Docstoc

walwyn_PD

Document Sample
walwyn_PD Powered By Docstoc
					                               Administrative Law Judge Rate Schedule Proposal

STATE OF CALIFORNIA                                                                       GRAY DAVIS, Governor

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




        May 9, 2001


        TO: PARTIES OF RECORD IN APPLICATION 00-11-038 ET AL.


        Enclosed are the proposed decision of Administrative Law Judge (ALJ) Christine Walwyn and
        the alternate order of President Loretta Lynch in the rate design phase of this proceeding. These
        items will be on the Commission’s agenda at the May 14, 2001 meeting. The Commission may
        act then, or it may postpone action until later.

        When the Commission acts on the proposed decision or the alternate, it may adopt all or part of
        it as written, amend or modify it, or set it aside and prepare its own decision. Only when the
        Commission acts does the decision become binding on the parties.

        Rule 77.7(f)(9) provides for reduction or waiver of the 30-day period for public review and
        comment when public necessity requires such reduction. We must balance whether the public
        necessity of adopting an order outweighs the public interest in having the full 30-day review
        and comment. We are convinced that these items fall under Rule 77.7(f)(9), and for that reason,
        we established a shortened period for comments on the proposed decision and the alternate.

        Parties to the proceeding may serve comments on the proposed decision and the alternate by
        6:00 p.m. on May 10, 2001 by electronic service, followed by formal filing on May 11, 2001. No
        reply comments will be accepted. Pursuant to Rule 77.3 of the Commission’s Rules of Practice
        and Procedure, opening comments on each document shall not exceed 15 pages. Finally,
        comments on the proposed decision and the alternate must be served separately on the ALJ and
        the assigned Commissioner, and for that purpose I suggest electronic service, hand delivery,
        overnight mail, or other expeditious method of service.



        /s/ LYNN T. CAREW
        Lynn T. Carew, Chief
        Administrative Law Judge


97227
LTC:tcg

Attachments




              2   - -
ALJ/CMW/tcg                      DRAFT                                      1
                                                                         5/14/01

Decision PROPOSED DECISION OF ALJ WALWYN (Mailed 5/9/2001)

 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA


Application of Southern California Edison            Application 00-11-038
Company (E 3338-E) for Authority to Institute a    (Filed November 16, 2000)
Rate Stabilization Plan with a Rate Increase and
End of Rate Freeze Tariffs.


Emergency Application of Pacific Gas and             Application 00-11-056
Electric Company to Adopt a Rate Stabilization     (Filed November 22, 2000)
Plan.                        (U 39 E)


Petition of THE UTILITY REFORM NETWORK               Application 00-10-028
for Modification of Resolution E-3527.              (Filed October 17, 2000)



                  (See Appendix A for List of Appearances.)




97322                                  -   1-
A.00-11-038 et al. ALJ/CMW/tcg                                                                                      DRAFT


                                                     TABLE OF CONTENTS

                    Title                                                                                                  Page

INTERIM OPINION REGARDING RATE DESIGN…………………………….. 2
    I. Summary ................................................................................................................. 2
   II. Background............................................................................................................. 3
  III. Rate Design Principles and Goals ....................................................................... 6
       A. Equity ................................................................................................................. 7
       B. Conservation ..................................................................................................... 9
  IV. Revenue Requirement Increase ......................................................................... 11
   V. Revenue Allocation ............................................................................................. 16
       A. Revenue Allocation Methodology ............................................................... 17
       B. Revenue Requirement Shortfalls ................................................................. 22
          1. Usage Under 130% of Baseline ............................................................... 22
          2. CARE and Medical Baseline Exemption ............................................... 27
          3. Direct Access Customers ......................................................................... 29
       C. Amortization of Rate Increase as of March 27, 2001 ................................. 30
  VI. Preliminary Matters in Rate Design.................................................................. 32
       A. Rate Freeze Constraints ................................................................................. 32
       B. Agricultural Definition .................................................................................. 35
       C. Bill Limiters ..................................................................................................... 36
 VII. Residential Rate Design ...................................................................................... 37
       A. PG&E’s E-8 Schedules ................................................................................... 38
 VIII. Nonresidential Rate Design ............................................................................... 39
       A. Tiering .............................................................................................................. 39
       B. Non-TOU Schedules ...................................................................................... 41
       C. Time of Use ..................................................................................................... 42
       D. “Super Peak” Rate .......................................................................................... 43
       E. County of Los Angeles’ Proposal to Cap Rates for
            Essential Customers .................................................................................... 44
       F. Agricultural ..................................................................................................... 44
       G. Master Meter Customers............................................................................... 45
       H. Streetlight and Traffic Light Schedules....................................................... 46
       I. CIPA’s Credit for Interruptible Customers ................................................ 47




                                                                 -i-
A.00-11-038 et al. ALJ/CMW/tcg                                                                                   DRAFT
                                                   TABLE OF CONTENTS
                                                         (Cont'd)

                  Title                                                                                                 Page

 IX. Other Issues .......................................................................................................... 47
     A. Tracking and Posting Data ........................................................................... 47
     B. Expedited Installation of RTP Metering Systems...................................... 49
     C. 10% Rate Discount Associated with Rate Reduction Bonds.................... 50
     D. Bill Display ...................................................................................................... 52
     E. Bill Insert ......................................................................................................... 53
     F. Customer Education ...................................................................................... 54
  X. Next Steps ............................................................................................................. 56
 XI. Issuance of the Proposed Decision .................................................................... 57
INTERIM ORDER……………………………………………………………………. 73


Appendix A – List of Appearances
Appendix B – Pacific Gas and Electric Proposed Rates
Appendix C – Southern California Edison Proposed Rates




                                                              - ii -
A.00-11-038 et al. ALJ/CMW/tcg                                                    DRAFT


                 INTERIM OPINION REGARDING RATE DESIGN

I. Summary
       This decision adopts a rate design for the three-cent per kilowatt-hour
(kWh) rate increase authorized for Southern California Edison Company
(Edison) and Pacific Gas and Electric Company (PG&E) in Decision
(D.) 01-03-082. That surcharge was adopted on March 27, 2001 to provide the
utilities with additional revenues on a going-forward basis in order for those
utilities to comply with their statutory duty to provide adequate electric service
to their customers. Pursuant to Assembly Bill (AB) 1X, residential use below
130% of baseline is exempt from this increase. In addition, we exempt all
customers who qualify for the California Alternative Rates for Energy (CARE)
and Medical Baseline programs from paying the surcharge.1
       In today’s decision, we address the steps for allocating the rate increase to
customer classes. First, we determine the revenue requirement, which is the
starting point for revenue allocation and rate design. We then allocate the
revenue increase among the customer groups. Finally, we design rates within
the customer groups to collect the revenue requirement. We allocate revenue
and design rates in a manner that is consistent with our overall goals of
conservation and equity.
       The rate design we adopt allows rates to be effective as of June 1, 2001.
One important goal of this rate design is to provide both customers and this
Commission the market information and technical tools (RTP metering systems)

1 We also increased the eligibility criteria for the electric customers participating in the
CARE program from 150% to 175% of the federal poverty guideline. Additional CARE
issues are being addressed in Application (A.) 00-11-009 et al.




                                            -2-
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

to actively respond to the wholesale market costs California Department of
Water Resources (CDWR) could face this summer. We also set in place a
framework that allows us to make midcourse corrections this summer.

II. Background
      While we adopted a rate increase effective on the date D.01-03-082 was
issued, we did not adopt a specific residential tiering approach in the absence of
an overall rate-design proposal and sufficient record evidence to so act.
Conceptually, we agreed that it is time to adopt a tiered approach for those
customer classes that do not have rates structured on a time-of-use (TOU) basis.
This approach sends the proper price and usage signals. Electric bills should be
tiered to promote conservation, i.e., those who use more electricity pay higher
prices for the excess use.
      Residential customers whose usage is below 130% of baseline are now
statutorily exempt from rate increases that were not in effect as of January 5,
2001. The assigned Commissioner issued a concurrent Assigned Commissioner
Ruling (ACR) setting forth an illustrative tiered rate design, inviting comment,
and scheduling a prehearing conference (PHC) to establish dates for briefings
and hearings.2
      On April 2, 2001, the assigned Commissioner and assigned Administrative
Law Judge (ALJ) convened a PHC. The assigned Commissioner stated that the
Commission would pursue an intensive and expedited schedule in order to
adopt and implement by June 1, 2001 a rate design to collect the three cents per

2 San Diego Gas & Electric Company (SDG&E) was included in the illustrative rate
design included in the March 26 ACR and also participated in the PHC. Pursuant to the
ACR issued on April 11, issues related to SDG&E rate increases and rate design are
being addressed in A.00-10-045 et al.




                                        -3-
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

kWh increase approved by the Commission in D.01-03-082. The following day,
April 3, the Commission’s Energy Division held a workshop to finalize rate
design templates and develop a master data request for the utilities. Parties also
discussed a procedural schedule to present the Commission. On April 5, Edison
and PG&E each filed a report on their billing system capabilities, and on April 6,
all interested parties filed comments on the rate design goals the Commission
should pursue, billing system structural issues, and procedural schedule.
      On April 11, 2001, the assigned Commissioner issued a ruling finding that,
after review of the April 6 comments, the Commission needed a more extensive
evidentiary record to design new rates. The April 11 ruling directed parties to
serve their rate design proposals as testimony on April 13, followed by hearings
to commence on April 16. The Energy Division held a workshop on April 12 to
provide parties more information regarding the rate design proposed by
Governor Davis. The parties listed in the accompanying footnote served
testimony on April 13, 20013.



3 On April 13, 2001, the following parties submitted testimony: Aglet Consumer
Alliance (Aglet), Agricultural Energy Consumers Association (AECA), Alliance for
Retail Markets (ARM), California City-County Street Light Association (CAL-SLA),
California Energy Commission (CEC), California Farm Bureau Federation (CFBF),
California Independent Petroleum Association (CIPA), California Industrial Users
(CIU), California Large Energy Consumers Association/California Manufacturers &
Technology Association (CLECA/CMTA), California League of Food Processors
(CLFP), County of Los Angeles (LA County), Energy Producers and Users Coalition
(EPUC), Enron Energy Services, Inc. (Enron), The United States Department of the Navy
and All Other Federal Executive Agencies (FEA), Kinder Morgan Energy Partners (KM),
Leprino Foods Company (Leprino), Office of Ratepayer Advocates, California Public
Utilities Commission (ORA), Pacific Gas and Electric Company (PG&E), Southern
California Edison (SCE), The Utility Reform Network (TURN), Western Manufactured
Housing Communities Association (WMA). These parties are designated active parties
to this proceeding. The Wine Institute (WI) provided comments.




                                        -4-
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

      The Commission held hearings beginning on April 16 and concluding on
April 26. Expert witnesses Peter A. Bradford, George J. Sterzinger, and Severin
Bornstein, also appeared before the Commission at hearing on April 24 and 25 to
offer testimony evaluating how effectively the proposed rate design proposals
meet our rate design.
      The Commission also held Public Participation Hearings (PPHs)
throughout Edison’s and PG&E’s service territories to allow customers to
directly address the Commission. The PPHs were held in the following locations
on the dates and times indicated:


         Monday, May 7:         12 noon       Santa Monica
                                7:00 p.m.     Rosemead

         Tuesday, May 8:        2:00 p.m.     Fresno
                                7:00 p.m.     Visalia

         Wednesday, May 9: 2:00 p.m.          Fullerton
                           7:00 p.m.          San Bernadino

         Thursday, May 10:      12 noon       Sacramento
                                7:00 p.m.     Oakland

         Friday May 11:         3:00 p.m.     San Jose

      Edison and PG&E informed all customers of the locations and times by a
special mailing. At the PPHs, the Commission heard statements from a total of
____ citizens.
      After the conclusion of hearings on April 26, 2001, the parties filed briefs.
The proposed decision was issued for comment on May 9, 2001. The parties filed
and served comments on the proposed decision on May 10, 2001 and presented
Final Oral Argument to the Commission on May 11, 2001.



                                        -5-
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

III. Rate Design Principles and Goals
        In the ACR issued on March 26, the following principles were set forth as a
framework in designing the illustrative rate proposal:
        -   Base-rate differences among customer classes should be adjusted
            to reduce the disparity in prices paid for energy (on a per
            kilowatt hour basis) to ensure fairness in the prices paid for all
            energy purchased for California;
        -   For all customers, electric bills should be tiered to the amount of
            electricity used in order to promote conservation – the more you
            use, the more you pay for that extra electricity above a certain
            threshold of use; and
        -   For commercial customers with time-of-use (TOU) or other
            advanced meters, rates should be tiered to promote the greatest
            amount of conservation possible during summer peak hours.

        After considering interested parties views4 on the rate design goals the
Commission should pursue, President Lynch issued an ACR on April 11 that
provided parties flexibility in constructing their own rate design proposals and
established a hearing process to examine the proposals. As will appear from the
discussion below, the original framework has been extensively modified in
response to the submissions of parties.
        We provided each witness an opportunity to address the rate design goals
of equity and conservation as set forth in the March 26 ACR. In addition, as
explained above, we invited three expert witnesses to offer testimony that
evaluated how effectively each rate design proposals met these goals.




4   At the April 2 PHC and in comments on April 6, 2001.




                                          -6-
A.00-11-038 et al. ALJ/CMW/tcg                                                  DRAFT
        A. Equity
            The goal of equity is essentially one of fairness, viewed in a broad
context. Cost responsibility should be considered but only as one of the
measurement criteria, and only when we have the reliable data to use in our
analysis. In this proceeding, we will consider the unusual nature and large
dollar amount of the surcharge increase, as well. Parties generally agree that we
do not have the cost of service data necessary to consider cost-based equity5 here.
There are two reasons for this. First, we do not have accurate information
concerning the nature and extent of the costs relating to power purchases to date
by CDWR on behalf of the utilities and their customers.6 These purchases are the
primary basis of the three-cent surcharge authorized in D.01-03-082 and being
allocated here. Second, the wholesale power market has been dysfunctional for
approximately a year, such that costs are not the basis of the prices being
charged. As PG&E states, “There is no basis for assuming that peak demands
drive investment decisions in the current wholesale market.”7
            We agree with TURN that we should consider fairness in the broadest
sense, viewing it as a social or policy construct far more than it is a matter of



5  In defining equity as a rate design goal, several parties equated it solely with
economic efficiency, stating customers should pay a rate that is in direct relationship to
the marginal cost of serving them. Edison defines equity as charging various classes of
customers based on the costs of providing service to them. Farm Bureau witness
Illingworth noted her agreement with Edison’s definition, stating revenue allocation
should be based on the future costs to serve the loads of each class. 19 RT 2404.
6 In a May 2, 2001 letter to President Lynch, CDWR provided a revenue requirement
figure but not the details necessary for rate design.
7   PG&E brief at 15.




                                           -7-
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

economics.8 The view that fairness encompasses social and political questions is
shared by Peter Bradford, one of three outside experts invited by the
Commission. Bradford cites to Professor James Bonbright’s rate design
principles, the sixth of which is: fairness of the specific rates and the
apportionment of total costs of service among the existing customers.9 Further,
Bradford states he would consider ability to pay as a measurement criteria in
looking at equity as a rate design goal.
           In recognizing the extraordinary burden we must allocate, we are
convinced of the need to allocate this burden on an equal basis, in a manner that
protects vulnerable customers and ensures no individual customers experience
extreme hardship. The basis on which we allocate this increase should be
understandable to all customers and appear reasonable to most customers.
Following Bonbright’s first principle, our rate design should have the related
practical attributes of simplicity, understandability, public acceptability, and
feasibility of application.
           We are certainly conscious of the economic impact our decision will
have on all sectors of California life – residential, retail and service businesses,
agriculture, public services, and manufacturing and processing firms. We intend
to design rates that provide price signals to which customers can respond, and
thereby reduce the amount of the increase they will see on their bills. We will
ensure that customers receive the public information and energy efficiency tools

8   Florio, TURN, 22 RT 2962.
9 Bradford, Energy Division, 23 RT 3001-2. Bradford states that the eight rate design
principles laid down by James Bonbright, the preeminent utility economist of the mid-
20th century, have held up well over time and should be considered by the Commission
here.




                                           -8-
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

necessary to manage their energy usage in a manner that reduces their overall
bill.
             We are also cognizant of individual customer impact as a principle to
be considered in designing equitable rates. As CIU states, “a second prong of the
equity test is that no customer should receive very harsh impacts relative to
others.”10 ORA addresses this issue through its bill limiter proposal. CIPA
believes that the equity goal will be met through (1) protection of low-income
customers under the CARE customer exemption, (2) the Governor’s proposal
that agricultural rates be capped, and (3) the Legislature’s exemption of
residential usage up to 130% of baseline.
             At this time, we do not intend to pursue the goal of reducing the
disparity in prices paid for energy among customer classes. We do not have
sufficient data to undertake this fundamental structural review now. We intend
to revisit this goal in future proceedings.

         B. Conservation
             Conserving electricity means reducing the amount of electric power
needed to serve customers. This is a fundamental rate design goal of this
proceeding. The record demonstrates that power purchased in the wholesale
market for all hours by CDWR and the Independent System Operator (ISO) to
serve the customers of PG&E and Edison is prohibitively expensive, as we
discuss more fully below.
             The March 26 ACR also cited our goal of promoting the greatest
amount of conservation possible during summer peak hours. The record reflects
that summer peak is the time PG&E and Edison have the largest net short

10   CIU brief at 4.




                                          -9-
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

position and are therefore projecting a need for the most purchases from CDWR
and the ISO to meet anticipated customer needs. We expected to have detailed
information from CDWR, broken out by month and time of day, on the amount
of power it had under contract, the prices it would be paying, and the amount of
power it anticipated buying on the spot market. This information would allow
us to determine the value of conserving energy in specific peak periods.
Unfortunately, we have not yet received that information.
         Several parties testified that they expect CDWR will have to purchase
significant power on the spot market this summer. Our record provides
information showing futures contracts for this summer being quoted at $200-
800/MW. As Dr. Borenstein testified, all energy purchased this summer will be
expensive and power purchased in peak periods will be even more expensive.
         The Governor’s 20/20 program is designed to reward customers who
reduce their overall electric consumption by 20% this summer. This incentive,
combined with customer education, energy efficiency programs, and the price
signal that higher rates will send customers, are effective tools to promote
conservation. A reduction in total energy consumption will help protect
Californians from blackouts and reduce the total financing needed by the state to
purchase electricity.
         To maximize the value of conserving energy at times of peak demand,
we can strengthen the price signal we send customers for periods when demand
is highest. We have some ability to do this now by increasing rates at peak
periods for those customers on time-of-use (TOU) schedules. Without having
CDWR’s specific cost and supply information we are using our institutional
judgement based on our expertise and experience to set the price premium for
peak usage. This is also the basis for our determination that the traditional peak
period of 6-8 hours accurately captures the specific peak time periods we need to

                                       - 10 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

address. Both of these findings may be modified when the CDWR provides us
with more and better information.
          We will address the issue of reliability through promoting our
conservation goals and using interruptible programs that we are addressing in
Rulemaking (R.) 00-10-002. We recognize that certain types of customers place
an extremely high value on reliability and expect that these customers will be
particularly receptive to peak reduction programs.
          The Legislature authorized $35 million in AB 1X 29 for the CEC to
install RTP metering systems on all commercial customers of PG&E and Edison
with connected loads of 200 kW and above. When CEC completes this
installation and the CDWR provides specific projections, the Commission will be
better able to specifically target and provide more effective price signals.
          Consistent with our principles of equity and conservation, we adopt a
revenue allocation and rate design that achieve the following objectives:
(1) reduce the need for procuring power and therefore reduce the amount of
money California is paying wholesale generators for electric power; (2) allocate
the unreasonable costs of this generation in a fair and understandable manner to
all customers, recognizing the adverse economic impact our decision will have
on all sectors of California life; (3) protect the most vulnerable customers; (4)
ensure no individual customers experience extreme hardship; and (5) provide
customers the necessary tools to manage their energy usage and reduce their
energy bills.

IV. Revenue Requirement Increase
      Determining the revenue requirement increase is the first step in allocating
revenue and designing rates. Determining the exact price increase to be
implemented for each nonexempt rate schedule offered by the Edison and PG&E
first requires calculating the incremental revenue each utility must collect. In a

                                        - 11 -
A.00-11-038 et al. ALJ/CMW/tcg                                                   DRAFT

typical rate case, we would determine the per kWh increase for each rate
schedule as the ultimate product of allocating a known increase in costs or
revenue requirement. Here, however, the unprecedented current circumstances
described in our earlier decisions, D.01-01-018 and D.01-03-082, preclude us from
knowing actual cost increases or revenue requirement. We do not know the
costs of wholesale power being purchased to serve electric customers, in part
because the CDWR has not yet established its revenue requirements.
Nevertheless, we must expeditiously determine a revenue requirement and
implement the surcharge.11 The surcharge revenues are subject to refund, as
provided in D.01-03-082, should the anticipated costs not materialize.
       The incremental revenue requirement created by the surcharge authorized
in D.01-03-082 is a function of the sales to which the revenue requirement
increase applies. The sales forecasts used by both Edison and PG&E were
prepared solely by the respective utilities. Due to the extremely compressed
schedule for this proceeding, these forecasts were not thoroughly reviewed by
the other parties, as would be the normal course in a proceeding implementing a
rate case of this magnitude. Due to the lack of review, Aglet requests that we
limit the use of these forecasts to the rate increase at issue in this proceeding. We
agree. In addition to the usual uncertainty present in any forecast, the time
available has not allowed the utilities even to account for known or predictable
future events.12 Consequently, we must acknowledge that these forecasts, while


11 TURN states that the term “incremental revenue amount used for surcharge
allocation” is more illustrative of the actual process involved here.
12 For example, neither PG&E nor SCE modified their respective sales forecasts to
include any reduction in sales as a result of the customers’ conservation efforts, or for
increased numbers of CARE-eligible customers due to the increased income standards

                                                              Footnote continued on next page


                                          - 12 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

the best evidence available, should only be used for the limited purposes of this
proceeding.
      Having concluded above that we will use the sales forecasts provided by
the utilities, we must determine whether the rate design is applicable to both the
1¢/kWh increased authorized in D.01-01-018 and the 3¢/kWh increase
authorized in D.01-03-082. In addition, we must determine whether the sales to
which the surcharge is applied for purposes of determining the incremental
revenue requirement properly include sales exempt from paying the surcharge.
      In D.01-01-018, we authorized PG&E and Edison to impose for 90 days an
Emergency Procurement Surcharge (EPS) of 1¢/kWh for all applicable sales of
electricity. We directed PG&E and Edison to implement the increase as adopted;
that is, add a 1¢/kWh surcharge to all applicable sales. In D.01-03-082, Ordering
Paragraph 6, we made the EPS permanent and, in Ordering Paragraph 1, we
authorized an additional surcharge of 3¢/kWh. For the latter surcharge,
however, we declined to adopt a similar across-the-boards approach and instead
undertook this process to consider rate design proposals tailored to encourage
conservation by allocating more of the surcharge to higher volume users’ “tiered
rates.”
      Some parties have advocated that we include the revenues to be collected
from the EPS in this rate design effort. Specifically, those parties would calculate




adopted in D.01-01-018. While such modifications would typically be included in a
thorough sales forecast, such modifications would greatly exceed the time available and
the scope of this proceeding. We endorse the assigned ALJ’s determination excluding
SCE’s attempt to include a proposal to re-instate the Electric Revenue Adjustment
Mechanism (ERAM) from the record of this case.




