Aug. 2, 2000).




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              CCC is not advocating that the Commission expand the scope of SCE’s Petition and re-

examine the IER or any other element of the Starting Price. As discussed above, the Starting

Price as defined in Section 390(b) is not subject to change, and modifying other elements of the

SCE Formula in order to produce the same effect as changing the Starting Price would be in

conflict with the provisions of Section 390(b). CCC’s point is simply that it would be

methodologically unsound and fundamentally unfair for the Commission to modify the SCE

Formula to reflect the impact of lower intrastate transportation rates and not account for changes

in other assumed values that, if recalculated, would result in the SCE Formula producing higher

SRAC prices.


VI.           SCE’S PROPOSAL, IF ADOPTED, WOULD UNDERMINE EFFORTS BY THE
              COMMISSION, THE GOVERNOR AND OTHERS TO INCREASE THE SUPPLY
              OF COMPETITIVELY-PRICED POWER IN CALIFORNIA.

              In addition to being inconsistent with Section 390(b), technically flawed,

methodologically unsound and fundamentally unfair, SCE’s proposal, if adopted, would

undermine the current efforts of this Commission, Governor Davis, the Legislature, the ISO, the

PX and even SCE to enhance the supply of competitively-priced power available to California

consumers. Such efforts include Governor Davis’ June 15, 2000 letter to President Lynch

directing the Commission to investigate the sources of this summer’s electricity crisis, as well as

President Lynch’s recent report to Governor Davis outlining the Commission’s findings and

recommendations. Another example is D.00-08-022, the Commission’s recent order approving

standard, voluntary QF contract amendments for SCE and San Diego Gas & Electric Company

(“SDG&E”) that encourage increased QF output during peak demand periods. According to

SCE, its proposal to modify the SCE Formula, if adopted, would reduce QF payments by

approximately 12%. See SCE Petition at 4. The result would be a weakening of price signals,

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thereby discouraging QFs from increasing production during periods of high demand, precisely

when competitively-priced power is needed most.


              Notwithstanding SCE’s complaints, QF contracts are competitively priced. Indeed, QF

energy is priced at below-market levels during periods of peak demand. According to John

Fielder, Vice President of Regulatory Affairs for SCE, QF contracts represent “. . . the best hedge

[against price volatility] we have.” California Energy Markets, No. 575, Section [15], at 11 (July

14, 2000). This is shown in Attachment 1, which contains a graph comparing SRAC prices and

PX prices from January 1 through August 2 of this year.


              The competitiveness of QF contracts is demonstrated by SDG&E’s recent experience.

On July 6, 2000, in response to dramatic increases in the electric bills of SDG&E customers

resulting from the summer spike in wholesale electricity prices, the Utility Consumers’ Action

Union (“UCAN”) filed an emergency petition to modify D.99-05-051 (the “Emergency

Petition”). In the Emergency Petition, UCAN requested, among other things, that the

Commission impose a temporary rate freeze for SDG&E residential, small commercial and

lighting customers for August, September and October 2000. In opposing the proposed rate

freeze, SDG&E offered its own proposal to extend an immediate credit to all customers that

refunds the overcollection of ongoing transition costs that SDG&E has accrued this year.

SDG&E expected the overcollection balance to have reached $100 million by August 1, 2000.

D.00-08-021, mimeo, at 7. The Commission rejected UCAN’s rate freeze proposal and adopted

SDG&E’s overcollection balance refund proposal. Id.


              According to CCC’s calculation, approximately one-third of SDG&E’s estimated $100

million overcollection balance is attributable to SDG&E’s QF contracts. Under those contracts,

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SDG&E purchases power from the QFs at SRAC prices as determined by application of a

formula similar to the SCE Formula. CCC calculates that by selling that QF power into the PX,

SDG&E has realized a net gain this summer of approximately $30 million. Undoubtedly, SCE is

realizing similar gains from the resale of the power it purchases from QFs at SRAC prices.


              QF power is not only competitively priced, but also provides important reliability

benefits. This is demonstrated by the emergency motion (the “Emergency Motion”) filed by SCE

on July 10, 2000, in which SCE requested approval of a standard, voluntary QF contract

amendment designed to encourage increased QF output during periods of peak demand. As

explained in the Emergency Motion, unless additional QF supplies are brought to market, this

summer’s unfolding energy crisis could worsen, with frequent rolling blackouts and curtailments.

SCE Emergency Motion at 2. In granting the Emergency Motion, the Commission expressly

recognized that the availability of QF power at less than market prices benefits ratepayers. D.00-

08-022, mimeo, at 6.


              Given that QFs represent an important source of competitively-priced power, and given

the reliability benefits that QFs provide, reducing SRAC payments, and thus the value of QF

contracts, would undermine the efforts of this Commission, Governor Davis and others to

increase the supply of competitively-priced power available to California consumers.

Accordingly, SCE’s proposal should be rejected.

///

///

///




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VII.          CONCLUSION.

              For the foregoing reasons, CCC recommends that the Commission reject SCE’s proposal

to modify the SCE Formula.


                                                               Respectfully submitted,




                                                               Jerry R. Bloom
                                                               Gregory S.G. Klatt
                                                               WHITE & CASE LLP
                                                               633 W. Fifth Street
                                                               Los Angeles, CA 90071
                                                               Telephone: (213) 620-7700
                                                               Facsimile: (213) 687-0758

                                                               Attorneys for CALIFORNIA
                                                               COGENERATION COUNCIL

Dated: August 28, 2000




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                                                                Price ($/MWh)




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                              01/01/2000


                              01/15/2000


                              01/29/2000


                              02/12/2000


                              02/26/2000


                              03/11/2000


                              03/25/2000


                              04/08/2000


                              04/22/2000




                       Date
                              05/06/2000


                              05/20/2000
                                                                                                                             SRAC vs. PX
                                                                                                                                                    Attachment 1




                              06/03/2000
                                                                                                                    Electricity Price Comparison:




                              06/17/2000


                              07/01/2000


                              07/15/2000


                              07/29/2000


                              08/12/2000
                                                                    SP15 PX
                                                                              Edison SRAC

								
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