                                         - 13 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

the incremental revenue requirement by multiplying forecasted sales by
4¢/kWh, rather than 3¢/kWh.
      Aglet stated that the rate design adopted in this phase should be applied to
the full four-cent increase because considering only the three-cent increase would
tend to obscure the “full impact of the heroic rate increases customers will bear.”
CLECA/CMTA argued that while the Commission did not have the opportunity
to evaluate revenue allocation and rate design for the one-cent surcharge when it
was adopted, the Commission should use this phase for that purpose.
      The Commission adopted the one-cent surcharge on January 4, 2001,
which applies to all sales except to customers eligible for the CARE program. On
February 1, 2001, the California Legislature enacted and the Governor signed
AB1X, which created another exemption. Among other things, AB1X prohibits
increases to rates effective on January 5, 2001, applicable to residential usage
below 130% of baseline usage. Because the Legislature adopted the 130%
exemption after we adopted the 1¢ surcharge, the 130% exemption does not
apply to the one-cent surcharge. Stated another way, usage below 130% is not
exempt from the 1¢ surcharge. Such usage is, however, exempt from the 3¢
surcharge. Thus, the two surcharges are subject to different exemptions. While
there may be some administrative ease in folding the two surcharges into one,
the differing exemptions preclude this seeming simplification. Moreover, in
D.01-03-082, we clearly identified the 3¢/kWh as subject to a new rate design
approach. The EPS is already reflected in the rates that are used as the starting
point for the rate design being considered in this proceeding. Therefore, the
revenue allocation and rate design we discuss here applies to the three-cent
increase.
      Edison calculates the incremental revenue to be recovered by multiplying
3¢/kWh times its total forecasted system-wide sales for 2001 of 83.78 billion

                                        - 14 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

kWh. This results in an annual revenue increase of $2.513 billion. Similarly,
PG&E applies 3¢/kWh increase to all its forecasted sales for 2001. PG&E
determined that its annual incremental revenue requirement is $2.46 billion.
Because we agree that the revenue requirement increase should apply only to the
3¢/kWh adopted in D.01-03-082 and because we agree that we will use the
utilities’ sales forecasts for our determinations in this decision only, these
revenue requirement increases are an accurate estimate of what is required.
      Most parties apply the surcharge amount to all forecasted sales, including
those sales that are exempt from paying it. In this way, the revenue requirement
is determined based on an average of 3¢/kWh, recognizing that some kWh sales
will carry no surcharge and others will carry a substantially higher surcharge.
      Aglet agrees that under usual circumstances exempting certain sales from
cost recovery responsibilities would yield a shortfall that other customers would
have to make up. Aglet contends that in this unusual proceeding there is no
legal or policy requirement to recover revenues that the utility would have
achieved if there were no exempt sales. Because the surcharge is not based on
quantified costs, there is no absolute need to collect that revenue. TURN agrees
that all usage that is exempt from paying the surcharge should similarly be
exempt from determining the revenue requirement. TURN contends that the
first step in a proper methodology for allocating the rate increase to residential
customers is to exclude the protected usage, as determined by the Commission
and the Legislature.
      In adopting the three-cent surcharge in D.01-03-082, we did not specifically
address this issue in the context of calculating a revenue requirement. We
simply applied the rate increase “to all power costs incurred after the effective
date of this decision.” There is no way of knowing actual procurement costs at
this point in time. CDWR has not yet established its revenue requirements for

                                        - 15 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

procuring power. However, we have clearly stated that CDWR is to receive the
full amount the utilities collect from all customers for each kWh of power
provided by CDWR. PG&E and Edison are required to pay CDWR for energy
purchases on behalf of all retail customers, without providing any exemptions
for CARE usage or residential usage below 130% of baseline. It is reasonable to
base the revenue requirement on applying the surcharge to forecast system-wide
sales. Therefore, while we reiterate our commitment to ensuring that the exempt
sales do not pay the surcharge, for purposes of determining the overall revenue
requirement, all sales should be included.

V. Revenue Allocation
      Having determined the revenue requirement amount each utility is
authorized to collect under the 3¢/kWh surcharge, the next step is to establish a
rate structure that will enable Edison and PG&E to collect this revenue from its
customers. The two principal issues concerning revenue allocation are: (1) the
method used to apportion the revenue increase among customer classes; and
(2) the treatment of the shortfall which results from exempting residential usage
up to 130% of baseline consumption from any increase.
      It is equally important to realize what we are not doing. While the
incremental revenue created by the surcharge is material when compared to the
total revenue of the utilities, in this proceeding, the Commission is not setting
aside all previous revenue allocation and rate design. The allocation and rate
design issues addressed in this decision are limited to allocation and design of
the revenues to be collected pursuant to the surcharge. The underlying rate
structure of the utilities will not change. Consequently, in this decision we affect
only a fraction, albeit a significant fraction, of the charges imposed on customers.
For residential customers, by Legislative order, we exempt approximately half of



                                       - 16 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

all sales. The scope of this proceeding does not include a complete revamping of
all charges, just this surcharge.

      A. Revenue Allocation Methodology
          Traditionally, revenue allocation has reflected cost causation. For the
last several years, the Commission has allocated revenue based on the fact that
the costs of providing service vary with the amount and duration of energy
consumption, and with the facilities used to provide service. The Commission
also found that it cost a utility more to deliver a kWh of energy during periods of
peak demand than during non-peak periods. The fundamental facts underlying
such ratemaking have changed. We have a dysfunctional wholesale energy
market that has resulted in unconscionable, unlawful wholesale prices, which
have increased by staggering proportions since the summer of 2000. These prices
bear no relationship to any actual costs incurred in production. In fact,
Califonria has experienced Stage 2 and 3 emergencies and rolling outages during
off-peak times.
          While we acknowledge that the fundamental ratemaking facts have
changed, we underscore the fact that the basic costs of production, other than
fuel, have not changed. Simply put, the outrageously priced wholesale energy
that causes us to take the extraordinary step of imposing this rate surcharge is
being produced at the same plants upon which we based our traditional cost
allocation procedures. In that respect, the fundamental facts of energy
production have not changed. What has changed is that California is beset by
wholesale sellers intent upon maximizing revenue without limit, and federal
regulators refusing to impose any limitations. The price of wholesale energy is
no longer a function of cost of production but rather a function of what price can
be extracted from a market subject to manipulation.



                                       - 17 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

         Further compounding our dilemma is the fact that CDWR has not yet
presented us with cost forecasts for the supply contracts CDWR is negotiating.
Absent this data, we must look to other methodology to allocate the revenue to
be collected from among the customer classes. Parties have proposed several
methods for allocating revenue from the surcharge. We describe these briefly
below.
         Historic Generation Cost Allocation – this methodology allocates the
incremental revenue requirement based on the percent of generation revenues
contributed by each customer group prior to adoption of the 3¢/kWh surcharge.
Prior to making the allocation, the revenues must be adjusted to remove the
effects of the Rate Reduction Bonds transaction and nonfirm service credits to
interruptible customers.
         On Peak Energy Use/Top 100 hours – these two methods allocate costs
based on the customer group’s share of either summer on peak energy use or
100 hours of highest system demand.
         1999 Power Exchange (PX) Generation Charges – this method allocates
revenue requirement by each customer group’s contribution to 1999 PX costs
         Equal cents per kWh – this method divides the revenue among the
customer classes based on the total number of kWhs each class is forecast to
consume during calendar year 2001.
         Our task here is to devise a rational basis for choosing one alternative
revenue allocation methodology over another in a market setting that defies
rationality. The record demonstrates that (1) the traditional rules of cost
causation are no longer reflected in wholesale energy prices, and (2) there is no
reason to believe that any of the suggested alternatives will be better at
predicting cost causation in this market.



                                       - 18 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

          All but one of the suggested alternatives ignore the simple fact that the
price of wholesale energy is completely divorced from cost. The PX prices at
least use recent historical data to attempt to predict what prices will be prevalent
this year. These prices, however, ignore the CDWR purchases, for good reason,
as those prices are not available, as well as the other factors specific to this
summer such as drought conditions in the Northwest which will seriously curtail
the availability of hydro generation.
          Recent price experience, however, suggests that all kWhs will be
valuable. In this volatile and dysfunctional market, we cannot predict which
kWhs will be more valuable than others. For example, California has
experienced blackouts in an off-peak season, at an off-peak time of day. Several
actions could further enhance the value of off-peak energy. Customers currently
on TOU schedules may engage in more aggressive load shifting, such that off-
peak loads increase, decreasing the differential between off-and on-peak. In
addition, it is possible that the drought in the Northwest may give us
opportunities to run California fossil-fuel-fired generation at night and allow us
to sell power to the Northwest. These, and many other possibilities and
unanticipated events, all unpredictable in the volatile energy market, could
impact the value of energy at particular times.
          We recognize that we cannot devise an optimum solution. In choosing
among these proposals, at least two parties referred us to the works of
preeminent ratemaking expert James C. Bonbright. Mr. Bonbright’s teaching
provide us comfort but, unfortunately, little concrete guidance:

          [R]ate structure problems are far more complex than
          problems of a fair return even though the latter are by no
          means elementary; and they are even less amenable to
          solution by reference to definite principles or rules or rate
          making. In part, the complexity is due to the mass of


                                         - 19 -
A.00-11-038 et al. ALJ/CMW/tcg                                                 DRAFT

          technical detail, including the technology of metering,
          involved in the design and administration of workable rate
          schedules for different types of utility enterprises. In part it
          is due to the inability of the rate maker to predict the effect
          of changes in rates on demand for the services and hence on
          costs of supply – due, in short, to ignorance of demand
          functions and cost functions. But in part – and this is the
          most serious theoretical difficulty – it is due to the necessity,
          faced alike by public utility managements and by regulating
          agencies, of taking into account numerous conflicting
          standards for fairness and functional efficiency in the choice
          of rate structure. . . . [B]y way of illustration, we may note
          the conflict between the desirable attribute of simplicity and
          the otherwise desirable attribute of close conformity to the
          principle of service at cost. Here, as with other clashes
          among various desiderata of rate-making policy, the wise
          choice must be that of a wise compromise; and in reaching
          this compromise, the practical rate expert would look in vain
          to any general theory of public utility rates, at least in its
          present stage of development, for a scientific method of
          reaching the optimum solution. Bonbright, James C.,
          Principles of Public Utility Rates, p. 288-9 (1961).

          Allocating the revenue requirement to customer classes based on the
proportion of 2001 forecast total kWh sales to the class drew support from PG&E,
ORA, TURN, and Aglet.13 These parties chose the methodology for equity
considerations and also because the methodology best reflects the surcharge’s
primary purpose: to provide funds for CDWR to purchase electricity in the



13 These parties arrived at this conclusion by eliminating other possibilities. For
example, the data upon which the generation cost allocation methodology is based are
stale and obviously inapplicable to current costs. The peak hours proposals similarly
suffer from a lack of confidence that the past peak/non peak distinctions are valid
forecasts for the future. While closest in time to current markets, the PX price proposal
fails to account for known changes in the market.




                                          - 20 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

wholesale market at a time when those costs are expected to be higher in all
hours of the year as compared to the costs incurred during the same period in
previous years.14 The surcharge is in place to provide the additional funds
necessary to provide for customers’ energy consumption and we have previously
determined that generation costs associated specifically with energy
consumption are properly recovered using an equal cents per kilowatt hour
methodology.15
            There is little cost data available on the wholesale purchase costs that
will be necessary for this summer and the rest of 2001. The dysfunctional
wholesale market has created a unique crisis of unknown duration for California
electric customers. No class of customers believes that it is responsible for these
price increases, and thus no class of customers wants to pay for increased
wholesale electric costs.
            ORA equates the rate surcharge to a tax to pay for a disaster or
emergency – in this case, the electricity crisis. Applying the surcharge as broadly
as possible is the fairest way to apportion the noncost-based price premium
being extracted by wholesale generators and should help our choice of
apportionment gain the widest public acceptance.
            An equal cents per kilowatt-hour is the most equitable revenue
allocation methodology as well as the methodology most appropriate to
apportioning energy purchase costs to all future energy consumption. This
allocation methodology is also simple, understandable, and consistent with our


14Marcus, TURN, 24 RT 3293; Brubaker, FEA, 19 RT 2504; McCann, CIPA/WMA, 22
RT 2873.
15   D.00-06-034, issued June 8, 2000, slip at 66.




                                              - 21 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

approach for the one cent surcharge adopted in D.01-01-018. Therefore, we find
that the revenue requirement associated with the 3¢/kWh surcharge adopted in
D.01-03-082 should be allocated among the customer classes16 based on the
proportional number of kWhs each class is forecast to consume during calendar
year 2001.

      B. Revenue Requirement Shortfalls
         Having completed the allocation of revenue across the customer
classes, we must now address the revenue shortfalls resulting from exemptions
to the surcharge. Because the exempt sales will not be contributing the revenue
requirement assigned to them via the allocation process, this revenue
requirement must be re-allocated to other sales.

         1. Usage Under 130% of Baseline
             In AB X, the Legislature added section 80110 to the Water Code,
effective February 1, 2001:

             In no case shall the commission increase the electricity
             charges in effect on the date that the act that adds this
             section becomes effective for residential customers for
             existing baseline quantities or usage by those customers
             of up to 130 percent of existing baseline quantities, until
             such time as the department has recovered the costs of
             power it has procured for the electrical corporation’s
             retail end use customers as provided in this division.

             This section exempts 130% of “baseline” usage. Baseline usage is
defined in § 739(a). That section requires the Commission to establish a quantity

16SCE’s customer classes are: Residential, Small and Medium Commercial, Large
Power, Agriculture and Plumbing, and Street and Area Lighting. PG&E’s customer
groups are: Residential, Small Light and Power, Medium Light and Power, E-19 and
E-20, Streetlights, Standby, and Agriculture.




                                        - 22 -
A.00-11-038 et al. ALJ/CMW/tcg                                                  DRAFT

of gas and electricity that is necessary to supply a “significant portion of the
reasonable energy needs of the average residential customer.” This “baseline
quantity” is defined to be between 50 and 60% of average residential
consumption, with allowances for seasonal and climatic variations, in § 739(d)(1).
The Commission is further directed to require the utilities to file residential rate
schedules that provide for the baseline quantity to be the first or lowest block in a
increasing block rate structure. In addition, the Commission is directed to
“establish an appropriate gradual difference between the rates for the respective
blocks of usage.” § 739(c)(1). In 1976, the Commission determined the initial
baseline quantities in D.86087, 80 CPUC 182. Subsequent revisions and updates
to the baseline quantities and applicable rates have been done in the utilities’
general rate cases. The currently applicable baseline quantities and rates are set
out in PG&E’s residential tariff schedules and in Section H.3. of the Edison
Preliminary Statement.
              Taken together, new Water Code § 80110 and Pub. Util. Code § 739,
exempt a significant share of each utility’s residential sales. This exemption
protects residential consumers under baseline and protects the class as a whole
by providing a measure of protection to at least some portion of their service.
This statutory exemption raises the issue of how this shortfall should be
recovered and from other customers. The shortfall is significant: In Edison’s
territory, 64% of residential sales are exempt, and 62% are exempt in PG&E’s
territory.
              As ORA states, there are three proposals for allocating this shortfall.
The first option is to recover the shortfall within residential rates. The second is
to reallocate to all eligible sales, and the third is to allocate the increase to all
nonresidential sales.



                                          - 23 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

               TURN proposes that the revenue requirement be re-allocated to all
non-exempt sales. TURN reasons that (1) the plain language of § 80110 is silent
on the issue, and (2) the Legislature knows how to and has prohibited cost
shifting when it so desires. Because cost shifting is not prohibited, the
Commission should re-allocate the revenue requirement to all non-exempt sales.
TURN also offered Exhibit 98 that is an informal analysis from a rate design
expert to Senator Bowen, Chair of the Energy, Utilities, and Communications
Committee. Exhibit 98 evaluates setting the exemption at 125% versus 150% of
baseline, and compares the resulting subsidies of residential customers by
nonresidential customers. Inherent in this analysis is the assumption that the
shortfall would be allocated to nonresidential customers. Based on Exhibit 98,
TURN concludes that the Legislature was well aware of the cost-shifting
implications of this exemption. TURN also notes that such a re-allocation would
be consistent with treatment of the CARE subsidy.
               All other parties17 addressing this issue propose to re-allocate the
revenue requirement to all residential sales that are not included within the
exemption. PG&E states that the Commission’s usual practice is, where cost
re-allocation is required, to keep such costs with the customer class. PG&E
points out that revenue shortfall created by baseline rates is re-allocated solely
within the residential class. Edison adds that the Governor in his rate design
proposal uses this re-allocation methodology.
               Under the re-allocation method supported by most of the parties,
the residential customer group would be allocated significantly more of the
revenue requirement, and see a significantly greater rate increase. Exhibit 111

17   ORA took no position on this issue.




                                           - 24 -
A.00-11-038 et al. ALJ/CMW/tcg            DRAFT




                                 - 25 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

shows the following comparison of the rate increase that would result from the
competing re-allocation methods for two groups of Edison customers:
                                     Non-exempt              All Non-
                                     Residential only        Exempt

         Residential                      22%                  9%
         Large Power                      36%                 43%
         The residential customers would also see significantly greater changes in
prices for higher tier usage. For example, PG&E’s E-1 General Residential rate
schedule would show the following increases under the two alternatives:
                                          Allocated to     Allocated to
                                          Non-Exempt       All Non-
                                          Residential only Exempt

         Tier 1 (0 – 100%)18                        11.419    12.520
         Tier 2 (100 – 130%)                        13.0      14.32
         Tier 3 (130 – 200%)                        19.5      16.66
         Tier 4 (Over 200%)                         28.9      20.30
         One of the criteria for desirable rate structure advocated by Professor
Bonbright is that the rates are stable, with a minimum of “unexpected changes
seriously adverse to existing customers.”21 The price increase that a customer
would see should the customer’s usage move from Tier 2 to Tier 3 spikes

18   Percentage of baseline usage.
19   Exhibit 116 PG&E Rate Design Testimony.

20Exhibit 111 ORA Testimony. ORA’s rates are slightly different from PG&E’s
apparently because PG&E accounted for rate reduction bonds and the 1¢ surcharge and
ORA did not.
21   Bonbright, supra, p. 291.




                                           - 26 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

dramatically under the “only non-exempt residential” methodology, but is more
gradual (although still high) under the other methodology.
      Guided once again by Professor Bonbright’s directive to make wise
choices, we find that re-allocating the revenue requirement associated with sales
that are exempt from paying the surcharge solely to the narrow range of
remaining residential sales is too severe. The cost of this legislatively-mandated
exemption should be broadly assessed across all customer groups. We find that
the revenue requirement shortfall caused by applying the 3¢/kWh surcharge
approved in D.01-03-082 to sales to residential customers below 130% of baseline
shall be re-allocated to all sales other than residential sales below 130% of
baseline. Therefore, we adopt the TURN method of capturing the revenue
shortfall. This method spreads the shortfall to all eligible consumption,
including residential sales greater than 130% of baseline. We treat the shortfall in
the same way we allocate CARE shortfalls, as a subsidy. The amount is spread to
all eligible customer classes on an equal cents per kWh basis.

         2. CARE and Medical Baseline Exemption
             We also find that the revenue requirement shortfall caused by
exempting CARE customers from the 3¢/kWh surcharge approved in
D.01-03-082 shall be re-allocated to all sales other than sales subject to the CARE
program and residential customers with usage of or less than 130% of baseline.
             In D.89-09-044, the Commission implemented modifications to its
Low-Income Rate Assistance (LIRA) program that provided a 15% discount to
low-income customers, and created a LIRA surcharge to recover the amounts
necessary to fund the program. Re Investigation on the Commission’s own
Motion to Comply with Senate Bill 987 and Realign Residential Rates, Including
Baseline Rates, of California Energy Utilities, (1989) 32 CPUC 2d 406, 419. The
decision exempted several customer groups from paying the LIRA surcharge

                                        - 27 -
A.00-11-038 et al. ALJ/CMW/tcg                                                DRAFT

primarily due to contractual obligations of the utility, the potential for double-
paying, or statutory requirements. In addition, the decision exempted
streetlighting:

             Street lighting shall also be exempt because such service
             is ultimately paid for by taxpayers, who will already
             contribute to the LIRA program as ratepayers. 32
             CPUC2d at 416.

             The LIRA program was subsequently renamed CARE in § 739.1.
Cal- SLA relies on this decision, and others, for the proposition that “street light
customers are not to be burdened with revenue allocated from the CARE
discount.” PG&E disagrees, contending that the previous Commission decision
applied to allocating the cost of the discount for low-income service. At issue in
this proceeding, in contrast, is allocating the revenue requirement for an overall
surcharge.
             We agree with PG&E. Whatever may have been the validity of the
1989 justification to exclude street lighting from its fair share of this program,
that justification is not applicable here. This allocation is not a revenue
requirement necessary to fund the low-income discount program, from which
street lighting continues to be exempt, but rather a general surcharge covering
procurement of electricity. It should be allocated as broadly as possible to
achieve our goal of equity.
             The purpose of the medical baseline allowance is to protect those
customers with medical conditions that require the use of electricity to protect
their health and well being. Current Commission-approved tariffs provide
qualifying customers with a medical baseline quantity of approximately




                                        - 28 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

16.5 kWh per day above the standard baseline allowance. Medical baseline
allowances are required by § 739(b)(1).22 We also adopt an exemption of the rate
increase for this customer class. The utilities’ data show that PG&E has
approximately 40,044 customers on a medical baseline allowance and Edison has
12,222, for a total of 52,266. Approximately 35% of these customers are in the
CARE program and would be exempt from these charges. Because of the
extraordinary size of the rate increase, it is reasonable to mitigate the impact to
the remaining customers on medical baseline who are among the most
vulnerable customer classes. This exemption will be allocated using the same
methodology as the CARE exemption. The utilities should reflect the exemption
of medical baseline customers in the tariffs they file pursuant to this order.

         3. Direct Access Customers
             In this decision, we must consider whether direct access customers
should be required to pay any of the rate increase. Direct access customers
should be exempt from the surcharge as direct access customers are purchasing
their own power and are not relying on the utilities. Furthermore, direct access
customers do not contribute to the net short that the CDWR is procuring on
behalf of the utilities. The surcharge adopted in D.01-03-082 is intended to
provide payment for power purchases and delivery to utility customers. Neither
the utilities nor the CDWR procure power for direct access customers. Instead,
by definition, direct access customers receive their energy from their Energy
Service Provider (ESP). It would be inequitable for direct access customers to
pay for both their own cost of procurement and the procurement costs of


22Medical baseline allowances are addressed in PG&E’s Rule 19 and Edison’s
Preliminary Statement Part H.




                                        - 29 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

bundled customers. We do not refer to direct access customers in D.01-03-082
and this surcharge should not apply to direct access customers.

      C. Amortization of Rate Increase as of
         March 27, 2001
          We issued D.01-03-082 on March 27, 2001, and stated that the rate
increase became effective as of that date. That decision also obligates Edison and
PG&E to pay a generation-related rate including the 3¢/kWh surcharge to
CDWR beginning on that date. Today’s decision determines the specific rate
allocation and design of the surcharge and implements it with the effective date
of this order. During the intervening time, March 27 to the date Edison and
PG&E begin applying the surcharge, Edison and PG&E have been subject to the
obligation to pay the funds to CDWR but have not been able to collect the
amounts from their customers. PG&E and Edison therefore seek to recover the
revenue shortfall from this time period over some period in the future. Edison
proposes to recover this shortfall by amortizing it over three months (June until
August). This three-month amortization, would effectively increase the three-
cent surcharge to five cents. PG&E proposes a twelve-month amortization
method, increasing the surcharge to 3.6 cents per kWh over the period.
          Aglet and TURN contend that the rule against retroactive ratemaking
prohibits collection of these amounts, because no balancing or memorandum
account has yet been established to authorize such collection.23 This point is
irrelevant. Section 728 requires the Commission to determine the rate “to be
thereafter observed and in force.” The right to recover the revenues equivalent


23Balancing accounts have been established in D.01-03-082, but only for the purpose of
recording revenues received from the authorized rate increases.




                                         - 30 -
A.00-11-038 et al. ALJ/CMW/tcg                                                  DRAFT

to the three-cent surcharge was established by D.01-03-082 and affected only
electricity delivered from the effective date of that decision forward. Similarly,
the precise charges to be collected from customers to recover those revenues will
be effective prospectively after the date of today’s decision. We see nothing
retroactive here that could possibly violate § 728.
          TURN’s argument assumes, without citation, that creation of a
balancing or memorandum account is the only method whereby the Commission
can allow a utility to collect sums at a later date. This is simply not so. At most,
what § 728 requires is that there be a prospective authorization to recover the
revenues.24 While the Commission often accomplishes this result through
balancing or memorandum accounts, that method is not required by § 728.25
Accordingly, we see no possible violation of any prohibition against retroactive
ratemaking here.



24 We do not address here the question of whether the three-cent surcharge would be
subject to the legal restrictions on retroactive ratemaking. (See Southern California
Edison Co. v. Public Utilities Commission (1978) 20 Cal.3d 813, where the court
discussed the scope of the prohibition.) Rather, we point out that even if the restrictions
of § 728 do apply to this situation, there would not be any violation.

25 In this regard, we stress the importance of the fact that D.01-03-082 made the three-
cent surcharge effective immediately. Sometimes the Commission may authorize the
creation of a balancing or memorandum account in a decision, but make it clear in the
authorizing decision that this account will not become effective until the filing or
approval of the required tariff. In that situation, the Commission’s practice is to allow
recovery only of those costs incurred after the effective date of the balancing or
memorandum account. Here, in contrast, the Commission neither required the creation
of a balancing or memorandum account nor the filing of tariffs in order to make the
three-cent surcharge effective. As noted above, the three-cent surcharge was effective
immediately, although the precise method by which the rates would be spread among
the various customer classes had not yet been established.




                                          - 31 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

         Therefore, we determine that the revenue associated with applying the
3¢/kWh surcharge to all non-exempt energy sales from March 27, 2001, to the
day utilities begin collecting the surcharge should be added to each utility’s
revenue requirement. We will authorize the utilities to amortize the unrecovered
amount over 12 months, as PG&E proposes. TURN agrees that should the
Commission reject its retroactive ratemaking argument, discussed above, then a
12-month amortization period is reasonable. From a standpoint of equity, a
three-month summer amortization would undoubtedly cause undue stress on
summer rates, which will already be very high. The three-month surcharge also
places a severe hardship upon summer intensive industries, especially the
agricultural industry, which did not contribute significantly to the shortfall.

VI. Preliminary Matters in Rate Design
      In developing these methodologies for the rate increase, we have focused
on promoting equity and encouraging conservation. We have designed rates for
Edison and PG&E customers that will meet CDWR’s revenue requirements,
while promoting conservation to keep the cost of CDWR-procured power down.
Despite a number of attempts on the part of the Commission, we were unable to
craft this decision with the benefit of detailed cost estimates from CDWR, and
therefore, in many instances we have resorted to utilizing historical information
to set peak periods. This decision will advance the equity and conservation goals
for this proceeding, but lacks the fine-tuning that could have been possible if
CDWR had supported our ratemaking needs.

      A. Rate Freeze Constraints
         As a preliminary matter, we address the question of whether the
continuing rate freeze precludes us from requiring certain customers who are not
currently on time-of-use schedules to shift to such schedules. Many parties



                                        - 32 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

assume, without much explanation, that such a mandatory shift is barred by the
rate freeze. A few specifically cite to the provisions of Pub. Util. Code §§ 367
and 368. As we explain below, we conclude that the continuation of the rate
freeze does not preclude us from responding to the current energy emergency by
requiring certain customers to shift to time-of-use meters, thereby shifting use
away from periods of peak demand. This approach achieves our goals of
conservation and equity. Such a shift away from periods of peak demand can be
expected to both help avoid blackouts and decrease the total cost of procuring
electricity.
          Section 367 deals with the utilities’ recovery of certain uneconomic or
transition costs. The rate freeze is mentioned in two portions of § 367.
Section 367(a) provides for recovery of such uneconomic/transition costs
“consistent with not increasing rates for any rate schedule, contract, or tariff
option above the levels in effect on June 10, 1996.” Similarly, § 367(e)(2) states
that “[i]ndividual customers shall not experience rate increases as a result of the
allocation of transition costs.”
          Section 368 deals with the utilities’ cost recovery plans for the recovery
of uneconomic costs. More specifically, § 368 sets certain conditions on the
Commission’s approval of transition cost recovery plans. In that regard, § 368(a)
provides that the rate levels required in the cost recovery plan “for each
customer class, rate schedule, contract, or tariff option shall remain in effect until
the earlier of March 31, 2002, or the date on which the commission-authorized
costs for utility generation-related assets and obligations have been fully
recovered.”
          Thus, under § 368, the rate freeze is a required condition of the plan for
recovery of transition costs. Similarly, under § 367, the recovery of transition



                                        - 33 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

costs is not allowed to result in a rate increase. In short, these provisions are
designed to control the recovery of transition costs. We do not view them as a
limitation on our authority to respond to the current energy crisis (which was not
foreseen at the time those sections were enacted) by requiring certain customers
to use TOU meters, thereby shifting load away from periods of peak demand.
(Similarly, in D.01-01-018, we concluded that the rate freeze was not a limitation
on our authority to grant emergency, interim rate relief.)
          We will also require the utilities to establish certain tracking accounts to
further ensure that our requirement that certain customers shift to TOU
schedules does not violate the principle that only the frozen rates are available
for transition cost recovery. More specifically, each utility shall track the actual
billings of all customers who are required to shift to time-of-use schedules by
today’s order. Each utility shall also track what these customers would have
been billed if they had remained on their former schedules. If comparison of
these two figures shows that there has been any net increase in billings as a result
of requiring these customers to shift to time-of-use schedules, we will require
that this net increase in revenues be devoted only to those purposes to which we
have previously dedicated the once-cent and three-cent surcharges. In this way,
if there is a net increase in revenues as a result of shifting these customers to
time-of-use schedules, it will not be available for transition cost recovery.
          In short, nothing in this decision alters Ordering Paragraph 9 of
D.01-03-082, in which we concluded that the rate freeze has not ended for either
PG&E or Edison under AB 1890. Rather, we conclude that, even while the rate
freeze continues under AB 1890, we may require customers to shift to time-of-use
schedules to encourage those customers to shift-load off-peak and thereby
ameliorate the current energy emergency, so long as any resulting increase in
revenues cannot be used to recover transition costs.

                                        - 34 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT
      B. Agricultural Definition
          Several parties, including the California League of Food Processors, the
Farm Bureau, and the Wine Institute, urge us to adopt the recommendation of
§ 740.11 (added by SB 5X) and change the definition of customers eligible to be
served under agricultural tariffs to include agricultural commodity processing
customers. Section 740.11 provides, in relevant part:

          In recognition of the fact that agricultural and water supplier
          customers necessarily have high electricity usage during
          peak summer demand periods, the Legislature strongly
          urges the commission to consider providing the option to all
          agricultural commodity processing customers to be included
          in the definition of customers eligible to be served under
          agricultural tariffs, consistent with its other constitutional
          and statutory objectives, and to the extent it does not result
          in cost shifting to other customer classes.

          We acknowledge the uniqueness of California’s agriculture industry,
and their heavy dependence upon summer on-peak usage. However, we will
not expand the definition of the agricultural class at this time. The potential of
migration for industrial customers tied to the agricultural industry deserves
further exploration.
          We decline to make this change at this time, for the reason that our
record is insufficient to conclude that such a change will not result in cost
shifting. We do not believe the Wine Institute’s recommendation -- that we
adopt this expanded category, along with a requirement that the utilities track
the revenue changes resulting from customers moving to agricultural tariffs, in
order to keep revenue shortfalls within each customer class and to prevent cost
shifting to other classes - would sufficiently satisfy the terms of the statute.
Moreover, making such a change would also require that we craft a definition of
“agricultural commodity food processors.” While we have received some


                                         - 35 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

suggestions on how to do this, we would need to explore further on the record
the ramifications of different alternatives.
         PG&E and Edison maintain that it is not feasible to adopt the proposed
customer migration before summer’s end. Customers who qualify for the rate
migration need to be identified and the difference in usage from other industrial
customers understood. We will further examine this proposal to determine its
feasibility and explicitly specify the type of customer eligible to migrate, and
examine the impact of cost shifting upon other customer groups before adopting
this measure.

      C. Bill Limiters
         ORA proposes using bill limiters to protect energy consumers from
large increases. Some parties have suggested special schedules to protect their
unique industries. In the short term, we prefer bill limiters to address the
concerns of a particular group while the effects of migration are considered.
Customers who currently reside within the industrial rate schedules should be
protected by bill limiters, which can help limit the hardship created by equal
cents per kWh surcharge. We believe that bill limiters are preferable to the
creation of new schedules to reflect the diverse needs of customers. It is not
feasible for Edison and PG&E to change the rate schedules to reflect the special
constraints of each industry before June 1. Therefore, in order to mitigate rate
shocks, we adopt the use of bill limiters of 300% for all rate classes other than
agriculture and 250% for the agricultural class, relative to the class average rate.
These bill limiters will serve as adequate protection from unique circumstances
resulting in extraordinary bill impacts and can serve as a more general aid to all
consumers in the way they mitigate rate increases.
         We acknowledge that implementing bill limiters for all customers may
result in a revenue shortfall. We expect this shortfall to be small since bill

                                        - 36 -
A.00-11-038 et al. ALJ/CMW/tcg                                                 DRAFT

limiters cap bills of "outlying" customers, i.e., those with extremely high bills.
However, the utilities should be able to recover these shortfalls from all
customers, except those we exempt from the rate increase, i.e., CARE, residential
sales below 130% of baseline, and medical baseline customers. In their
compliance advice letters, PG&E and Edison should reflect in rates an allocation
of shortfalls from bill limiters to all customers subject to the rate increase. The
utilities should also establish a balancing account to track the amount by which
these rates over- or undercollect the shortfall due to bill limiters. We will review
the balance in this account in the utilities' next rate design proceeding.

VII. Residential Rate Design
      In the interest of promoting conservation, the March 26 ACR proposed a
tiered rate structure. As we have discussed, our discretion in setting the tiers is
framed by AB1X1, which requires that residential consumption up to 130% of
baseline is not to see a rate increase.
      We adopt a five-tier rate design with incremental block tiers. We use a
methodology similar to the one proposed by Aglet. Tier 1 captures usage up to
the baseline amount and Tier 2 represents usage from 100 percent of baseline to
130 percent of baseline. Tier 3 reflects usage from 130 percent of baseline to
200 percent, tier 4 captures usage from 200 percent of baseline to 300 percent, and
tier 5 captures usage in excess of 300 percent of baseline. Tiers 1 and 2 shall not
see a rate increase. The increase between tier 3 to tier 4 is set at a rate that is
double the increase from tier 2 to tier 3. The Tier 5 rate is set to be sufficient to
cover the residual revenue requirement for the class.
      The components of the rate increase in the tiers 3 through 5 include the
residential class allocation, and the residential class’ share of the shortfalls due to
CARE, medical baseline allowances, and the 130% exemption.



                                          - 37 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

      Increasing block tiers is most equitable from a revenue allocation
standpoint. Prices for the residential customers who are the heaviest users will
be higher than moderate users. This approach is more equitable than increasing
rates for all levels of usage by the same amount. Consumers who use less place
less strain on the grid and are rewarded with a lower rate for their usage. The
tiered rate structure we adopt today is consistent with our goal to encourage
conservation through higher rates above threshold usage.
      CLECA/CMTA expressed concern that the exemption would dilute the
conservation signal, because many customers would not see an increase on their
bill. While we recognize this concern, the exemption AB1X1 is clear.

      A. PG&E’s E-8 Schedules
         The E-8 seasonal schedule for residential consumers was implemented
well before the rate freeze and was locked in when the freeze took effect.
Schedule E-8 energy charges do not adequately represent the costs of serving
schedule E-8 customers as compared to the costs of serving schedule E-1
customers; the rates in E-8 are too low. Because the residential core electric rates
have not been adjusted since 1993, schedule E-1 customers pay higher rates to
subsidize those customers on E-8. Schedule E-8 summer rates are 10 percent
lower than schedule E-1 summer rates and schedule E-8's low winter seasonal
rate is approximately 45 percent less than the schedule E-1 Tier 2 rate. This sends
the wrong price signal to E-8 residential customers with heavy heating loads by
encouraging them to increase their winter peak loads.
         Schedule E-8 fails to meet the Commission’s conservation objectives of
equity and conservation. Conservation is essential during the upcoming months.
Very few customers on E-8 schedules consume less than 130% of baseline during
any month of the year. These large users must be given the appropriate
incentive to conserve and must face the same rates as E-1 customers.

                                       - 38 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

         Therefore, we adopt TURN and PG&E’s proposal to close schedule E-8
to new customers and adopt TURN’s proposal for a two-tiered rate design for
existing customers on schedule E-8.

VIII. Nonresidential Rate Design

      A. Tiering
         Parties generally agreed that nonresidential use should not be tiered.
Nonresidential classes, both commercial and industrial, capture a diverse body
of energy users. We agree that tiering classes heterogeneous in size is inequitable
and does not send the appropriate conservation signal.
         Parties who proposed tiered nonresidential rates, such as TURN and
the Farm Bureau did so to conform to the specifications of the March 26 ACR.
TURN proposes an extremely low first tier, where the majority of usage would
be captured in the second tier. It is essential that all nonresidential consumers,
without regard of size conserve, since all usage contributes to the amount
procured by the CDWR.
         The record provides us with no basis to assume that customers who use
more energy are necessarily inefficient. Tiering would punish larger consumers
to the benefit of smaller consumers within that class, without regard to their
efficiency. As Mr. Sterzinger noted, tiering is not required to provide
conservation incentives. We stress that a conservation signal must be sent to
encourage all customers, regardless of size, to conserve during this summer’s
supply shortage. At this point, we determine that a rate increase of 3 cents
provides the appropriate conservation incentive and discourages biases based
upon the size of a business.
         One alternative to tiering discussed in the hearing is special rates by
SIC classification. Identification by SIC classifications do not solve the problems



                                       - 39 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

associated with tiering because they predict neither energy efficiency nor usage.
Tiering based on SIC classification data available is not likely to be equitable, nor
would it provide a meaningful conservation signal. There is neither appropriate
time nor sufficient information to create specialized rates during this proceeding.
Further, neither utility has the SIC classifications of their consumers and would
require significant billing system changes before implementation. We reject
tiering on the basis of industry codes at this time.
          We intend to further investigate the idea of industry-specific rates. We
are open to further investigate whether more specialized SIC classifications could
help us develop a more equitable rate structure. We direct the utilities to collect
SIC classification data from their customers in an effort to understand whether a
more detailed system of rate design by SIC classification should be available in
future rate design proceedings.
          Another tiering alternative discussed for nonresidential consumers is
creating tiers based upon the customer’s historic usage. This approach seeks to
remove some of the unfairness in nonresidential tiering, but this indexing
ultimately may present several problems. Possible problems arising from tiering
by usage history include potential gaming of meters, punishment for seasonal
variation, and the tiering would be difficult to implement for new or expanding
businesses. In essence, selecting a baseline based upon prior year consumption
punishes companies for expansion, regardless of their level of efficiency. We do
not seek to penalize efficient business growth. The record does not support
tiering by usage history, therefore, we reject it.
          A tiering based upon baseline rates also would reward inefficient users
compared to efficient users. Those most able to conserve are those customers
who have not invested in energy efficient equipment. Those who remain
efficient would see little benefit.

                                         - 40 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

            We reject tiering for TOU customers for the same reasons that we reject
tiering for nonresidential, non-time of use customers. Time-of-use signals are
more precise and encourage conservation at the appropriate times relative to the
signals sent by tiering. Additionally, neither Edison nor PG&E can implement
tiering for TOU customers on their billing systems by June 1.

      B. Non-TOU Schedules
            As discussed above, tiering for non-TOU schedules is rejected. Smaller
amounts of usage are not necessarily more efficient. We agree with parties such
as TURN and PG&E that conservation signals need to be sent to all customers,
not just those customers who would fall into the second tier. We adopt the
methodology proposed by ORA for nonresidential, non-TOU design. For small
and large commercial customers with seasonal designation, 70% of revenue
requirement is allocated to the summer period and 30% to the winter period.
This approach is reasonable and consistent with our goals because it balances the
year-round need for conservation, with a stronger conservation signal during the
peak summer months.
            This methodology reconciles differing proposals. Parties such as
Kinder Morgan suggest spreading the rate increase to summer consumption
only. We reject this proposition because of the need to encourage conservation at
all hours, not just during the summer. As established this past winter, rolling
blackouts can occur in any season, at any hour of the day. We encourage
conservation at all times, and without adequate data from CDWR, we cannot
advocate limiting price signals to one period only.
            There will be no rate caps allotted to this customer class, however, the
we will adopt bill limiters of 300% of class usage, as discussed above. These bill
limiters protect customers who may be disproportionately impacted by the rate
increase.

                                         - 41 -
A.00-11-038 et al. ALJ/CMW/tcg                                            DRAFT

         For larger customers with declining block schedules, such as GS-2 and
PA-2 for Edison, the existing declining block structure shall be corrected to be an
increasing block structure. Eliminating the declining block rate structure
improves conservation incentives to this group of customers and adheres to our
goal to discourage and reward customers for lower amounts of usage.
         We also agree with ORA that large customers should be shifted to TOU
schedules in order to send improved price signals and spur additional
conservation. Pursuant to ABIX 29, RTP metering systems will be installed for
all customers over 200 kW. These meters will enable customers to participate in
RTP pricing programs. If these customers do not chose to use their RTP metering
systems in this manner, the meters can also be used to track usage by TOU
period. Therefore, as customers on non-TOU schedules receive these meters,
they should be immediately switched to the appropriate TOU schedule.

      C. Time of Use
         Parties proposed three primary proposals for time-of-use rate design.
The first, promoted by Edison, ORA and the Street Light Association, proposes
an all hour increase. The second, proposed by EPUC and CIPA, places the bulk
of the increase on summer on peak hours. The third, supported by TURN and
CLECA, spreads the rate increase over all hours, with the largest increase during
summer on-peak hours.
         A simple all-hour rate increase does meet some of our rate design goals,
yet we find that it does not sufficiently promote conservation during the hours of
peak demand when the electric system is most stressed.
         We reject the proposals that put the vast majority of the revenue
requirement burden on summer on-peak consumption. Existing TOU rates are
already heavily weighted to the summer on-peak period. We agree with TURN
that peak conservation is of key importance, but extremely high peak period

                                       - 42 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

prices could be counterproductive. There is a significant risk of endangering
revenue recovery by too much shifting off peak, because many customers will
shift their load to avoid paying the highest rates.
            We adopt the approach proposed by TURN and CLECA. This
approach combines spreads the rate increases over all hours, yet the more of the
increase falls upon summer on-peak usage. The differential between on- and off-
peak usage is increased, but customers within this class will not be exposed to
excessive on-peak prices. In addition, rate limiters shall be in effect to ensure
that that customers shall not suffer undue price shocks.

         D. “Super Peak” Rate
            The California League of Food Processors proposes a three-hour super
on-peak period for the food processing industry. The on-peak price proposed
would be twice as high as the on-peak price for other members of their class
during the traditional six-hour peak. The proposal offers off-peak rates during
the remainder of the peak period.
            We reject this proposal. This structure is designed to allow food
processors to avoid the higher rates. The proposal would not be revenue neutral,
as food processors would simply avoid the super-on-peak prices.26 One of the
main goals of this rate design proceeding is to collect the revenue requirement
and we are not willing to adopt proposals that would jeopardize this objective.




26   Yates, CLFP, Tr. 2435.




                                         - 43 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

      E. County of Los Angeles’ Proposal to Cap
         Rates for Essential Customers
         We reject the County of Los Angeles’ proposal to mitigate the impact
the rate of increase on essential government facilities. The cap proposed would
apply to facilities that have a limited ability to reduce consumption.
         The impact of a rate increase is a concern shared by every customer
group in this proceeding. Other than statutory mandates, we oppose preferential
treatment for any customer class and will not establish a methodology to discern
which group should be awarded special treatment. In the interest of both
conservation and equity, local government agencies will be exposed to the same
price signals as other customer groups.

      F. Agricultural
         Agriculture depends heavily on summer on-peak usage and a limited
ability to load shift. Despite the special needs of this group, every eligible
customer group contributing to the net short must assist in the conservation
efforts of the state. Agricultural customers will be sent appropriate conservation
signals and receive a fair share of the burden of increased rates.
         The Governor’s rate increase proposal, advocated by the Farm Bureau,
proposal limits agricultural increases to 5% for TOU rates and 15% for non-TOU
rates. We agree with the direction provided by the Governor’s proposal, but will
take additional steps to protect this class. We are sensitive to the needs of this
customer class, especially in a drought year. We will cap agricultural rate
increases at 30% for both TOU and non-TOU customers. The shortfall from the
30% cap is to be spread over all eligible customer classes, including streetlights
and residential consumers above 130% of baseline.
         In order to send an improved price signal and promote conservation,
all agricultural customers with demand over 200 kW that are not on a TOU


                                        - 44 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

schedule should be switched when they are provided an interval meter. This is
consistent with our treatment of non-TOU commercial and industrial customers.
          We provide additional protection to agriculture customers by adopting
a bill limiter of 250% on energy charges. Both the cap and the bill limiters will
protect agricultural customers who are disproportionately affected by the rate
increases in this unique year. In taking these actions, we both address the acute
energy problems faced by agriculture customers and their unique risk for
economic hardships from the combination of rate increases and drought and
balance this risk with equity and conservation considerations.

       G. Master Meter Customers
          Master meter customers are required to revise their billing systems to
address the rate increase. While they are engaged in that process, these
customers must also comply with AB1X1, which exempts customers using less
than 130% of baseline from the surcharge, and Pub. Util. Code § 739.5, which
requires master meter customers to charge their park residents approximately
the same rate they would have been charged if they took service directly from
the utility.
          We reject WMA’s proposals to exempt master meter customers from
any surcharge in the near future and to phase in a surcharge over a year. All
eligible customer classes must share the burden of a rate increase. If WMA
receives an exemption or an extension, park owners who quickly fix their billing
systems could receive a windfall, since they would be exempt from the surcharge
but would be charging it to the customers. It is inequitable to allow the master
metered customers to reap the financial benefits of the sub-metering transaction
without bearing the responsibility that comes with that transaction, i.e., the
payment of the CDWR procurement cost.



                                       - 45 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

         We order a surcharge to appear on the master meter customer’s bill,
effective June 1. This approach ensures these customers are not exempted from
bearing some portion of the energy procurement costs covered by the three-cent
surcharge. We also give the master meter customers a strong incentive to take
immediate steps to implement the necessary billing system changes. Over the
longer term, we will continue to encourage movement away from the master
meter system.

      H. Streetlight and Traffic Light Schedules
         We allocate a rate increase to the streetlight and outdoor lighting
schedules on equal cents per kilowatt-hour basis. TURN proposes an alternative
rate tiering method for streetlights, based on the type of lamp rather than the size
of lamp or size of customer. The goal of TURN’s rate design is to encourage the
replacement of the more inefficient lighting technologies. We encourage the
replacement of inefficient lighting technologies; however, we believe the rate
increase itself will prompt cities and counties who employ streetlights to invest
in the more efficient bulbs, and any conservation-minded tariff rate schedules
would be unnecessary.
         We also adopt an equal cents per kilowatt-hour design for traffic
signals. We find tiering for traffic signals, such as the proposal by TURN, adds
more complexity, but little value. We agree that cities and counties using traffic
signals should join the conservation effort and switch to more efficient
technologies. However, the summer initiative energy efficiency program
(adopted in D.00-07-017) already provides communities with significant funding
for investment in Light Emitting Display (LED) technology. In addition, these
technologies were cost-effective, even before any rate increase, and providing a
price break through a tiered rate design to encourage their deployment should
not be necessary.

                                       - 46 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT
      I. CIPA’s Credit for Interruptible Customers
          The California Independent Petroleum Association (CIPA) proposes
that interruptible customers be exempted from a substantial portion of any
surcharge, “as an investment in helping customers reduce their on-peak electrical
demand.” Ex. 86, p. 7. We reject this proposal of a rate surcharge credit.
          Interruptible customers receive lower rates for energy in return for
curtailing (interrupting) usage when called upon to do so to provide grid relief.
The presence of the three-cent system wide surcharge will not change their
interruptible status, or their obligation to comply with the tariff.
          Interruptible customers already receive a substantial pricing incentive
that recognizes their interruptible status. According to § 743.1(b), “In no event
shall the level of the pricing incentive for interruptible or curtailable service be
altered from the levels in effect on June 10, 1996, until March 31, 2002.” CIPA
proposes altering the calculation of the credit for these customers. Such
alterations are currently prohibited by statute. As the calculation of the credit
remains unchanged, an additional rebate or “surcharge discount” will not be
given to each interruptible customer. The same credits will apply: customers
whose credits are calculated by a percentage method will increase by an absolute
amount. Customers with dollar credits will not increase as the same calculations
for credits will apply.

IX. Other Issues

      A. Tracking and Posting Data
          Informing customers of their rate group’s usage pattern with
comparison information from the previous year will provide some assessment of
the success of conservation efforts. In addition, as pricing information becomes
available, such information will enable customers, particularly those on TOU
schedules, to make decisions about when to consume energy. Data collection

                                         - 47 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

this summer is essential both for analysis in future rate proceedings and to raise
consumer awareness about the challenges California faces in the months ahead.
We direct the utilities to post customer load profiles on their website, with
weekly updates. We consider this feedback to customers to be critical to the
success of the conservation efforts underway in this state.
           We therefore direct PG&E and Edison to post dynamic load profile
information for all rate groups for which such information is available on their
websites. Pricing information should also be posted as it becomes available. We
also direct the utilities to post the day-ahead ISO price for electricity daily.
Consumers will take heed at the magnitude of the wholesale market prices, and
it will serve as a tool to understanding generation pricing. Current price data
from the ISO will raise consumer awareness of the unjust and unreasonable
wholesale market costs for electricity.
           Moreover, we direct these utilities, as part of their overall customer
service function, to provide such other information on their websites as may be
useful to customers in controlling their energy usage and bills. We appreciate
their efforts to date to inform and educate their customers, and we know that
they will continue. We also direct our staff to work with the utilities to maximize
the potential for information sharing and customer assistance offered by the
website.
           PG&E and Edison have explained that they can provide such
information. For each rate group, Edison can post on its website the monthly
load pattern and level for this summer and, for comparison purposes, last
summer. In addition, load level and patterns of usage for each customer class
will be available for June, July, and August. Edison will average the daily load
profile by hours over either a week or a month and will present some text
analyzing and explaining the significance of the information in an effort to be

                                          - 48 -
A.00-11-038 et al. ALJ/CMW/tcg                                            DRAFT

helpful to consumers. Edison also promises to display pricing information by
time of use when it becomes available.
         PG&E states that it provides dynamic load profile information with
daily updates of the hourly consumption profiles for the statistically
representative customer served under sixteen separate rate schedules. PG&E
cautions that while a comparison of this year’s load profile with last year’s may
provide some feedback on the success of conservation efforts, it maintains that
this data is not sufficient to determine individual price responses, and that the
comparisons should be controlled for weather related effects.
         ORA generally supports the idea of providing more information to
customers about the market prices for electricity. Better-informed customers will
be more likely to adjust their consumption to avoid high price times, and to
make conservation investments. ORA recommends that the Commission
maintain its own website, rather than relying solely on the utilities. We agree
and intend to use our website for these purposes, as time and resources become
available.

      B. Expedited Installation of RTP Metering
         Systems
         Current metering capabilities place significant limitations on rate
design. Customers that are able to reduce or shift their load in response to
hourly price fluctuations would benefit from a real time pricing model. We find
that real time pricing has tremendous potential for reducing the overall costs of
supplying energy. Such pricing will enable to customers to control their bills by
shifting load to lower cost times. Reducing peak load will lead to more efficient
use of our available generation resources.
         We intend to promptly develop a detailed real time pricing rate
structure to capture these benefits for California consumers. The Legislature has


                                       - 49 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

appropriated funding for real time metering systems. AB29X provides
$35 million dollars for the installation of RTP metering systems for all bundled
service customers with greater than 200 kW in peak load. Timely installation of
the meters authorized by the Legislature is critical to the success of our plan.
Installation of the meters will also assist in implementing our TOU rate design
discussed above.
           Two things need to happen, however, before real time pricing can
become a reality in California – meters and information. The CEC intends to
begin the meter deployment process during this summer and complete it by this
fall. The CEC also states that extending the meters to the next size range, 100 –
200 kW, creates another 22,000 end-users requiring meters, approximately
doubling the population that is being addressed by the AB29X monies. It is
possible for this next set of end-users to have advanced metering systems
installed by early 2002 if additional funds are authorized by the Legislature, if
end-users can be mandated to make self-provision of such meters a condition of
service, or if the Commission decides to authorize utilities expenditures with a
workable cost recovery mechanism.
           We will closely monitor the CEC’s progress, and commit to providing
any necessary assistance to ensure timely installation of the meters. The CEC
maintains that it is working with the utilities and the ISO to meet the price
information requirement. We direct our staff to cooperate and assist in these
efforts.

       C. 10% Rate Discount Associated with Rate
          Reduction Bonds
           Pursuant to § 368(a), PG&E’s and Edison’s residential and certain small
commercial customers currently receive a 10% reduction to their electricity rates.
This rate reduction is financed by rate reduction bonds (RRB) issued pursuant to


                                        - 50 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

§ 840-847, and orders of this Commission. The 10% rate reduction applies
through the end of the transition period established in § 368(a), i.e., through
March 31, 2002, with the repayment obligation extending for another six years.
The Legislature intended that the 10% RRB-financed rate reduction would be
followed by additional rate reductions at the end of the transition period,
yielding a cumulative reduction of 20% by April 1, 2002. § 330(a).
         TURN proposes that the 10% reduction continue despite the expiration
of the RRB-produced financing. TURN reasons that the Legislature’s prohibition
on rate increases in AB1X preclude this Commission from ending the 10% rate
reduction because an end to the 10% reduction would effectively be an
additional rate increase for residential and small commercial customers. Edison
opposes this and PG&E states that this proposal is premature.
         At this time, we will make no determinations as to any ratemaking
ramifications of the expiration of the 10% rate reduction in this decision. We
need not reach the issue of how the expiration of the 10% rate reduction might
interact with the prohibition on residential rate increases for up to 130% baseline
because implementing the end of the 10% reduction will require further
Commission action. At that time, the Commission will be better informed about
the ramifications of TURN’s proposal.
         One related calculation issue, however, does require our determination.
Edison raises the question of whether the 10% reduction should be applied to the
pre-existing rates, i.e., prior to both the 1¢/kWh and 3¢/kWh, or should be
applied after the surcharges are added to rates. Because the bonds that finance
the rate reduction were sized to the pre-existing rates, Edison concludes that the
10% reduction should apply only to the pre-existing rates.
         The amount financed by the bonds did not provide for these
surcharges. Consequently, we are constrained to limiting the 10% reduction to

                                        - 51 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

rates in effect prior to the surcharges. In applying the 10% rate reduction for
residential customers and certain commercial customers, PG&E and Edison shall
apply the rate reduction to rates in effect prior to the surcharges.

        D. Bill Display
           We provide direction with respect to how PG&E and Edison should
format the new rate design on the customer bill. Our intent is to adopt a format
which accurately and effectively conveys to customers our stated fundamental
rate design goal of promoting conservation to reduce the amount of electricity
needed to serve customers. The customer bill format must communicate the
direct correlation between electricity supply, price, usage, and consumption
patterns in order to promote price-responsive behavior. We intend that the bill
format communicate easily understood price signals, and deliver the message
that by managing their electricity usage, customers can assume a significant
measure of control over the impacts of the rate increase and reduce their overall
bill.
           We believe consumers are most likely to respond to these price signals
when the bill provides sufficient detail allowing consumers to clearly identify
and understand the differential pricing structures based on usage levels. In
order to accurately portray the new rate design, whereby customers who use
more electricity pay higher rates, each differential rate category or tier will
identify its respective applicability to usage. On residential customer bills, the
new rates will be incorporated through the five designated tiered usage levels:
Baseline, 101% to 130%, 131% to 200%, 201% to 300% and over 300%. TOU
customer bills will categorize the new rates under off-peak, mid-peak and
on-peak classifications, as applicable. Likewise, commercial non-TOU customer
bills will reflect the rate increase within the appropriate commodity component
or block structure. Any bill reference to total energy charges will include the

                                        - 52 -
A.00-11-038 et al. ALJ/CMW/tcg                                                DRAFT

total cost of all energy consumption during the billing period, not merely
baseline usage or some other minimum level of usage.
          PG&E proposes to characterize the rate increase as a “Baseline
Surcharge.” PG&E indicates that its proposed designation serves two purposes.
First, the presentation makes it clear to customers that the rate increase is an
addition to the frozen rate levels. Second, the Baseline Surcharge is structured to
show how customers must revise usage to reduce the amount of surcharge they
pay.
          We recognize that customers may experience confusion as to why their
electric rates are increasing while the rate freeze and legislated 10% rate
reduction is still in effect. We have no objection to the utilities characterizing the
rate increase as a “energy surcharge” or “Baseline Surcharge,” provided the bill
format complies with our objective to communicate easily understood price
signals. The utilities should also include definition of the surcharge designation
on the bill and a line item showing the total of energy surcharges authorized by
D.01-01-018 and D.01-03-082.

       E. Bill Insert
          The customer bill does not provide sufficient space to accommodate
comprehensive information about the rate increase. Electric customers should
receive information describing the need for the rate increase and the tiered rate
structure adopted by the Commission. The bill insert should inform customers
that if their usage falls completely within Tier 1 and Tier 2, they will not see a
rate increase. Customers should be aware that the rate increase will not apply to
medical baseline, CARE or Direct Access customers. The bill insert should
briefly describe the CARE and medical baseline programs, and provide
information on how to apply. And finally, the bill insert should make customers
aware that their diligent, consistent conservation efforts will reduce the both the

                                        - 53 -
A.00-11-038 et al. ALJ/CMW/tcg                                            DRAFT

impacts of the rate increase and the chance of blackouts due to inadequate
electricity supply. A brief description of the California 20/20 Rebate Program
adopted in Resolution E-3733 on May 3, 2001 should also be included.
         We will direct PG&E and Edison to submit a bill insert to the
Commission’s Public Advisor for review and approval by May 18, 2001. The
utilities may coincide the bill insert we order today with the release of any
planned bill inserts related to implementation of the 20/20 Program and should
include the bill insert information on their internet websites.

      F. Customer Education
         The rate design we adopt here delivers a price increase to electric
customers of PG&E and Edison that is larger than any they have experienced.
We need to provide customers the information and tools they need to be able to
respond to these prices by (1) lowering their energy use through participation in
energy efficiency programs, (2) understanding the savings available through the
Governor’s 20/20 program, (3) ensuring low income families understand the
assistance available to them, and (4) offering commercial and business customers
the opportunity to manage their energy bills through participation in a real time
pricing program.
         On May 3, 2001, the Commission in D.01-05-033 took action to address
issues related to the rapid deployment of additional funding for low-income
assistance programs during the energy crisis. The Commission’s energy
efficiency and conservation programs include low-income assistance programs
for rate assistance under our California Alternate Rates for Energy (CARE)
program, and energy efficiency services under the Low Income Energy Efficiency
(LIEE) program. Funding for these programs was substantially augmented with




                                        - 54 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

the passage of SB1X 5 and AB1X 29, both passed by the Legislature on April 5,
2001 and signed by the Governor on April 11, 200127.
          The Commission also administers a program for customer education
about the changes occurring in the electric industry, and how those changes
would affect them. This program includes the activities of the Electric Education
Trust (EET) utilizing the services of community-based organizations (CBOs), and
the education of small businesses under the auspices of the Commission’s
Consumer Services Division (CSD). A draft decision by Administrative Law
Judge John Wong, mailed April 24, 2001 for consideration at the May 24, 2001
conference, changes the focus of these customer education efforts to adjust for
the energy crisis. Instead of focusing on direct access, these educational efforts
should be broadened to include messages about conserving electricity, eligibility
for the CARE program, and the exemption of certain customer classes from the
recently adopted three-cent per kWh surcharge.
          We can facilitate further customer education by coordinating with other
state agencies who are also involved in energy issues. The Department of
Consumer Affairs is organizing a major marketing campaign to promote energy
conservation titled “Flex Your Power” that will provide customers savings tips
and promote the savings available under the Governor’s 20/20 program.
Further, the California Energy Commission under its AB1X 29 funding for real
time pricing meters should have funds available to address the extensive
customer education that Dr. Borenstein testified will be needed to gain customer
acceptance of real time pricing programs.

27SB1X 5 and AB1X 29, collectively, also appropriate an additional $140 million to the
Department of Community Services and Development (DCSD) to augment its state
low-income energy assistance programs, including weatherization services.




                                         - 55 -
A.00-11-038 et al. ALJ/CMW/tcg                                            DRAFT
X. Next Steps
      As discussed above, we are interested in implementing a real time pricing
(RTP) program as soon as the technical impediments can be resolved. The
technical impediments are (1) any delays the CEC experiences in implementing
its $35 million SB1X 5 authorized program to install interval meters for all
customers of PG&E, Edison, and SDG&E who have a connected load of 200kW
or greater; (2) delays caused by the time necessary for PG&E and Edison to make
the necessary changes to their billing systems; and (3) posting of real time prices
by the ISO for the day ahead or spot market.
      The proposals presented by CEC and Dr. Borenstein at hearings were
general in nature, did not include specific details necessary for implementation,
and were based on the premise that the technical impediments listed above
posed an effective barrier to implementing actual programs by June 1, 2001. The
proposal presented by Enron contained more specific information and addressed
the lack of ISO posted price information by using Dow Jones electricity price
indices as its marginal price signal.
      We will proceed expeditiously to develop and adopt a voluntary RTP that
will be available to customers when their interval meters are installed. We will
direct Energy Division to work closely with PG&E and Edison on their billing
system constraints and the manual billing procedures that can be done for
customers until the system changes are complete.
      Our RTP process will begin with a workshop facilitated by Energy
Division on May 21, 2001 and we anticipate adopting a final program later this
summer.
      We are convinced that a comprehensive review of PG&E’s and Edison’s
rate schedules and rate design should be undertaken when the Commission and
interested parties have sufficient data and the time and resources necessary to


                                        - 56 -
A.00-11-038 et al. ALJ/CMW/tcg                                           DRAFT

thoroughly review the issues. We plan to embark on this process soon so that a
comprehensive, rigorous review of rate design will be undertaken in early 2002.
      We recognize that we may need to quickly make a mid-course correction
this summer and modify the rate design within each customer class to provide
more pronounced peak period price signals, and possibly collect a higher energy
surcharge, if CDWR provides information on its energy purchases that require
this action. If we determine that a mid-course correction is needed, we will
afford notice and provide all parties the opportunity to be heard on an expedited
schedule.

XI. Issuance of the Proposed Decision
      The proposed decision was issued on May 9, 2001. Parties filed and served
comments on the proposed decision on May 10 and appeared for final oral
argument (FOA) before a quorum of the Commission on May 11. Public Utilities
Code Section 311(d) generally requires, in matters that have gone to hearing, a
30-day period between service of an assigned Commissioner’s or ALJ’s proposed
decision and the Commission’s issuance of the decision. However, Section
311(d) provides that that period may be reduced or waived by the Commission
“in an unforeseen emergency or upon the stipulation of all parties to the
proceeding or as otherwise provided by law.”
      Although not expressly stated in Section 311(d), the 30-day period
provides an opportunity for parties to comment on the proposed decision. In
this proceeding, we are considering the rate design to apply to the three-cent
surcharge adopted in D.01-03-082. One of the stated goals of this rate design is to
encourage conservation to help Californians avoid, to the extent possible, rolling
blackouts during the summer months. Given the fact that the Independent




                                       - 57 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

System Operator (ISO) has identified over 30 days28 in which it predicts rolling
blackouts to occur and the State of Emergency called by Governor Davis on
January 17, 2001, we believe that this constitutes an unforeseen emergency for
these purposes. Such blackouts threaten to severely impair public health and
safety. Accordingly, we will reduce the 30-day advance publication period of
Section 311(d) to six days, and will allow parties to file and serve written
comments on May 10, followed by final oral argument on May 11 and
Commission consideration of the decision on May 14.

Findings of Fact
     1. To the extent possible, we will design rates to promote our fundamental
goals of equity and conservation in this proceeding.
     2. The goal of equity is one of fairness, viewed in a broad context and
encompasses both social and political questions.
     3. We do not have the necessary data to consider cost-based equity at this
time, because the wholesale market is dysfunctional and costs are not the basis of
prices being charged. In addition, we do not have accurate information
regarding the nature and extent of costs relating to power purchases to date by
CDWR.
     4. We recognize the economic impact our revenue allocation and rate
design decision will have on all sectors of California. We intend to design rates
that provide price signals to which customers can respond and thereby reduce
the amount of the increase they will see on their bills.


28 See, e.g., CAISO Summer Assessment prepared on March 22, 2001 that identifies
resource deficiencies for June through September ranging from 600 MW to nearly
3,700 MW. This report can be accessed on the ISO’s website: http://www.caiso.com.




                                        - 58 -
A.00-11-038 et al. ALJ/CMW/tcg                                            DRAFT

     5. We do not have sufficient data to pursue reducing the disparity in prices
paid for energy among customer classes, but intend to revisit this goal in future
proceedings.
     6. Conserving electricity means reducing the amount of electric power
needed to serve customers. A reduction in total energy consumption will help
protect Californians from blackouts and reduce the total financing needed by the
state to purchase electricity.
     7. We intend to promote the greatest amount of conservation during
summer peak hours. Summer peak is the time PG&E and Edison have the
largest net short position and are therefore projecting a need for the most
purchases from CDWR and the ISO to meet anticipated customer needs.
     8. Power purchased in the wholesale market all hours by CDWR and the
Independent System Operator (ISO) to serve the customers of PG&E and Edison
is prohibitively expensive. Once CDWR provides us with information, broken
out by month and time of day, on the amount of power it had under contract, the
prices it would be paying, and the amount of power it anticipated buying on the
spot market, we should be able to determine the value of conserving energy in
specific peak periods. However, at this time, the record demonstrates that all
energy purchased this summer will be expensive and power purchased in peak
periods will be even more expensive.
     9. To maximize the value of conserving energy at peak times, we can
strengthen the price signal we send customers for periods when prices are
highest. We have some ability to do this now by increasing rates at peak periods
for those customers on time-of-use (TOU) schedules.
  10. The Governor’s 20/20 program is designed to reward customers who
reduce their overall electric consumption by 20% this summer. This incentive,



                                       - 59 -
A.00-11-038 et al. ALJ/CMW/tcg                                            DRAFT

along with customer education, energy efficiency programs, and the price signal
that higher rates will send customers, are effective tools to promote conservation.
  11. We recognize business customers generally place an extremely high value
on reliability and expect that these customers will be particularly receptive to
peak reduction programs and the interruptible programs adopted in R.00-10-002.
  12. The Legislature authorized $35 million in SB 5X for the CEC to install
interval meters on all commercial customers of PG&E and Edison with connected
loads of 200 MW and above. When CEC completes this installation and the
CDWR provides specific projections, the Commission will be better able to
specifically target and provide more effective price signals.
  13. The incremental revenue requirement created by the surcharge authorized
in D.01-03-082 is a function of the sales to which the revenue requirement
increase applies.
  14. The sales forecasts, while the best evidence available, should only be used
for the limited purposes of calculating the revenue requirement to be applied in
this proceeding.
  15. The Commission adopted the one-cent surcharge on January 4, 2001,
which applies to all sales except to customers eligible for the CARE program.
  16. AB1X prohibits increases to rates, effective as of January 5, 2001, applicable
to residential usage below 130% of baseline usage. Usage below 130% is not
exempt from the one-cent surcharge. Usage below 130% of baseline usage is
exempt from the three-cent surcharge.
  17. The EPS is already reflected in the rates that are used as the starting point
for the rate design being considered in this proceeding.
  18. The revenue allocation and rate design discussed in this decision applies
to the three-cent increase adopted in D.01-03-082.



                                        - 60 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

  19. Edison calculates the incremental revenue to be recovered by multiplying
3¢/kWh times its total forecasted system-wide sales for 2001 of 83.78 billion
kWh. This results in an annual revenue increase of $2.513 billion.
  20. PG&E applies 3¢/kWh increase to all its forecasted sales for 2001, which
results in an annual incremental revenue requirement of $ 2.46 billion.
   21. There is no way of knowing actual procurement costs at this point in
time. CDWR has not yet established its revenue requirements for procuring
power.
   22. We have clearly stated that CDWR is to receive the full amount the
utilities collect from all customers for each kWh of power provided by CDWR.
   23. PG&E and Edison are required to pay CDWR for energy purchases on
behalf of all retail customers, without providing any exemptions for CARE usage
or residential usage below 130% of baseline.
   24. The two principal issues concerning revenue allocation are: (1) the
method used to apportion the revenue increase among customer classes; and (2)
the treatment of the shortfall which results from exempting residential usage up
to 130% of baseline consumption from any increase.
   25. The allocation and rate design issues addressed in this decision are
limited to allocation and design of the revenues to be collected pursuant to the
surcharge. The underlying rate structure of the utilities will not change.
   26. The fundamental facts underlying traditional cost-based revenue
allocation have changed. The dysfunctional wholesale energy market has
resulted in unconscionable, unlawful wholesale prices, which have increased by
staggering proportions since the summer of 2000. These prices bear no
relationship to any actual costs incurred in production. The outrageously priced
wholesale energy that causes us to take the extraordinary step of imposing this
rate surcharge is being produced at the same plants upon which we based our

                                       - 61 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

traditional cost allocation procedures. The price of wholesale energy is no longer
a function of cost of production but rather a function of what price that can be
extracted from a market subject to manipulation.
   27. Absent data from CDWR regarding cost forecasts, we have nothing upon
which we might be able to determine a cost-based revenue requirement, or to do
revenue allocation guided by cost causation.
   28. Recent price experience suggests that all kWhs will be valuable. In this
volatile and dysfunctional market, we cannot predict which kWhs at what
particular time periods will be more valuable than others.
   29. The surcharge is in place to provide the additional funds necessary to
provide for customers’ energy consumption and we have previously determined
that generation costs associated specifically with energy consumption are
properly recovered using an equal cents per kilowatt hour methodology.
   30. Because we have used total forecast sales to this class, and all other
classes, upon which to allocate the revenue requirement associated with the
3¢/kWh surcharge, the share allocated to residential sales that are exempt from
paying the surcharge must be re-allocated to other sales.
   31. Re-allocating the revenue requirement associated with sales that are
exempt from paying the surcharge solely to the narrow range of remaining
residential sales is too severe. The cost of this legislatively-mandated exemption
should be broadly assessed across all customer groups.
   32. The revenue requirement caused by exempting CARE customers should
be allocated to all other customer classes, including streetlighting.
   33. Funding for the CARE program is not at issue in allocating the CARE
surcharge shortfall.
   34. Because of the extraordinary size of the rate increase, it is reasonable to
exempt customers who have usage above 130% of baseline due to medical

                                        - 62 -
A.00-11-038 et al. ALJ/CMW/tcg                                              DRAFT

conditions. The protection we afford these vulnerable customers has a similar
equitable basis to our CARE customer exemption.
   35. Direct access customers do not contribute to the net short that the CDWR
is procuring on behalf of PG&E’s and Edison’s customers.
   36. It would be inequitable for direct access customers to pay for both their
own cost of procurement and the procurement costs of bundled customers.
   37. The right to recover the revenues equivalent to the three-cent surcharge
was established by D.01-03-082 and affected only electricity delivered from the
effective date of that decision forward.
   38. A 12-month amortization period for the collection of the revenue
associated with applying the three-cent surcharge to all sales from March 27,
2001 to the day utilities begin collecting the surcharge it will have less of an
impact on already high rates than a shorter amortization period, and it will not
disadvantage summer intensive industries such as agriculture.
   39. Shifting customers to time-of-use metered schedules helps us achieve our
goal of conservation as it shifts use away from periods of peak demand.
   40. We can ensure that customers shifted to TOU schedules do not contribute
any additional revenue toward transition cost recovery by requiring the utilities
to establish tracking accounts for these customers and if there is any net increase
in billings as a result of requiring these customers to shift to TOU schedules,
applying these increased revenues only to those purposes to which we have
previously dedicated the one-cent and three-cent surcharges.
   41. We do not have sufficient information to craft a definition of “agricultural
commodity food processors” or to determine that no cost shifting to other classes
would occur if these customers were allowed to migrate to the agricultural
tariffs, as provided under Pub. Util. Code § 740.11.



                                        - 63 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

   42. Bill limiters are an effective short-term means to address the concerns of
unique industry groups requesting to migrate to special schedules and to
mitigate rate shock on individual customers.
   43. We expect the revenue shortfall from implementing bill limiters to be
small and it is addressable by the utilities reflecting in their compliance advice
letters an allocation of the expected shortfall and then establishing balancing
accounts to track the over- or undercollection.
   44. Increasing block tiers is most equitable form of revenue allocation because
prices for the residential customers who are the heaviest users will be higher
than moderate users, which is consistent with our goal to encourage
conservation through higher rates above threshold usage.
   45. It is reasonable to adopt a 5 tier-rate design with incremental block tiers
with the following tiers:
             a. Tier 1           Up to the baseline amount
             b. Tier 2           From 100 – 130% of baseline
             c. Tier 3           From 130 – 200% of baseline
             d. Tier 4           From 200 – 300% of baseline
             e. Tier 5           In excess of 300% of baseline
   46. The components of the rate increase in the tiers 3 through 5 include the
residential class allocation, and the residential class’ share of the shortfalls due to
CARE, medical baseline allowances, and the 130% exemption.
   47. Schedule E-8 energy charges do not adequately represent the costs of
serving schedule E-8 customers as compared to the costs of serving schedule E-1
customers.
  48. Because the residential core electric rates have not been adjusted since
1993, schedule E-1 customers pay higher rates to subsidize schedule those
customers on the E-8 tariff. This sends the wrong price signal to residential


                                         - 64 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

customers with heavy heating loads by encouraging them to increase their
winter peak loads.
  49. Schedule E-8 fails to meet the Commission’s conservation objectives of
equity and conservation.
  50. We would prefer to eliminate Schedule E-8; however, we must provide
sufficient notice to customers, pursuant to § 729.5. It is reasonable, for now, to
adopt TURN’s proposal to close this schedule to new customers.
  51. Tiering rate classes comprised of customers with substantially dissimilar
usage volumes is inequitable and inconsistent with our conservation goal.
  52. All nonresidential consumers, without regard of usage volume, must
conserve, since all usage contributes to the amount that must be purchased by
the CDWR.
  53. The record does not support the finding that customers with greater usage
volume are necessarily inefficient.
  54. Tiering the nonresidential class would impose disproportionate impacts
on larger volume usage consumers without regard to their efficiency.
  55. A uniformly applied rate increase of 3¢/kWh to the nonresidential class
provides the appropriate conservation incentive and discourages unfounded
biases based upon usage volume.
  56. Rates based on SIC classification do not predict energy efficiency or usage,
and neither PG&E nor Edison has the SIC classifications of their consumers.
  57. PG&E and Edison should collect SIC classification data from their
customers in an effort to understand whether a more detailed system of rate
design by SIC classification should be available in future rate design
proceedings.




                                        - 65 -
A.00-11-038 et al. ALJ/CMW/tcg                                          DRAFT

  58. Tiering nonresidential rates by the customer’s historic usage could lead to
gaming of meters, result in punishment for seasonal variation, and such tiering
would be difficult to implement for new or expanding businesses.
  59. Tiering nonresidential rate schedules by baseline usage would reward
inefficient users.
  60. Tiering TOU rate schedules should be rejected because time-of-use signals
are more precise and encourage conservation at the appropriate times relative to
the signals sent by tiering, and neither Edison nor PG&E can implement tiered
TOU rates by June 1.
  61. ORA’s proposal for nonresidential, non-TOU rate design for small and
large commercial customers is reasonable and consistent with our goals because
it balances the year-round need for conservation, with a stronger conservation
signal during the peak summer months. 70% of revenue requirement will be
allocated to the summer period and 30% to the winter period.
  62. We encourage conservation at all time periods. Without adequate date
from CDWR showing which period is more valuable than another, we cannot
support limiting price signals to one period only.
  63. No rate caps should be allotted to the non-TOU nonresidential customer
class, other than the bill limiters of 300% of class usage.
  64. Customers with declining block schedules, such as GS-2 and PA-2 for
Edison, should be corrected to be an increasing block structure to improve
conservation incentives.
  65. A simple all-hour rate increase does not sufficiently promote conservation
during the hours of peak demand.
  66. Placing the vast majority of the revenue requirement burden on summer
on-peak consumption may result in too much shifting off-peak.



                                         - 66 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

  67. The revenue requirement should be spread over all hours, but more of the
increase should fall on summer on-peak usage. Although the differential
between on- and off-peak usage is increased, on-peak prices are not excessive.
  68. We reject the proposed 3-hour super on-peak period for the food
processing industry because it would not be revenue neutral.
  69. We reject the County of Los Angeles’ proposal to limit the impact the rate
of increase on essential government facilities because we oppose preferential
treatment for any customer class.
  70. Agricultural customers depend heavily on summer on-peak usage and
have a limited ability to load shift.
  71. Agricultural customers are disproportionately affected by the rate
increases in this year due to the unique combination of the energy emergency
and drought.
  72. To mitigate the effects of the rate increase on agricultural customers, it is
reasonable to cap agricultural rate increases at 30% for both time-of-use and non-
time-of-use customers, with the resulting revenue shortfall to be spread over all
eligible customer classes, including streetlights and residential consumers above
130% of baseline.
  73. A bill limiter of 250% on energy charges for agricultural customers will
assist individual customers within this class in managing their bills.
  74. Master meter customers should revise their billing systems to incorporate
this surcharge, and to comply with Water Code § 80110 and Pub. Util. Code
§ 739.5, by June 1, 2001.
  75. It is inequitable to allow the master metered customers to reap the
financial benefits of the sub-metering transaction without bearing the
responsibility that comes with that transaction, i.e., the payment of the surcharge.



                                        - 67 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

  76. The surcharge revenue requirement is allocated to the streetlight, outdoor
lighting schedules, and traffic signal schedules on equal cents per kilowatt-hour
basis.
  77. It is not necessary at this time to adopt TURN’s tiering method for
streetlights (based on the type of lamp rather than the size of lamp or size of
customer) because the rate increase itself will prompt cities and counties who
employ streetlights to invest in the more efficient bulbs.
  78. Interruptible customers should not be exempted from the surcharge, as
CIPA proposes. Interruptible customers already receive a substantial pricing
incentive, which cannot be altered until March 31, 2002, pursuant to § 743.1(b).
  79. Customers must receive as much information as possible about their usage
pattern and pricing information in order to make intelligent decisions about
energy consumption.
  80. Data collection this summer is essential both for analysis in future rate
proceedings and to raise consumer awareness about the challenges California
faces in the months ahead.
  81. Commission staff will work with the utilities to maximize the potential for
information sharing and customer assistance offered by the website.
  82. Real time pricing has tremendous potential for reducing the overall costs
of supplying energy because such pricing will enable to customers to control
their bills by shifting load to lower cost times, and will also reduce peak load.
  83. Real time pricing meters are critical to implementing real time pricing.
  84. The Legislature has appropriated $35 million dollars for the installation of
real time pricing metering systems for all bundled service customers with greater
than 200 kW in peak load by a program administered by the CEC.




                                        - 68 -
A.00-11-038 et al. ALJ/CMW/tcg                                            DRAFT

  85. We will closely monitor the CEC’s progress in installing the meters, and
commit to providing any necessary assistance to ensure timely installation of the
meters. Our staff will cooperate and assist the CEC in these efforts.
  86. We will limit the 10% RRB-financed reduction to rates in effect prior to
implementation of the 1¢/kWh and 3¢/kWh surcharges.
  87. The customer bill format must communicate the direct correlation between
electricity supply, price, usage, and consumption patterns in order to promote
price-responsive behavior.
  88. Customers need to be informed about the rate increase and how they will
be impacted.
  89. Consumers are most likely to respond to price signals when the bill
provides sufficient detail allowing consumers to clearly identify and understand
the differential pricing structures.
  90. The customer bill does not provide sufficient space to accommodate
comprehensive information about the rate increase. Electric customers should
receive information describing the need for the rate increase and the tiered rate
structure adopted by the Commission.
  91. We will proceed expeditiously to develop and adopt a voluntary RTP that
will be available to customers when their interval meters are installed, and we
direct Energy Division to work closely with PG&E and Edison on their billing
system constraints and the manual billing procedures that can be done for
customers until the system changes are complete.
  92. Energy Division will facilitate a workshop on May 21, 2001 on real time
pricing issues, and we anticipate adopting a final program later this summer. It
is reasonable that this workshop be used to develop a master data request and
format for data collection. We intend that the data request be finalized and
issued no later than June 8 and to refine our approach to rate design in early July.

                                       - 69 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

  93. We intend to comprehensively and rigorously review of PG&E’s and
Edison’s rate schedules and rate design in early 2002.
  94. The proposed decision was issued on May 9, 2001. Parties filed and served
comments on the proposed decision on May 10 and appeared for final oral
argument before a quorum of the Commission on May 11.
  95. Although not expressly stated in Section 311(d), the 30-day period
provides an opportunity for parties to comment on the proposed decision.
  96. One of the stated goals of the rate design options considered in this
decision is to encourage conservation to help Californians avoid, to the extent
possible, rolling blackouts during the summer months.
  97. The ISO has predicted more than 30 days of rolling blackouts of electricity
supply over the upcoming summer.
  98. Electricity supply blackouts can severely impair public health and safety.
  99. On January 17, 2001, Governor Davis declared a State of Emergency due to
the energy shortage in California.

Conclusions of Law
    Water Code § 80110 exempts all residential usage below 130% of baseline
from any increase in electricity charges after February 1, 2001.
    It is reasonable to allocate this extraordinary surcharge on an equal cents per
kWh basis, in a manner that protects vulnerable customers and ensures no
individual customers experience extreme hardship.
    It is reasonable to adopt a revenue allocation and rate design that achieve
the following objectives: (1) reduce the need for procuring power and therefore
reduce the amount of money California is paying wholesale generators for
electric power; (2) allocate the unreasonable costs of this generation in a fair and
understandable manner to all customers, recognizing the adverse economic
impact our decision will have on all sectors of California life; (3) protect the most

                                        - 70 -
A.00-11-038 et al. ALJ/CMW/tcg                                                DRAFT

vulnerable customers; (4) ensure no individual customers experience extreme
hardship; and (5) provide customers the necessary tools to manage their energy
usage and reduce their energy bills.
     An equal cents per kilowatt-hour is the most equitable revenue allocation
methodology as well as the methodology most appropriate to apportioning
energy purchase costs to all future energy consumption. This allocation
methodology is also simple, understandable, and consistent with our approach
for the one cent surcharge adopted in D.01-01-018.
     Because we agree that the revenue requirement increase should apply only
to the 3¢/kWh adopted in D.01-03-082 and because we agree that we will use the
utilities’ sales forecasts for our determinations in this decision only, these
revenue requirement increases are reasonable.
     It is reasonable to base the revenue requirement on applying the surcharge
to forecast system-wide sales.
     It is reasonable that the revenue requirement shortfall caused by applying
the 3¢/kWh surcharge approved in D.01-03-082 to sales to residential customers
below 130% of baseline should be re-allocated to all sales other than residential
sales below 130% of baseline.
     It is reasonable to allocate the revenue requirement shortfall from exempting
CARE customers to all other customer classes, including streetlighting. This
allocation is not a revenue requirement necessary to fund the low-income
discount program, from which street lighting continues to be exempt, but rather
a general surcharge covering procurement of electricity. It should be allocated as
broadly as possible to achieve our goals of equity and conservation.
     We should exempt from the surcharge all customers who have usage above
130% due to medical conditions. The utilities should reflect the exemption of
medical baseline customers in the tariffs they file pursuant to this order.

                                        - 71 -
A.00-11-038 et al. ALJ/CMW/tcg                                               DRAFT

   We should allocate the revenue shortfall from this exemption in the same
manner as we allocate the CARE shortfall.
   The revenue associated with applying the three-cent/kWh surcharge to all
non-exempt energy sales from March 27, 2001 to the day utilities begin collecting
the surcharge should be added to each utility’s revenue requirement and
amortized over a 12-month period.
   The surcharge adopted in D.01-03-082 should not apply to direct access
customers because they are not relying on CDWR or the utilities to obtain their
power.
   We should require certain customers to shift to TOU schedules in order to
better address the current energy emergency.
   Requiring customers to shift to TOU schedules is not precluded by the
continuing rate freeze because no additional revenues will be applied toward
transition cost recovery.
   Our record is insufficient to conclude that there will be no cost shifting if we
expand the definition of the agricultural class to include agricultural commodity
processing customers. Therefore, pursuant to Pub. Util. Code § 740.11, we do not
expand the definition of the agricultural class.
   It is reasonable to adopt the use of bill limiters of 300% for all rate classes
other than agriculture and 250% for the agricultural class, relative to the class
average rate. A lower limiter for the agricultural class is reasonable due to the
higher than normal water pumping requirements forecast for this summer.
   CIPA’s proposed alteration of the interruptible customer credit calculation is
prohibited by § 743.1(b) because it would alter the level of the pricing incentive
for interruptible or curtailable service be altered from the levels in effect on
June 10, 1996 prior to March 31, 2002.



                                         - 72 -
A.00-11-038 et al. ALJ/CMW/tcg                                           DRAFT

   Pursuant to § 368(a), PG&E’s and Edison’s residential and certain small
commercial customers currently receive a 10% reduction to their electricity rates,
financed by rate reduction bonds issued pursuant to § 840-847, and orders of this
Commission. The 10% rate reduction applies through the end of the transition
period established in § 368(a), i.e., through March 31, 2002.
   We need not and should not determine any ratemaking ramifications of the
expiration of the 10% RRB-financed rate reduction in this decision.
   Section 311(d) generally requires, in matters that have gone to hearing, a
30-day period between service of an assigned Commissioner’s or ALJ’s proposed
decision and the Commission’s issuance of the decision. That section also
provides that that period may be reduced or waived by the Commission “in an
unforeseen emergency or upon the stipulation of all parties to the proceeding or
as otherwise provided by law.”
   Based on the fact that the ISO has identified over 30 days in which it predicts
rolling blackouts to occur and the State of Emergency called by Governor Davis
on January 17, 2001, we conclude that an unforeseen emergency as provided in §
311(d) exists for purposes of adopting this decision.
   Consistent with the conclusion that an unforeseen emergency exists, we have
the authority to reduce the 30-day advance publication period of § 311(d) to five
days, and to allow parties to file and serve written comments on May 10,
followed by final oral argument on May 11 and Commission consideration of the
decision on May 14.
   This order should be effective today in order to allow the adopted rate design
to be implemented expeditiously.


                                 INTERIM ORDER



                                       - 73 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

      IT IS ORDERED that:
   1. Within seven days of the effective date of this decision, Pacific Gas and
Electric Company (PG&E) and Southern California Edison Company (Edison)
shall file compliance advice letters with complete tariffs to implement the rate
design changes adopted herein. PG&E’s advice letter shall become effective on
June 1, 2001 subject to Energy Division determining that it is compliant with this
Order. Edison’s advice letter shall become effective on June 3, 2001 subject to
Energy Division determining that it is compliant with this Order. PG&E and
Edison shall include with their advice letters detailed and complete workpapers
showing the revenue allocation and rate design calculations underlying the new
rates for each rate schedule. On the same day that they file their advice letters,
PG&E and Edison shall serve electronic copies of the workpapers on Energy
Division and all active parties in this phase of the proceeding. Specifically,
PG&E and Edison shall comply with the following:
      a) The revenue allocation and rate design applies to the
         3 cents/kilowatt-hour (kWh) surcharge adopted in Decision
         (D.) 01-03-082.
      b) The incremental revenue requirement associated with the
         3 cent/kWh surcharge adopted in D.01-03-082 shall be based on
         applying the surcharge to forecast system-wide sales excluding
         direct access sales. The rates attached to this Order reflect revenue
         allocation and rate design including direct access sales. Thus, in
         workpapers supporting their advice letters, PG&E and Edison
         shall show the level of direct access sales removed from the sales
         forecast in developing the revenue allocation, rate design, and
         resulting rates.
      c) The incremental revenue requirement associated with the 3¢/kWh
         surcharge adopted in D.01-03-082 shall be allocated among the
         customer classes based on the proportional number of bundled
         service kilowatt-hours (kWhs) each class is forecast to consume
         during calendar year 2001 (i.e., equal cents per kWh allocation).



                                       - 74 -
A.00-11-038 et al. ALJ/CMW/tcg                                           DRAFT

     d) CARE customers, residential usage below 130% of baseline, and
        non-CARE medical baseline customers are exempt from any
        revenue allocation associated with the 3 cent/kWh surcharge
        authorized by D.01-03-082. The rates attached to this decision do
        not reflect the exemption of non-CARE medical baseline
        customers. Thus, in workpapers supporting their advice letters,
        PG&E and Edison shall show the sales associated with non-CARE
        medical baseline customers, and how the rates were adjusted to
        reflect exemption of these customers from the surcharge.
     e) The revenue resulting from applying the 3¢/kWh surcharge
        approved in D.01-03-082 to forecast sales to bundled service
        residential customers below 130% of baseline, CARE customers,
        and non-CARE medical baseline customers shall be re-allocated on
        an equal cents per kWh basis to all bundled service sales other
        than 1) residential sales below 130% of baseline, 2) sales to CARE
        customers, and 3) sales to non-CARE medical baseline customers.
     f) PG&E and Edison shall reflect in the rates an allocation of
        shortfalls resulting from the application of the bill limiters adopted
        herein (bill limiter shortfalls). The rates attached to this decision
        do not reflect an allocation of bill limiter shortfalls. Thus, in
        workpapers supporting their advice letters, PG&E and Edison
        shall show how they developed the amount ($) of the bill limiter
        shortfalls and how these shortfalls are reflected in the revenue
        allocation, rate design, and rates within each rate schedule. The
        bill limiter shortfalls shall be allocated on an equal cents per kWh
        basis to all bundled service sales other than 1) sales to CARE
        customers, 2) sales to non-CARE medical baseline customers, and
        3) residential sales below 130% of baseline.
     g) PG&E and Edison shall each establish a balancing account to track
        the actual bill limiter revenue shortfall amount compared to the
        allocation of the bill limiter shortfalls required pursuant to
        Ordering Paragraph 1f, above. Balances in these accounts will be
        reviewed in PG&E’s and Edison’s next respective electric rate
        design proceedings.
     h) Edison and PG&E shall reflect a 5 tier-rate residential rate design
        with incremental block tiers with the following tiers:
              a. Tier 1        Up to the baseline amount



                                      - 75 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

               b. Tier 2        From 100 – 130% of baseline
               c. Tier 3        From 130 – 200% of baseline
               d. Tier 4        From 200 – 300% of baseline
               e. Tier 5        In excess of 300% of baseline.
      i) For small and large commercial customers with seasonal
         designation, 70% of revenue requirement shall be allocated to the
         summer period and 30% to the winter period.
      j) Non-TOU nonresidential customer class and the residential class
         shall have a bill limiter of 300% of class usage.
      k) All customers with declining block schedules shall be corrected to
         be an increasing block structure.
      l) Agricultural rate increases shall be limited to 30% for both time-of-
         use and non-time-of-use customers, with the resulting revenue
         shortfall to be spread over all eligible customer classes, including
         streetlights and residential consumers above 130% of baseline.
      m) Agriculture rates shall also be subject to a bill limiter of 250% on
         energy charges.
      n) The surcharge revenue requirement shall be allocated to the
         streetlight and outdoor lighting schedules on equal cents per
         kilowatt-hour basis.
      o) An equal cents per kilowatt-hour design for traffic signals shall be
         reflected in the tariffs.
      p) The 10% RRB-financed reduction to rates shall apply to rates in
         effect prior to implementation of the 1¢/kWh and 3¢/kWh
         surcharges.
      q) The bill format shall incorporate D.01-03-082’s rate increase
         through the applicable baseline tiers, mid-, off-, or on-peak
         classifications, or other appropriate usage-based component.
      r) The bill format shall label the surcharge as “energy surcharge” or
         “energy procurement surcharge” and should provide the customer
         a separate line item of total energy surcharges.

   2. PG&E and Edison shall amortize the revenue associated with applying the
3¢/kWh surcharge to all non-exempt energy sales from March 27, 2001, to the



                                       - 76 -
A.00-11-038 et al. ALJ/CMW/tcg                                             DRAFT

day utilities begin collecting the surcharge over a 12-month period beginning
with the date the utilities begin collecting the surcharge.
   3. PG&E and Edison shall collect SIC classification data from their customers
in an effort to understand whether a more detailed system of rate design by SIC
classification should be available in future rate design proceedings.
   4. Master meter customers shall revise their billing systems to incorporate
this surcharge, and to comply with Water Code § 80110 and Pub. Util. Code
§ 739.5, by June 1, 2001.
   5. We direct PG&E and Edison to post on their respective websites:
(1) dynamic load profile information for all rate groups for which such
information is available, (2) pricing information, as it becomes available, (3) day-
ahead ISO price for electricity daily, and (4) such other information as may be
useful to customers in controlling their energy usage and bills. We direct our
staff to work with the utilities to maximize the potential for information sharing
and customer assistance offered by the website.
   6. PG&E and Edison shall prepare bill inserts notifying customers of the need
for the rate increase, tiered rate structure, usage levels not impacted, customer
exemptions, the need for conservation and information about the CARE, medical
baseline and California 20/20 Rebate programs. The bill insert will be submitted
to the Public Advisor for review and approval by May 18 and when approved
posted on each utility’s website.
   7. We shall proceed expeditiously to develop and adopt a voluntary RTP that
will be available to customers when their RTP metering systems are installed,
and we direct Energy Division to work closely with PG&E and Edison on their
billing system constraints and the manual billing procedures that can be done for
customers until the system changes are complete.



                                        - 77 -
A.00-11-038 et al. ALJ/CMW/tcg                                          DRAFT

   8. Energy Division shall facilitate a workshop on May 21, 2001 on real time
pricing issues and to develop a master data request.
   9. The master data request shall be finalized and issued by June 8, 2001.
      This order is effective today.
       Dated ____________________, at San Francisco, California.




                                       - 78 -
    APPENDIX A

LIST OF APPEARANCES
                                            ************ SERVICE LIST ***********
                                             Last Update on 04-MAY-2001 by: SMJ
                                                        A0011038 LIST
                                                      A0011056/A0010028

************ APPEARANCES ************                           Michael Aguirre
                                                                Attorney At Law
Gerald Lahr                                                     AGUIRRE & MEYER
ABAG POWER                                                      1060 8TH AVENUE, SUITE 300
101 8TH STREET                                                  SAN DIEGO CA 92101
OAKLAND CA 94607                                                (619) 235-8636
(510) 464-7908                                                  julesan@aol.com
jerryl@abag.ca.gov                                              For: RATEPAYERS/UCAN
For: ASSOCIATION OF BAY AREA GOVERNMENTS (ABAG)
                                                                Carrie H. Allen
Katherine S. Poole                                              AKIN, GUMP, STRAUSS, HAUER & FELD, LLP
ADAMS BROADWELL JOSEPH & CARDOZO                                1333 NEW HAMPSHIRE AVENUE, N.W.
651 GATEWAY BLVD., SUITE 900                                    WASHINGTON DC 20036
SOUTH SAN FRANCISCO CA 94080                                    (202) 887-4444
(650) 589-1660                                                  callen@akingump.com
kpoole@adamsbroadwell.com                                       For: CE Generation
For: The Coalition of California Utility Employees
                                                                Michael Alcantar
Marc D. Joseph                                                  Attorney At Law
Attorney At Law                                                 ALCANTAR & KAHL LLP
ADAMS BROADWELL JOSEPH & CARDOZO                                1300 SW 5TH AVENUE., SUITE 1750
651 GATEWAY BOULEVARD, SUITE 900                                PORTLAND OR 97201
SOUTH SAN FRANCISCO CA 94080                                    (503) 402-9900
(650) 589-1660                                                  mpa@a-klaw.com
mdjoseph@adamsbroadwell.com                                     For: Cogeneration Association of California
For: The Coalition of California Utility Employees
                                                                Evelyn Kahl
William P. Adams                                                Attorney At Law
ADAMS ELECTRICAL SAFETY CONSULTING                              ALCANTAR & KAHL, LLP
716 BRETT AVENUE                                                120 MONTGOMERY STREET, SUITE 2200
ROHNERT PARK CA 94928-4012                                      SAN FRANCISCO CA 94104
(707) 795-7549                                                  (415) 421-4143
For: SELF                                                       ek@a-klaw.com
                                                                For: Energy Producers & Users Coalition
Aaron Thomas
AES NEWENERGY, INC.                                             Edward G. Poole
350 S. GRAND AVENUE, SUITE 2950                                 Attorney At Law
LOS ANGELES CA 90071                                            ANDERSON & POOLE
(213) 996-6136                                                  601 CALIFORNIA STREET, SUITE 1300
athomas@newenergy.com                                           SAN FRANCISCO CA 94108
For: New Energy Ventures, Inc.                                  (415) 956-6413
                                                                epoole@adplaw.com
James Weil                                                      For: California Independent Petroleum Association and Sun-
AGLET CONSUMER ALLIANCE                                         Maid Growers of California
PO BOX 1599
FORESTHILL CA 95631                                             Daniel W. Douglass
(530) 367-3300                                                  Attorney At Law
jweil@aglet.org                                                 ARTER & HADDEN LLP
For: AGLET CONSUMER ALLIANCE                                    5959 TOPANGA CANYON BLVD., STE 244
                                                                WOODLAND HILLS CA 91367
                                                                (818) 596-2201
                                                                douglass@arterhadden.com
                                                                For: ALLIANCE OF RETAIL MARKETS and WESTERN
                                                                POWER TRADING FORUM




                                                          -1-
                                           ************ SERVICE LIST ***********
                                            Last Update on 04-MAY-2001 by: SMJ
                                                       A0011038 LIST
                                                     A0011056/A0010028




Barbara R. Barkovich                                              Robert Pernell
BARKOVICH AND YAP, INC.                                           CALIFORNIA ENERGY COMMISSION
32 EUCALYPTUS LANE                                                1516 9TH STREET
SAN RAFAEL CA 94901                                               SACRAMENTO CA 95829
(415) 457-5537                                                    (916) 654-5036
brbarkovich@earthlink.net                                         rpernell@energy.state.ca.us
For: California Large Energy Consumers Association (CLECA)        For: CALIFORNIA ENERGY COMMISSION (CEC)

Reed V. Schmidt                                                   Karen Norene Mills
BARTLE WELLS ASSOCIATES                                           Attorney At Law
1889 ALCATRAZ AVENUE                                              CALIFORNIA FARM BUREAU FEDERATION
BERKELEY CA 94703                                                 2300 RIVER PLAZA DRIVE
(510) 653-3399                                                    SACRAMENTO CA 95833
rschmidt@bartlewells.com                                          (916) 561-5655
For: California City County Streetlight Association (CAL-SLA)     kmills@cfbf.com
                                                                  For: California Farm Bureau Federation
Marco Gomez
Attorney At Law                                                   Ronald Liebert
BAY AREA RAPID TRANSIT DISTRICT                                   Attorney At Law
800 MADISON STREET, 5TH FLOOR                                     CALIFORNIA FARM BUREAU FEDERATION
OAKLAND CA 94607                                                  2300 RIVER PLAZA DRIVE
(510) 464-6058                                                    SACRAMENTO CA 95833
mgomez1@bart.gov                                                  (916) 561-5657
For: Bay Area Rapid Transit District                              rliebert@cfbf.com
                                                                  For: California Farm Bureau Federation
Roger Berliner
BERLINER, CANDON & JIMISON                                        Ed Yates
1225 19TH STREET, N.W., SUITE 800                                 CALIFORNIA LEAGUE OF FOOD PROCESSORS
WASHINGTON DC 20036                                               980 NINTH STREET, SUITE 230
(202) 955-6067                                                    SACRAMENTO CA 95814
rogerberliner@bcjlaw.com                                          (916) 444-9260
For: Internal Services Department of Los Angeles County           ed@clfp.com
(LACISD)                                                          For: California League of Food Processors

A Brubaker                                                        Lisa G. Urick
BRUBAKER & ASSOCIATES, INC.                                       Attorney At Law
1215 FERN RIDGE PARKWAY, SUITE 208                                CALIFORNIA POWER EXCHANGE CORPORATION
ST. LOUIS MO 63141                                                200 S. LOS ROBLES AVENUE, SUITE 400
(314) 275-7007                                                    PASADENA CA 91101-2482
mbrubaker@consultbai.com                                          (626) 537-3328
For: Brubaker & Associates, Inc.                                  lgurick@calpx.com
                                                                  For: CALIFORNIA POWER EXCHANGE
Jonathan M. Weisgall
V.P. Legislative & Regulatory Affairs                             Tom Smegal
CALENERGY COMPANY, INC.                                           CALIFORNIA WATER SERVICE
1200 NEW HAMPSHIRE AVE., NW, SUITE 300                            1720 NORTH FIRST STREET
WASHINGTON DC 20036                                               SAN JOSE CA 95112
(202) 828-1378                                                    (408) 367-8235
jweisgall@aol.com                                                 tsmegal@calwater.com
                                                                  For: California Water Association
Fernando De Leon
Attorney At Law



                                                            -2-
                                      ************ SERVICE LIST ***********
                                       Last Update on 04-MAY-2001 by: SMJ
                                                  A0011038 LIST
                                                A0011056/A0010028

CALIFORNIA ENERGY COMMISSION
1516 9TH STREET, MS-14
SACRAMENTO CA 95814-5512
(916) 654-4873
fdeleon@energy.state.ca.us
For: CALIFORNIA ENERGY COMMISSION

Jennifer Chamberlin                                       Howard Choy
CHEVRON ENERGY SOLUTIONS                                  Energy Management Division Manager
345 CALIFORNIA ST., 32ND FLOOR                            COUNTY OF LOS ANGELES
SAN FRANCISCO CA 94104                                    INTERNAL SERVICES DEPARTMENT
(415) 733-4661                                            1100 NORTHEASTERN AVENUE
jnnc@chevron.com                                          LOS ANGELES CA 90063
For: Chevron Energy Solutions                             (323) 881-3939
                                                          hchoy@isd.co.la.ca.us
Theresa Mueller                                           For: COUNTY OF LOS ANGELES
Deputy City Attorney
CITY AND COUNTY OF SAN FRANCISCO                          Patrick Mcguire
1 DR. CARLTON B. GOODLETT PLACE                           TOM BEACH
SAN FRANCISCO CA 94102                                    CROSSBORDER ENERGY
(415) 554-4640                                            2560 NINTH STREET, SUITE 316
theresa_mueller@ci.sf.ca.us                               BERKELEY CA 94710
For: City & County of San Francisco                       (510) 649-9790
                                                          patrickm@crossborderenergy.com
Bill Mc Callum                                            For: Watson Cogeneration Company
CITY OF FRESNO
5607 W. JENSEN AVENUE                                     Tom Beach
FRESNO CA 93607                                           CROSSBORDER ENERGY
(559) 498-1728                                            2560 NINTH ST., SUITE 316
bill.mccallum@ci.fresno.ca.us                             BERKELEY CA 94710
For: CITY OF FRESNO                                       (510) 649-9790
                                                          tomb@crossborderenergy.com
Frederick Ortlieb                                         For: Watson Cogeneration Company
Deputy City Attorney
CITY OF SAN DIEGO                                         Treg Tremont
1200 THIRD AVENUE, 11TH FLOOR                             Attorney At Law
SAN DIEGO CA 92101                                        DAVIS WRIGHT TREMAINE
(619) 236-6220                                            ONE EMBARCADERO CENTER, SUITE 600
fmo@sdcity.sannet.gov                                     SAN FRANCISCO CA 94111-3834
For: CITY OF SAN DIEGO                                    (415) 276-6500
                                                          tregtremont@dwt.com
John Tooker                                               For: Costco Wholesale Corporation
City Manager
CITY OF YUCAIPA                                           Lindsey How-Downing
34272 YUCAIPA BLVD.                                       Attorney At Law
YUCAIPA CA 92399                                          DAVIS WRIGHT TREMAINE LLP
(909) 797-2489                                            ONE EMBARCADERO CENTER, STE 600
                                                          SAN FRANCISCO CA 94111-3834
Bill Powers                                               (415) 276-6500
CONGRESS OF CALIFORNIA SENIORS                            lindseyhowdowning@dwt.com
1228 N STREET, SUITE 29                                   For: CALPINE CORPORATION
SACRAMENTO CA 95814
(916) 442-4474                                            Edward W. O'Neill
bpowers@seniors.org                                       Attorney At Law
For: CONGRESS OF CALIFORNIA SENIORS                       DAVIS WRIGHT TREMAINE, LLP



                                                    -3-
                                             ************ SERVICE LIST ***********
                                              Last Update on 04-MAY-2001 by: SMJ
                                                         A0011038 LIST
                                                       A0011056/A0010028

                                                                 ONE EMBARCADERO CENTER, STE 600
                                                                 SAN FRANCISCO CA 94111-3834
                                                                 (415) 276-6500
                                                                 edwardoneill@dwt.com
                                                                 For: El Paso Natural Gas Company




Howard Owens
HOYT MINKOFF
CONSUMER FEDERATION OF CALIFORNIA
1228 N STREET, SUITE 29
SACRAMENTO CA 95814
(916) 554-7621
howens@seniors.org
For: CONSUMER FEDERATION OF CALIFORNIA

Norman J. Furuta                                                 Douglas K. Kerner
Attorney At Law                                                  Attorney At Law
DEPARTMENT OF THE NAVY                                           ELLISON, SCHNEIDER & HARRIS
900 COMMODORE DRIVE, BLDG. 107                                   2015 H STREET
SAN BRUNO CA 94066-5006                                          SACRAMENTO CA 95814
(650) 244-2100                                                   (916) 447-2166
furutanj@efawest.navfac.navy.mil                                 dkk@eslawfirm.com
For: Federal Executive Agencies                                  For: Independent Energy Producers Association

Dan L. Carroll                                                   Diane Fellman
Attorney At Law                                                  Attorney At Law
DOWNEY BRAND SEYMOUR & ROHWER, LLP                               ENERGY LAW GROUP LLP
555 CAPITOL MALL, 10TH FLOOR                                     1999 HARRISON STREET, SUITE 2700
SACRAMENTO CA 95814                                              OAKLAND CA 94612-3572
(916) 441-0131                                                   (510) 874-4301
dcarroll@dbsr.com                                                difellman@energy-law-group.com
For: CALIFORNIA INDUSTRIAL USERS                                 For: PacificCrockett Energy, Inc.

Colin L. Pearce                                                  Andrew J. Skaff
DUANE MORRIS & HECKSCHER                                         Attorney At Law
100 SPEAR STREET, SUITE 1500                                     ENERGY LAW GROUP, LLP
SAN FRANCISCO CA 94105                                           1999 HARRISON STREET, 27TH FLOOR
(415) 371-2200                                                   OAKLAND CA 94612
clpearce@duanemorris.com                                         (510) 874-4330
For: Sacramento Municipal Utility District (SMUD)                askaff@energy-law-group.com
                                                                 For: New York Mercantile Exchange/Dynegy, Inc.
Thomas M. Berliner
Attorneys At Law                                                 Carolyn Kehrein
DUANE MORRIS & HECKSCHER                                         ENERGY MANAGEMENT SERVICES
100 SPEAR STREET, SUITE 1500                                     1505 DUNLAP COURT
SAN FRANCISCO CA 94105                                           DIXON CA 95620-4208
(415) 371-2200                                                   (707) 678-9586
tmberliner@duanemorris.com                                       cmkehrein@ems-ca.com
For: Sacramento Municipal Utility District                       For: Energy Users Forum

Lynn M. Haug                                                     Patrick Mcdonnell
ANDY BROWN                                                       ENSERCH ENERGY SERVICES



                                                           -4-
                                           ************ SERVICE LIST ***********
                                            Last Update on 04-MAY-2001 by: SMJ
                                                       A0011038 LIST
                                                     A0011056/A0010028

Attorney At Law                                                SUITE 290
ELLISON & SCHNEIDER                                            711 GRAND AVENUE
2015 H STREET                                                  SAN RAFAEL CA 94901
SACRAMENTO CA 95814-3109                                       pmcdonne@wenet.net
(916) 447-2166                                                 For: Enserch Energy Services
lmh@eslawfirm.com
For: East Bay Municipal Utility District (EBMUD)

Andrew B. Brown                                                Nancy Ryan
Attorney At Law                                                ENVIRONMENTAL DEFENSE
ELLISON, SCHNEIDER & HARRIS                                    5655 COLLEGE AVENUE
2015 H STREET                                                  OAKLAND CA 94618
SACRAMENTO CA 95814                                            (510) 658-8008
(916) 447-2166                                                 nryan@environmentaldefense.org
abb@eslawfirm.com                                              For: Environmental Defense
For: CALIFORNIA DEPARTMENT OF GENERAL SERVICES
(DGS)

James D. Squeri                                                Kelly R. Tilton
Attorney At Law                                                Attorney At Law
GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP                       GRUENEICH RESOURCE ADVOCATES
505 SANSOME STREET, SUITE 900                                  582 MARKET STREET, SUITE 1020
SAN FRANCISCO CA 94111                                         SAN FRANCISCO CA 94104
(415) 392-7900                                                 (415) 834-2300
jsqueri@gmssr.com                                              ktilton@gralegal.com
For: California Retailers Association                          For: University of California/California State University

Jeanne M. Bennett                                              Morten Henrik Greidung
Attorney At Law                                                HAFSLUND ENERGY TRADING, LLC
GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP                       101 ELLIOT AVE., SUITE 510
505 SANSOME STREET, SUITE 900                                  SEATTLE WA 98119
SAN FRANCISCO CA 94111                                         (206) 436-0640
(415) 392-7900                                                 mhg@hetrading.com
jbennett@gmssr.com                                             For: HAFSLUND ENERGY TRADING, LLC
For: Alliance for Retail Markets and Enron Corporation
                                                               James Hodges
Michael B. Day                                                 4720 BRAND WAY
Attorney At Law                                                SACRAMENTO CA 95819
GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP                       (916) 451-7011
505 SANSOME STREET, SUITE 900                                  hodgesjl@pacbell.net
SAN FRANCISCO CA 94111-3133                                    For: TELACU and Maravilla Foundation
(415) 392-7900
mday@gmssr.com                                                 Jan Smutny-Jones
For: ENRON ENERGY SERVICES, INC., ENRON NORTH                  Association
AMERICA                                                        INDEPENDENT ENERGY PRODUCERS
                                                               1112 I STREET, STE. 380
Richard H. Counihan                                            SACRAMENTO CA 95814-2896
GREENMOUNTAIN.COM                                              (916) 448-9499
50 CALIFORNIA STREET, SUITE 1500                               smutny@iepa.com
SAN FRANCISCO CA 94111
(415) 439-5310                                                 William B. Marcus
rick.counihan@greenmountain.com                                JBS ENERGY, INC.
For: GREEN MOUNTAIN ENERGY RESOURCES                           311 D STREET, SUITE A
                                                               WEST SACRAMENTO CA 95605
David L. Marshall                                              (916) 372-0534



                                                         -5-
                                        ************ SERVICE LIST ***********
                                         Last Update on 04-MAY-2001 by: SMJ
                                                    A0011038 LIST
                                                  A0011056/A0010028

GREGG INDUSTRIES, INC.                                         bill@jbsenergy.com
10460 HICKSON STREET                                           For: TURN (EXPERT WITNESS)
EL MONTE CA 91731
(626) 575-7664                                                 Norman A. Pedersen
dmarshall@greggind.com                                         Esquire
For: Gregg Industries, Inc.                                    JONES DAY REAVES & POGUE
                                                               555 WEST FIFTH STREET, SUITE 4600
Irene K. Moosen                                                LOS ANGELES CA 90013-1025
KELLY TILTON                                                   (213) 243-2810
GRUENEICH RESOURCE ADVOCATES                                   napedersen@jonesday.com
582 MARKET STREET, SUITE 1020                                  For: Commonwealth Energy Corporation and Automated Power
SAN FRANCISCO CA 94104-5305                                    Exchange Inc. & Frito Lay, Inc.
(415) 834-2300
imoosen@gralegal.com
For: Sonoma County Water Agency                                Bill Bishop
                                                               JR. WOOD, INC.
                                                               PO BOX 545
                                                               ATWATER CA 95301
                                                               (209) 358-5643
                                                               bishop@jrwood.com
                                                               For: Jr. Wood, Inc. and Manufacturers Council of the Central
                                                               Valley (MCCV)


Kathleen Kiernan-Harrington                                    William H. Booth
JAMES WEIL                                                     Attorney At Law
SUITE 200                                                      LAW OFFICES OF WILLIAM H. BOOTH
720 MARKET STREET                                              1500 NEWELL AVENUE, 5TH FLOOR
SAN FRANCISCO CA 94102                                         WALNUT CREEK CA 94596
(415) 781-5348                                                 (925) 296-2460
harrington@ggra.org                                            wbooth@booth-law.com
For: GOLDEN GATE RESTAURANT ASSOCIATION                        For: California Large Energy Consumers Assn.

Daniel L. Rial                                                 Christopher A. Hilen
KINDER MORGAN ENERGY PARTNERS                                  Attorney At Law
1100 TOWN & COUNTRY ROAD                                       LEBOEUF LAMB GREENE & MACRAE LLP
ORANGE CA 92868                                                ONE EMBARCADERO CENTER, SUITE 400
(714) 560-4854                                                 SAN FRANCISCO CA 94111
riald@kindermorgan.com                                         (415) 951-1141
For: Kinder Morgan Energy Partners, SFPP, L.P., CALNEV         chilen@llgm.com
                                                               For: RELIANT ENERGY POWER GENERATION, INC.
Ron Knecht
1465 MARLBAROUGH AVENUE                                        John W. Leslie
LOS ALTOS CA 94024-5742                                        Attorney At Law
(650) 968-0115                                                 LUCE FORWARD HAMILTON & SCRIPPS, LLP
ronknecht@aol.com                                              600 WEST BROADWAY, SUITE 2600
For: SELF                                                      SAN DIEGO CA 92101-3391
                                                               (619) 699-2536
Thomas S. Knox                                                 jleslie@luce.com
Attorney At Law                                                For: SHELL ENERGY SERVICES, LLC
KNOX, LEMMON & ANAPOCSKY, LLP
ONE CAPITOL MALL, SUITE 700                                    Steven Moss
SACRAMENTO CA 95814                                            M.CUBED
(916) 498-9911                                                 673 KANSAS STREET
                                                               SAN FRANCISCO CA 94107



                                                         -6-
                                           ************ SERVICE LIST ***********
                                            Last Update on 04-MAY-2001 by: SMJ
                                                       A0011038 LIST
                                                     A0011056/A0010028

tknox@klalawfirm.com                                              (415) 643-9578
For: Leprino Foods                                                smoss@hooked.net
                                                                  For: WESTERN MOBILHOME PARK ASSOCIATION
Susan E. Brown
Attorney At Law                                                   David Huard
LATINO ISSUES FORUM                                               RANDALL KEEN
785 MARKET STREET, 3RD FLOOR                                      MANATT, PHELPS & PHILLIPS
SAN FRANCISCO CA 94103-2003                                       11355 W. OLYMPIC BLVD
(415) 284-7224                                                    LOS ANGELES CA 90064
joseh@lif.org                                                     (310) 312-4247
For: LATINO ISSUES FORUM                                          dhuard@manatt.com
                                                                  For: CALIFORNIA HEALTHCARE ASSOCIATION
C. Susie Berlin
Attorney At Law                                                   Matthew V. Brady
LAW OFFICES OF BARRY F. MC CARTHY                                 Attorney At Law
2105 HAMILTON AVENUE, SUITE 140                                   MATTHEW V. BRADY & ASSOCIATES
SAN JOSE CA 95125                                                 300 CAPITOL MALL, SUITE 1100
(408) 558-0950                                                    SACRAMENTO CA 95814
sberlin@mccarthylaw.com                                           (916) 442-5600
For: NORTHERN CALIFORNIA POWER AGENCY                             bradylaw@pacbell.net
                                                                  For: Shasta Hydroelectric, Inc.


David J. Byers                                                    Scott T. Steffen
Attorney At Law                                                   Attorney At Law
MCCRACKEN, BYERS & HAESLOOP                                       MODESTO IRRIGATION DISTRICT
840 MALCOLM ROAD, SUITE 100                                       1231 ELEVENTH STREET
BURLINGAME CA 94010                                               MODESTO CA 95354
(650) 259-5979                                                    (209) 526-7387
btenney@landuselaw.com                                            scottst@mid.org
For: California City County Streetlight Association (CAL-SLA)     For: MODESTO IRRIGATION DISTRICT (MID)

Terry J. Houlihan                                                 Diane E. Pritchard
Attorney At Law                                                   Attorney At Law
MCCUTCHEN DOYLE BROWN & ENERSEN LLP                               MORRISON & FOERSTER, LLP
3 EMBARCADERO CENTER, 18TH FLOOR                                  425 MARKET STREET
SAN FRANCISCO CA 94111                                            SAN FRANCISCO CA 94105-2482
(415) 393-2022                                                    (415) 268-7000
thoulihan@mdbe.com                                                dpritchard@mofo.com
For: RELIANT ENERGY POWER GENERATION, INC.                        For: E&J Gallo Winery, The Wine Institute and the Agricultural
                                                                  Energy Consumers Association.
Patricia R. Williams
MERVYN'S CALIFORNIA                                               Peter Hanschen
22301 FOOTHILL BOULEVARD                                          Attorney At Law
HAYWARD CA 94541                                                  MORRISON & FOERSTER, LLP
(510) 727-5905                                                    425 MARKET STREET
pat.williams@dhcmail.com                                          SAN FRANCISCO CA 94105
For: Mervyn's/Target Stores Division of Dayton Hudson             (415) 268-7214
Corporation                                                       phanschen@mofo.com
                                                                  For: Agricultural Energy Consumers Assn.
Jeffrey H. Goldfien
Assistant City Attorney                                           Sara Steck Myers
MEYERS, NAVE, RIBACK, SILVER & WILSON                             Attorney At Law
777 DAVIS STREET, SUITE 300                                       122 28TH AVENUE
SAN LEANDRO CA 94577                                              SAN FRANCISCO CA 94121



                                                            -7-
                                         ************ SERVICE LIST ***********
                                          Last Update on 04-MAY-2001 by: SMJ
                                                     A0011038 LIST
                                                   A0011056/A0010028

(510) 351-4300                                                  (415) 387-1904
jhg@meyersnave.com                                              ssmyers@worldnet.att.net
For: City of San Leandro                                        For: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE
                                                                TECHOLOGIES (CEERT)
Christopher W. Reardon
MFRS COUNCIL OF THE CENTRAL VALLEY                              Richard Roos-Collins
PO BOX 1564                                                     Attorney At Law
MODESTO CA 95353                                                NATURAL HERITAGE INSTITUTE
(209) 523-0886                                                  2140 SHATTUCK AVENUE, SUITE 500
cwrmccv@worldnet.att.net                                        BERKELEY CA 94704-1222
For: Manufacturers Council of the Central Valley (MCCV)         (510) 644-2900
                                                                rrcollins@n-h-i.org
Kevin R. Mcspadden                                              For: California Hydropower Reform Coalition
Attorney At Law
MILBANK TWEED HADLEY & MCCLOY                                   Janie Mollon
601 SOUTH FIGUEROA, 30TH FLOOR                                  Manager Regulatory Affairs
LOS ANGELES CA 90017                                            NEW WEST ENERGY
(213) 892-4563                                                  PO BOX 61868
kmcspadd@milbank.com                                            PHOENIX AZ 85082-1868
For: MILBANK, TWEED, HADLEY & MC CLOY                           (602) 629-7758
                                                                jsmollon@newwestenergy.com
                                                                For: NEW WEST ENERGY

Jose E. Guzman, Jr.                                             Don Schoenbeck
Attorney At Law                                                 RCS CONSULTING, INC.
NOSSAMAN GUTHNER KNOX & ELLIOTT LLP                             900 WASHINGTON STREET, SUITE 1000
50 CALIFORNIA STREET, 34TH FLOOR                                VANCOUVER WA 98660
SAN FRANCISCO CA 94111-4799                                     (360) 737-3877
(415) 398-3600                                                  dws@keywaycorp.com
jguzman@nossaman.com                                            For: Coalinga Cogenerator
For: Cargill Corporation
                                                                James Ross
Christine Ferrari                                               RCS CONSULTING, INC.
Depurty City Attorney                                           500 CHESTERFIELD CENTER, SUITE 320
OFFICE OF THE CITY ATTORNEY                                     CHESTERFIELD MO 63017
CITY HALL ROOM 234                                              (636) 530-9544
1 DR. CARLTON B. GOODLETT PLACE                                 rcsstl@cdmnet.com
SAN FRANCISCO CA 94102-4682                                     For: Midway Sunset Cogeneration
(415) 554-4634
christine_ferrari@ci.sf.ca.us                                   Steven Greenberg
                                                                REALENERGY
Joseph M. Malkin                                                300 CAPITOL MALL, SUITE 300
Attorney At Law                                                 SACRAMENTO CA 95814
ORRICK, HERRINGTON & SUTCLIFFE LLP                              (916) 325-2500
400 SANSOME STREET                                              sgreenberg@realenergy.com
SAN FRANCISCO CA 94111-3143                                     For: RealEnergy
(415) 773-5505
jmalkin@orrick.com                                              Keith Sappenfield
For: THE AES CORPORATION                                        RELIANT ENERGY RETAIL, INC.
                                                                PO BOX 1409
William H. Edwards                                              HOUSTON TX 77251-1409
KELLY M. MORTON, JAMES L. LOPES                                 (713) 207-5570
PACIFIC GAS AND ELECTRIC CO.                                    keith-sappenfield@reliantenergy.com
77 BEALE STREET                                                 For: Reliant Energy Retail, Inc.
PO BOX 7442, RM 3115-B30A



                                                          -8-
                                            ************ SERVICE LIST ***********
                                             Last Update on 04-MAY-2001 by: SMJ
                                                        A0011038 LIST
                                                      A0011056/A0010028

SAN FRANCISCO CA 94120-7442
(415) 973-2768                                                  Randy Britt
whe1@pge.com                                                    ROBINSONS-MAY
For: PG&E                                                       6160 LAUREL CANYON BLVD.
                                                                NORTH HOLLYWOOD CA 91606
Peter Ouborg                                                    (818) 509-4777
Attorney At Law                                                 randy_britt@mayco.com
PACIFIC GAS AND ELECTRIC COMPANY                                For: Robinsons-May
PO BOX 770000
SAN FRANCISCO CA 94177                                          Arlin Orchard
(415) 973-2286                                                  Attorney At Law
pxo2@pge.com                                                    SACRAMENTO MUNICIPAL UTILITY DISTRICT
For: Pacific Gas and Electric Company                           PO BOX 15830, MAIL STOP-B406
                                                                SACRAMENTO CA 95852-1830
Patrick J. Power                                                (916) 732-5830
Attorney At Law                                                 aorchar@smud.org
1300 CLAY STREET, SUITE 600                                     For: Sacramento Municipal Utility District
OAKLAND CA 94612
(510) 446-7742                                                  Dana S. Appling
pjpowerlaw@aol.com                                              General Counsel
For: City of Long Beach; Universal Studios Inc.                 SACRAMENTO MUNICIPAL UTILITY DISTRICT
                                                                LEGAL DEPARTMENT MSB406
                                                                PO BOX 15830
                                                                SACRAMENTO CA 95852-1830
                                                                (916) 732-6126


Phillip J. Muller                                               Beth A. Fox
SCD ENERGY SOLUTIONS                                            Attorney At Law
436 NOVA ALBION WAY                                             SOUTHERN CALIFORNIA EDISON COMPANY
SAN RAFAEL CA 94903                                             2244 WALNUT GROVE AVENUE
(415) 479-1710                                                  ROSEMEAD CA 91770
pjmuller@ricochet.net                                           (626) 302-6897
For: Southern Company Energy Marketing                          beth.fox@sce.com
                                                                For: SOUTHERN CALIFORNIA EDISON COMPANY (SCE)
Jeffrey M. Parrott
LYNN G. VAN WAGENEN                                             James P. Shotwell
Attorney At Law                                                 Attorney At Law
SEMPRA ENERGY                                                   SOUTHERN CALIFORNIA EDISON COMPANY
101 ASH STREET                                                  2244 WALNUT GROVE AVE., ROOM 337
SAN DIEGO CA 92101-3017                                         ROSEMEAD CA 91770-0001
(619) 699-5063                                                  (626) 302-4531
jparrott@sempra.com                                             j.p.shotwell@sce.com
For: San Diego Gas & Electric Company                           For: SOUTHERN CALIFORNIA EDISON COMPANY (SCE)

Judy Young                                                      James C. Paine
Attorney At Law                                                 Attorney At Law
SEMPRA ENERGY                                                   STOEL RIVES LLP
555 W. 5TH STREET, M.L.G.T. 14E7                                900 S.W. FIFTH AVENUE, STE 2600
LOS ANGELES CA 90013                                            PORTLAND OR 97204-1268
(213) 244-2955                                                  (503) 294-9246
jlyoung@sempra.com                                              jcpaine@stoel.com
For: Southern California Gas Company                            For: PacifiCorp

Keith W. Melville                                               James Bushee



                                                          -9-
                                          ************ SERVICE LIST ***********
                                           Last Update on 04-MAY-2001 by: SMJ
                                                      A0011038 LIST
                                                    A0011056/A0010028

DAVID R. CLARK                                                  SUTHERLAND, ASBILL & BRENNAN
Attorney At Law                                                 1275 PENNSYLVANIA AVENUE
SEMPRA ENERGY                                                   WASHINGTON DC 20004
101 ASH STREET                                                  (202) 383-0100
SAN DIEGO CA 92101-3017                                         jbushee@sablaw.com
(619) 699-5039                                                  For: CALIFORNIA MANUFACTURERS ASSOCIATION (CMA)
kmelville@sempra.com
For: San Diego Gas & Electric Company                           Keith Mc Crea
                                                                Attorney At Law
Andrew Chau                                                     SUTHERLAND, ASBILL & BRENNAN LLC
Attorney At Law                                                 1275 PENNSYLVANIA AVENUE, N.W.
SHELL ENERGY SERVICES COMPANY, L.L.C.                           WASHINGTON DC 20004-2415
1221 LAMAR STREET, SUITE 1000                                   (202) 383-0705
HOUSTON TX 77010                                                kmccrea@sablaw.com
(713) 241-8939                                                  For: CALIFORNIA MANUFACTURERS & TECHNOLOGY
anchau@shellus.com                                              ASSN.

Justin D. Bradley
SILICON VALLEY MANUFACTURING GROUP
226 AIRPORT PARKWAY, SUITE 190                                  Gene L. Waas
SAN JOSE CA 95110                                               THE CALIFORNIA POWER EXCHANGE
(408) 501-7852                                                  1000 SOUTH FREMONT BUILDING A9 WEST
jbradley@svmg.org                                               ALHAMBRA CA 91803
For: Silicon Valley Manufacturing Group                         (626) 537-3326
                                                                glwaas@calpx.com
                                                                For: The California Power Exchange


Chris Witteman                                                  Bernardo R. Garcia
THE GREENLINING INSTITUTE                                       UTILITY WORKERS UNION OF AMERICA,AFL-CIO
785 MARKET STREET, 3RD FLOOR                                    PO BOX 5198
SAN FRANCISCO CA 94103-2003                                     OCEANSIDE CA 92052-5198
(415) 284-7202                                                  (949) 369-9936
chrisw@greenlining.org                                          uwuaregion5@earthlink.net
For: THE GREENLINING INSTITUTE                                  For: Utility Workers Union of America, AFL-CIO

Denis George                                                    Jerry Bloom
Energy Manager                                                  MARGARET ROSTKER (EMAIL: ROSTKMA@LAWHITE
THE KROGER COMPANY                                              Attorney At Law
1014 VINE STREET                                                WHITE & CASE
CINCINNATI OH 45202                                             TWO EMBARCADERO CENTER, SUITE 650
(513) 762-4538                                                  SAN FRANCISCO CA 94111
dgeorge@kroger.com                                              (415) 544-1104
For: The Kroger Company                                         bloomje@la.whitecase.com
                                                                For: California Cogeneration Council
Peter Bray
THE NEW POWER COMPANY                                           Jason J. Zeller
101 CALIFORNIA STREET, SUITE 1950                               Legal Division
SAN FRANCISCO CA 94111                                          RM. 5002
(415) 782-7810                                                  505 VAN NESS AVE
pbray@newpower.com                                              San Francisco CA 94102
For: The New Power Company                                      (415) 703-4673
                                                                jjz@cpuc.ca.gov
Matthew Freedman                                                For: Office of Ratepayer Advocates
Attorney At Law



                                                       - 10 -
                                         ************ SERVICE LIST ***********
                                          Last Update on 04-MAY-2001 by: SMJ
                                                     A0011038 LIST
                                                   A0011056/A0010028

THE UTILITY REFORM NETWORK
711 VAN NESS AVENUE, SUITE 350                                 ********** STATE EMPLOYEE ***********
SAN FRANCISCO CA 94102
(415) 929-8876                                                 Truman L. Burns
freedman@turn.org                                              Office of Ratepayer Advocates
For: The Utility Reform Network (TURN)                         RM. 4209
                                                               505 VAN NESS AVE
Robert Finkelstein                                             San Francisco CA 94102
Attorney At Law                                                (415) 703-2932
THE UTILITY REFORM NETWORK                                     txb@cpuc.ca.gov
711 VAN NESS AVENUE, SUITE 350                                 For: OFFICE OF RATEPAYER ADVOCATES
SAN FRANCISCO CA 94102
(415) 929-8876 X-301                                           Michael W. Neville
bfinkelstein@turn.org                                          Attorney At Law
For: The Utility Reform Network (TURN)                         CALIFORNIA ATTORNEY GENERAL'S OFFICE
                                                               455 GOLDEN GATE AVENUE, SUITE 11000
Michael Shames                                                 SAN FRANCISCO CA 94102-7004
Attorney At Law                                                (415) 703-5523
UTILITY CONSUMERS' ACTION NETWORK                              nevillm@hdcdojnet.state.ca.us
1717 KETTNER BLVD., SUITE 105                                  For: CALIFORNIA RESOURCES AGENCY
SAN DIEGO CA 92101-2532
(619) 696-6966                                                 Jennifer Tachera
mshames@ucan.org                                               Attorney At Law
For: Utility Consumers' Action Network (UCAN)                  CALIFORNIA ENERGY COMMISSION
                                                               1516 NINTH STREET, MS-14
                                                               SACRAMENTO CA 95814-5504
                                                               (916) 654-3870
                                                               jtachera@energy.state.ca.us


Lorenzo Kristov                                                Robert Miyashiro
CALIFORNIA ENERGY COMMISSION                                   DEPT. OF FINANCE
1516 9TH ST., MS-22                                            STATE CAPITOL, RM 1145
SACRAMENTO CA 95814                                            SACRAMENTO CA 95814
(916) 654-4773                                                 (916) 445-8610
LKristov@energy.state.ca.us                                    firmiyas@dof.ca.gov
For: California Energy Commission                              For: DEPT. OF FINANCE (DOF)

Monica Schwebs                                                 Christopher Danforth
Attorney At Law                                                Office of Ratepayer Advocates
CALIFORNIA ENERGY COMMISSION                                   RM. 4101
1516 NINTH STREET, MS-14                                       505 VAN NESS AVE
SACRAMENTO CA 95814-5512                                       San Francisco CA 94102
(916) 654-5207                                                 (415) 703-1481
mschwebs@energy.state.ca.us                                    ctd@cpuc.ca.gov
                                                               For: Office of Ratepayer Advocates
Ruben Tavares
Electricity Analysis Office                                    Joseph R. DeUlloa
CALIFORNIA ENERGY COMMISSION                                   Administrative Law Judge Division
1516 9TH STREET, MS 20                                         RM. 5105
SACRAMENTO CA 95814                                            505 VAN NESS AVE
(916) 654-5171                                                 San Francisco CA 94102
rtavares@energy.state.ca.us                                    (415) 703-3124
For: California Energy Commission                              jrd@cpuc.ca.gov



                                                      - 11 -
                                     ************ SERVICE LIST ***********
                                      Last Update on 04-MAY-2001 by: SMJ
                                                 A0011038 LIST
                                               A0011056/A0010028

Roderick A. Campbell                                       Pamela Durgin
Office Of Governmental Affairs                             Energy Division
CALIFORNIA PUBLIC UTILITIES COMMISSION                     RM. 4-A
770 L STREET, STE 1050                                     505 VAN NESS AVE
SACRAMENTO CA 95814                                        San Francisco CA 94102
(916) 327-1418                                             (415) 703-1124
rax@cpuc.ca.gov                                            pmd@cpuc.ca.gov

Sean F. Casey                                              Robert T. Feraru
Office of Ratepayer Advocates                              Public Advisor Office
RM. 4205                                                   RM. 5303
505 VAN NESS AVE                                           505 VAN NESS AVE
San Francisco CA 94102                                     San Francisco CA 94102
(415) 703-1667                                             (415) 703-2074
sfc@cpuc.ca.gov                                            rtf@cpuc.ca.gov
For: Office of Ratepayer Advocates                         For: Public Advisor's Office

Jim O'Brien                                                Faline Fua
DEPARTMENT OF WATER RESOURCES                              Energy Division
1416 9TH STREET, ROOM 1118                                 AREA 4-A
SACRAMENTO CA 94236                                        505 VAN NESS AVE
(916) 653-8816                                             San Francisco CA 94102
dwrlegal1@water.ca.gov                                     (415) 703-2481
For: Department of Water Resources                         fua@cpuc.ca.gov


Julie Halligan                                             Donald J. Lafrenz
Executive Division                                         Energy Division
RM. 5215                                                   AREA 4-A
505 VAN NESS AVE                                           505 VAN NESS AVE
San Francisco CA 94102                                     San Francisco CA 94102
(415) 703-3491                                             (415) 703-1063
jmh@cpuc.ca.gov                                            dlf@cpuc.ca.gov
                                                           For: Energy Division
Audra Hartmann
Legal Division                                             Steve Linsey
770 L STREET, SUITE 1050                                   Office of Ratepayer Advocates
Sacramento CA 95814                                        RM. 4101
(916) 327-1417                                             505 VAN NESS AVE
ath@cpuc.ca.gov                                            San Francisco CA 94102
                                                           (415) 703-1341
Kayode Kajopaiye                                           car@cpuc.ca.gov
Energy Division                                            For: Office of Ratepayer Advocates
AREA 4-A
505 VAN NESS AVE                                           Jeanette Lo
San Francisco CA 94102                                     Energy Division
(415) 703-2557                                             AREA 4-A
kok@cpuc.ca.gov                                            505 VAN NESS AVE
For: Energy Division                                       San Francisco CA 94102
                                                           (415) 703-1825
Dexter E. Khoury                                           jlo@cpuc.ca.gov
Office of Ratepayer Advocates                              For: Energy Division
RM. 4205
505 VAN NESS AVE                                           Kim Malcolm
San Francisco CA 94102                                     Executive Division



                                                  - 12 -
                                     ************ SERVICE LIST ***********
                                      Last Update on 04-MAY-2001 by: SMJ
                                                 A0011038 LIST
                                               A0011056/A0010028

(415) 703-1200                                             RM. 5115
bsl@cpuc.ca.gov                                            505 VAN NESS AVE
For: Office of Ratepayer Advocates                         San Francisco CA 94102
                                                           (415) 703-1926
Robert Kinosian                                            kim@cpuc.ca.gov
Office of Ratepayer Advocates
RM. 4209                                                   Anne W. Premo
505 VAN NESS AVE                                           Energy Division
San Francisco CA 94102                                     AREA 4-A
(415) 703-1500                                             505 VAN NESS AVE
gig@cpuc.ca.gov                                            San Francisco CA 94102
For: Office of Ratepayer Advocates                         (415) 703-1247
                                                           awp@cpuc.ca.gov
Laura L. Krannawitter                                      For: CPUC ENERGY DIVISION
Executive Division
RM. 5210                                                   Steve Roscow
505 VAN NESS AVE                                           Energy Division
San Francisco CA 94102                                     AREA 4-A
(415) 703-2538                                             505 VAN NESS AVE
llk@cpuc.ca.gov                                            San Francisco CA 94102
                                                           (415) 703-1189
                                                           scr@cpuc.ca.gov




Steven C Ross                                              Rosalina White
Office of Ratepayer Advocates                              Public Advisor Office
RM. 4102                                                   RM. 5303
505 VAN NESS AVE                                           505 VAN NESS AVE
San Francisco CA 94102                                     San Francisco CA 94102
(415) 703-2140                                             (415) 703-2074
sro@cpuc.ca.gov                                            raw@cpuc.ca.gov

Randy Chinn                                                John S. Wong
SENATE ENERGY COMMITTEE                                    Administrative Law Judge Division
ROMM 408                                                   RM. 5019
STATE CAPITOL                                              505 VAN NESS AVE
SACRAMENTO CA 95814                                        San Francisco CA 94102
randy.chinn@senate.ca.gov                                  (415) 703-3130
                                                           jsw@cpuc.ca.gov
Linda Serizawa
Executive Division                                         ********* INFORMATION ONLY **********
RM. 5119
505 VAN NESS AVE                                           Tom O'Neill
San Francisco CA 94102                                     Vice President
(415) 703-1383                                             ABN AMRO INCORPORATED
lss@cpuc.ca.gov                                            EQUITY RESEARCH
                                                           ONE CALIFORNIA STREET, SUITE 200
Maria E. Stevens                                           SAN FRANCISCO CA 94111
Executive Division                                         (415) 983-2901
RM. 500                                                    tom.oneill@abnamro.com
320 WEST 4TH STREET SUITE 500
Los Angeles CA 90013                                       David Marcus
(213) 576-7012                                             ADAMS BROADWELL & JOSEPH



                                                  - 13 -
                                      ************ SERVICE LIST ***********
                                       Last Update on 04-MAY-2001 by: SMJ
                                                  A0011038 LIST
                                                A0011056/A0010028

mer@cpuc.ca.gov                                             PO BOX 1287
                                                            BERKELEY CA 94701-1287
Zenaida G. Tapawan-Conway                                   (510) 528-0728
Energy Division                                             dmarcus@slip.net
AREA 4-A                                                    For: Coalition of California Utility Employees
505 VAN NESS AVE
San Francisco CA 94102                                      Ira Schoenholtz
(415) 703-2624                                              President
ztc@cpuc.ca.gov                                             AMERICAN ASSN OF BUSINESS PERSONS W/DIS
                                                            2 WOODHOLLOW
Maria Vanko                                                 IRVINE CA 92604-3229
Energy Division                                             (949) 559-1516
AREA 4-A                                                    For: American Association of Business Persons with Disabilities
505 VAN NESS AVE
San Francisco CA 94102                                      Edward G. Poole
(415) 703-2818                                              Attorney At Law
mv1@cpuc.ca.gov                                             ANDERSON & POOLE
For: Energy Division                                        601 CALIFORNIA STREET, SUITE 1300
                                                            SAN FRANCISCO CA 94108
Christine M. Walwyn                                         (415) 956-6413
Administrative Law Judge Division                           epoole@adplaw.com
RM. 5101                                                    For: INDEPENDENT OIL PRODUCERS AGENCY (IOPA)
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-2301
cmw@cpuc.ca.gov


Robert E. Anderson                                          J. A. Savage
APS ENERGY SERVICES                                         CALIFORNIA ENERGY MARKETS
1500 FIRST AVENUE                                           3006 SHEFFIELD AVENUE
ROCHESTER MN 55906                                          OAKLAND CA 94602-1545
(507) 289-0800                                              (510) 534-9109
bob_anderson@apses.com                                      honest@compuserve.com
For: APS ENERGY SERVICES                                    For: California Energy Markets

Ed Cazalet                                                  Lulu Weinzimer
AUTOMATED POWER EXCHANGE, INC.                              CALIFORNIA ENERGY MARKETS
5201 GREAT AMERICA PARKWAY                                  9 ROSCOE STREET
SANTA CLARA CA 95054                                        SAN FRANCISCO CA 94110-5921
(408) 517-2900                                              (415) 824-3222
ed@apx.com                                                  luluw@newsdata.com
For: Automated Power Exchange, Inc.
                                                            William Dombrowski
Scott Blaising                                              CALIFORNIA RETAILERS ASSOCIATION
Attorney At Law                                             980 9TH STREET, SUITE 2100
8980 MOONEY ROAD                                            SACRAMENTO CA 95814-2741
ELK GROVE CA 95624                                          (916) 443-1975
(916) 682-9702
blaising@braunlegal.com                                     Alexandre B. Makler
                                                            CALPINE CORPORATION
Paul A. Harris                                              6700 KOLL CENTER PARKWAY, SUITE 200
BRIDGE NEWS                                                 PLEASANTON CA 94566
44 MONTGOMERY, SUITE 2410                                   (925) 600-2081
SAN FRANCISCO CA 94104                                      alexm@calpine.com


                                                   - 14 -
                                    ************ SERVICE LIST ***********
                                     Last Update on 04-MAY-2001 by: SMJ
                                                A0011038 LIST
                                              A0011056/A0010028

(415) 835-7641                                            For: CALPINE CORPORATION
paul.harris@bridge.com
For: BRIDGE NEWS                                          Susannah Churchill
                                                          Energy Advocate
Mona Patel                                                CALPIRG
BROWN & WOOD LLP                                          926 J ST. 523
555 CALIFORNIA STREET, 50TH FLOOR                         SACRAMENTO CA 95814
SAN FRANCISCO CA 94104                                    (916) 448-4516
(415) 772-1265                                            swchurchill@juno.com
mpatel@brownwoodlaw.com                                   For: CALPIRG

Stephen Layman                                            Douglas L. Anderson
CALIFORNIA ENERGY COMMISSION, EIAD                        Vice President And General Counsel
1516 9TH STREET, MS-20                                    CE GENERATION, L.L.C.
SACRAMENTO CA 95814                                       302 SOUTH 36TH STREET, SUITE 400
(916) 654-4845                                            OMAHA NE 68131
Slayman@energy.state.ca.us
                                                          J. Patrick Tang
Derk Pippin                                               JOHN A. RUSSO/BARBARA J. PARKER
CALIFORNIA ENERGY MARKETS                                 Deputy City Attorney
9 ROSCOE STREET                                           CITY OF OAKLAND
SAN FRANCISCO CA 94110-5921                               ONE FRANK OGAWA PLAZA 6TH FLOOR
(415) 824-3222                                            OAKLAND CA 94612
derkp@newsdata.com                                        (510) 238-6523
For: CALIFORNIA ENERGY MARKETS (CEM)                      jptang@oaklandcityattorney.org




John A. Barthrop                                          Gregory T. Blue
General Counsel                                           Manager, State Regulatory Affairs
COMMONWEALTH ENERGY CORP.                                 DYNEGY, INC.
15991 RED HILL AVENUE, NO. 201                            5976 W. LAS POSITAS BLVD., STE. 200
TUSTIN CA 92780                                           PLEASANTON CA 94588
(714) 258-0470                                            (925) 469-2355
jbarthrop@powersavers.com                                 gtbl@dynegy.com
For: Commonwealth Energy Corp.                            For: Dynegy, Inc.

Angela Oh                                                 Joseph A. Young
Advisor                                                   EAST BAY MUNICIPAL UTILITY DISTRICT
COMMUNITY TECHNOLOGY POLICY COUNCIL                       375 ELEVENTH STREET, ROOM MS 205
PMB 7000-639                                              OAKLAND CA 94607
REDONDO BEACH CA 90277                                    (510) 287-0147
                                                          jyoung@ebmud.com
June M. Skillman
COMPLETE ENERGY SERVICES, INC.                            Wendy Illingworth
650 E. PARKRIDGE AVENUE, UNIT 110                         ECONOMIC INSIGHTS
CORONA CA 92879                                           320 FEATHER LANE
(909) 280-9411                                            SANTA CRUZ CA 95060
jskillman@prodigy.net                                     (831) 427-2163
                                                          wendy@econinsights.com
Maria Crispi
22 SOUTH PARK, ROOM 320                                   Jon S. Silva
SAN FRANCISCO CA 94107                                    Government Affairs Associate



                                                 - 15 -
                                        ************ SERVICE LIST ***********
                                         Last Update on 04-MAY-2001 by: SMJ
                                                    A0011038 LIST
                                                  A0011056/A0010028

(415) 882-1663                                                EDISON SOURCE
                                                              955 OVERLAND COURT
Carl K. Oshiro                                                SAN DIMAS CA 91773
Attorney At Law                                               (909) 450-6035
CSBRT/CSBA                                                    jsilva@edisonenterprises.com
100 FIRST STREET, SUITE 2540
SAN FRANCISCO CA 94105                                        Susan A. Huse
(415) 927-0158                                                Research Analyst
oshirock@pacbell.net                                          EES CONSULTING, INC.
For: CALIFORNIA SMALL BUSINESS ASSOCIATION AND                12011 BEL-RED ROAD, SUITE 200
CALIFORNIA SMALL BUSINESS ROUNDTABLE                          BELLEVUE WA 98005-2471
                                                              (425) 452-9200
Nicole A. Tutt                                                huse@eesconsulting.com
DUANE MORRIS & HECKSCHER
100 SPEAR STREET, SUITE 1500                                  Jeffrey D. Harris
SAN FRANCISCO CA 94105                                        Attorney At Law
(415) 371-2200                                                ELLISON & SCHNEIDER
natutt@duanemorris.com                                        2015 H STREET
                                                              SACRAMENTO CA 95814-3105
Joseph M. Paul                                                (916) 447-2166
DYNEGY MARKETING & TRADE                                      jdh@eslawfirm.com
5976 WEST LAS POSITAS BLVD., STE. 200                         For: Sacramento Municipal Utility District
PLEASANTON CA 94588
(925) 469-2314                                                Gary B. Ackerman
joe.paul@dynegy.com                                           FOOTHILL SERVICES, INC.
                                                              340 AUGUST CIRCLE
                                                              MENLO PARK CA 94025
                                                              foothill@lmi.net
                                                              For: Western Power Trading Forum



Robert D. Schasel                                             Karen Lindh
FRITO-LAY, INC.                                               LINDH & ASSOCIATES
7701 LEGACY DRIVE (4C-101)                                    7909 WALERGA ROAD, ROOM 112, PMB 119
PLANO TX 75024-4099                                           ANTELOPE CA 95843
(972) 334-7000                                                (916) 729-1562
robert.d.schasel@fritolay.com                                 karen@klindh.com
                                                              For: California Manufacturers Assn.
H. Bradley Donovan
Senior Vice President                                         Richard J. Mccann
GEORGE WEISS ASSOCIATES, INC.                                 M.CUBED
660 MADISON AVENUE, 16TH FLOOR                                2655 PORTAGE BAY, SUITE 3
NEW YORK NY 10021-8405                                        DAVIS CA 95616
(212) 415-4567                                                (530) 757-6363
hbd@gweiss.com                                                rmccann@cal.net

Douglas E. Davie                                              Candace A. Younger
HENWOOD ENERGY SERVICES, INC.                                 MANATT, PHELPS & PHILLIPS, LLP
2710 GATEWAY OAKS DRIVE, STE. 300 NORTH                       11355 WEST OLYMPIC BOULEVARD
SACRAMENTO CA 95833                                           LOS ANGELES CA 90064
(916) 569-0985                                                (310) 312-4000
ddavie@hesinet.com                                            cyounger@manatt.com




                                                     - 16 -
                                    ************ SERVICE LIST ***********
                                     Last Update on 04-MAY-2001 by: SMJ
                                                A0011038 LIST
                                              A0011056/A0010028

Jeffrey D. Schlichting                                    Randall W. Keen
HMH RESOURCES, INC.                                       MANATT, PHELPS & PHILLIPS, LLP
100 LARKSPUR LANDING, SUITE 213                           11355 WEST OLYMPIC BLVD.
LARKSPUR CA 94939                                         LOS ANGELES CA 90064
(415) 289-4080                                            (310) 312-4000
jeff@hmhresources.com                                     rkeen@manatt.com

Joelle Ogg                                                Linda R. Beck
JOHN & HENGERER                                           MCDONOUGH, HOLLAND & ALLEN
1200 17TH STREET, NW, STE 600                             1999 HARRISON STREET, STE 1300
WASHINGTON DC 20036                                       OAKLAND CA 94612
(202) 429-8812                                            (510) 839-9104
jogg@jhenergy.com                                         For: City of Paso Robles

Joaquin Herrera                                           Christopher J. Mayer
L. A. COUNTY PUBLIC WORKS                                 MODESTO IRRIGATION DISTRICT
TRAFFIC AND LIGHTING DIVISION                             PO BOX 4060
PO BOX 1460                                               MODESTO CA 95352-4060
ALHAMBRA CA 91802-1460                                    (209) 526-7430
jherrera@dpw.co.la.ca.us                                  chrism@mid.org
                                                          For: MODESTO IRRIGATION DISTRICT (MID)
Ralph Smith
LARKIN & ASSOCIATES, INC.                                 Robert B. Weisenmiller
15728 FARMINGTON ROAD                                     MRW & ASSOCIATES
LIVONIA MI 48154                                          1999 HARRISON STREET, SUITE 1440
(734) 522-3420                                            OAKLAND CA 94612-3517
ad046@detroit.freenet.org                                 (510) 834-1999
For: Larkin & Associates, Inc.                            rbw@mrwassoc.com
                                                          For: MRW & Associaes


Gary Herbert                                              Bruce Bowen
MSDW                                                      Mailcode B10a
ONE TOWER BRIDGE, 11TH FLOOR                              PACIFIC GAS AND ELECTRIC COMPANY
WEST CONSHOHOCKEN PA 19428                                PO BOX 770000
(610) 940-4524                                            SAN FRANCISCO CA 94177
gerhordt.herbert@msdw.com                                 brb3@pge.com

Melanie Gillette                                          Dan Pease
NAVIGANT CONSULTING INC                                   PACIFIC GAS AND ELECTRIC COMPANY
3100 ZINFANDEL DRIVE, SUITE 600                           MAILCODE B10B
RANCHO CARDOVA CA 95670                                   PO BOX 70000
(916) 852-1300                                            SAN FRANCISCO CA 94177
melanie_gillette@rmiinc.com                               drp6@pge.com

Kay Davoodi                                               Ed Lucha
NAVY RATE INTERVENTION OFFICE                             PACIFIC GAS AND ELECTRIC COMPANY
WASHINGTON NAVY YARD                                      MAIL CODE: B9A
1314 HARWOOD STREET SE                                    PO BOX 770000
WASHINGTON NAVY YARD DC 20374-5018                        SAN FRANCISCO CA 94177
(202) 685-0130                                            (415) 973-3872
DavoodiKR@efaches.navfac.navy.mil                         ell5@pge.com
For: Navy Rate Intervention
                                                          Janice Frazier-Hampton
Martin Mattes                                             PACIFIC GAS AND ELECTRIC COMPANY



                                                 - 17 -
                               ************ SERVICE LIST ***********
                                Last Update on 04-MAY-2001 by: SMJ
                                           A0011038 LIST
                                         A0011056/A0010028

Attorney At Law                                      MAIL CODE B9A
NOSSAMAN GUTHNER KNOX & ELLIOTT, LLP                 PO BOX 770000
50 CALIFORNIA STREET, 34TH FLOOR                     SAN FRANCISCO CA 94177
SAN FRANCISCO CA 94111-4799                          (415) 973-2254
(415) 438-7273                                       jyf1@pge.com
mmattes@nossaman.com
                                                     Joe Migocki
Eve Mitchell                                         PACIFIC GAS AND ELECTRIC COMPANY
OAKLAND TRIBUNE                                      77 BEALE STREET, MAIL CODE B9A
401 13TH ST.                                         SAN FRANCISCO CA 94105-1890
OAKLAND CA 94612                                     (415) 973-1332
(510) 208-6474                                       j3m9@pge.com
emitchel@angnewspapers.com
                                                     Niels Kjellund
Jonathan Jacobs                                      PACIFIC GAS AND ELECTRIC COMPANY
PA CONSULTING GROUP                                  MAIL CODE 859A
75 NOVA DRIVE                                        PO BOX 770000
PIEDMONT CA 94610-1037                               SAN FRANCISCO CA 94177
(510) 654-9495                                       NXK2@pge.com
jon.jacobs@paconsulting.com
For: PA CONSULTING GROUP                             Roger J. Peters
                                                     PACIFIC GAS AND ELECTRIC COMPANY
Gail L. Slocum                                       MAIL CODE B30A
Attorney At Law                                      PO BOX 7442
PACIFIC GAS AND ELECTRIC CO.                         SAN FRANCISCO CA 94120
77 BEALE ST. RM 3143                                 RJP2@pge.com
SAN FRANCISCO CA 94105
(415) 973-6583
glsg@pge.com



Ron Helgens                                          Michael Bazeley
PACIFIC GAS AND ELECTRIC COMPANY                     SAN JOSE MERCURY NEWS
MAIL CODE B9A                                        111 ELLIS STREET, 3RD FLOOR
PO BOX 770000                                        SAN FRANCISCO CA 94102
SAN FRANCISCO CA 94177                               (415) 434-1018
(415) 973-7524                                       mbazeley@sjmercury.com
rrh3@pge.com
                                                     James E. Hay
Roxanne Piccillo                                     SEMPRA ENERGY
PACIFIC GAS AND ELECTRIC COMPANY                     101 ASH STREET - H.Q. 14B
MAILCODE B10B                                        SAN DIEGO CA 92101-3017
PO BOX 70000                                         (619) 696-2141
SAN FRANCISCO CA 94177                               jhay@sempra.com
rtp1@pge.com                                         For: Sempra

George A. Perrault                                   Kimberly Freeman
1813 FAYMONT AVENUE                                  SEMPRA ENERGY
MANHATTAN BEACH CA 90266                             601 VAN NESS AVENUE, SUITE 2060
(310) 379-0901                                       SAN FRANCISCO CA 94102
georgeperrault@msn.com                               (415) 202-9983
                                                     Kfreeman@Sempra.com
Henry Moore




                                            - 18 -
                                             ************ SERVICE LIST ***********
                                              Last Update on 04-MAY-2001 by: SMJ
                                                         A0011038 LIST
                                                       A0011056/A0010028

PETERSON RISK CONSULTING, LLC                                      Leslie Katz 4/1
1 MARKET STREET, SUITE 1300                                        Regional Vp-Regulatory Affairs
SAN FRANCISCO CA 94105                                             SEMPRA ENERGY
(415) 393-0588                                                     601 VAN NESS AVENUE, SUITE 2060
hwmoore@pcit.com                                                   SAN FRANCISCO CA 94102
                                                                   (415) 202-9986
Jean Pierre Batmale                                                lkatz@sempra.com
REALENERGY                                                         For: sempra
1900 AVENUE OF THE STARS, 755
LOS ANGELES CA 90067                                               Lynn G. Van Wagenen
(310) 203-2976                                                     Regulatory Affairs Project Manager
jpbatmale@realenergy.com                                           SEMPRA ENERGY
                                                                   101 ASH STREET, ROOM 10A
Carrie Peyton                                                      SAN DIEGO CA 92101
SACRAMENTO BEE                                                     (619) 696-4055
PO BOX 15779                                                       LvanWagenen@sempra.com
SACRAMENTO CA 95852                                                For: Sempra Energy
(916) 321-1086
cpeyton@sacbee.com                                                 G. Darryl Reed
                                                                   SIDLEY & AUSTIN
Tim Haines                                                         10 S. DEARBORN
SACRAMENTO MUNICIPAL UTILITY DISTRICT                              CHICAGO IL 60603
PO BOX 15830                                                       (312) 853-7766
SACRAMENTO CA 95852-1830                                           gdreed@sidley.com
(916) 732-6342                                                     For: SIDLEY & AUSTIN
thaines@smud.org
For: Sacramento Municipal Utility District                         Bruce Foster
                                                                   Regulatory Affairs
                                                                   SOUTHERN CALIFORNIA EDISON COMPANY
                                                                   601 VAN NESS AVENUE, SUITE 2040
                                                                   SAN FRANCISCO CA 94102
                                                                   (415) 775-1856
                                                                   fosterbc@sce.com


Frank J. Cooley                                                    Bill C. Wells
SOUTHERN CALIFORNIA EDISON COMPANY                                 Lt. Col.
2244 WALNUT GROVE AVENUE                                           TYNDALL AFB
ROSEMEAD CA 91770                                                  139 BARNES DRIVE, SUITE 1
(626) 302-3115                                                     TYNDALL AFB FL 32403-5319
frank.cooley@sce.com                                               (850) 283-6347
For: SOUTHERN CALIFORNIA EDISON COMPANY (SCE)                      bill.wells@afcesa.af.mil
                                                                   For: AIR FORCE LEGAL SERVICES AGENCY
Peter S. Goeddel
SOUTHERN CALIFORNIA EDISON COMPANY                                 Sam Wise
PO BOX 800                                                         4045 PALOS VERDES DR. NORTH
2244 WALNUT GROVE AVENUE, SUITE 321                                ROLLING HILLS ESTATES CA 90274
ROSEMEAD CA 91770                                                  (310) 377-1577
(626) 302-3104
For: SOUTHERN CALIFORNIA EDISON

Stephen E. Pickett
RONALD L. OLSON
Attorney At Law
SOUTHERN CALIFORNIA EDISON COMPANY



                                                          - 19 -
                                 ************ SERVICE LIST ***********
                                  Last Update on 04-MAY-2001 by: SMJ
                                             A0011038 LIST
                                           A0011056/A0010028

2244 WALNUT GROVE AVENUE
ROSEMEAD CA 91770
(626) 302-1903
picketse@sce.com

Charles C. Read
Attorney At Law
STEPTOE & JOHNSON, LLP
1330 CONNECTICUT AVENUE, N.W.
WASHINGTON DC 20036
(202) 429-6244
cread@steptoe.com

Peter Fox-Penner, Ph.D.
THE BRATTLE GROUP
1133 20TH STREET NW, SUITE 800
WASHINGTON DC 20036
(202) 955-5050
peter_fox-penner@brattle.com

Tony Wetzel
THERMO ECOTEK CORPORATION
1100 MELODY LANE, SUITE 206
ROSEVILLE CA 95678
(916) 773-2940
twetzel@thermoecotek.com
For: THERMO ECOTEK CORPORATION

Fred Wesley Monier
TURLOCK IRRIGATION DISTRICT
PO BOX 949
333 EAST CANAL DRIVE
TURLOCK CA 95381-0949
(209) 883-8321
fwmonier@tid.org

                                    (END OF APPENDIX A)




                                              - 20 -
      APPENDIX B


PACIFIC GAS AND ELECTRIC
    PROPOSED RATES
                                                                Billing
                                                             Determinants           Current       Total Current        Revenue           New Total           New Rates
Customer Group                                                  (kWh)             Rate ($/kWh)     Revenue             Increase          Revenue               $/kWh



E-1       Energy                     Smr    Tier 1            6,743,661,372           $0.12589        $848,959,530
                                            Tier 2            4,786,100,707           $0.14321        $685,417,482
                                     Winter Tier 1            7,085,095,391           $0.12589        $891,942,659
                                            Tier 2            4,752,592,916           $0.14321        $680,618,831

          0% to 100% Baseline                Tier 1          13,828,756,763           $0.12589       $1,740,902,189                        $1,740,902,189       $0.12589
          100% to 130% Baseline              Tier 2           2,533,865,376           $0.14321        $362,874,860                          $362,874,860        $0.14321
          130% to 200% Baseline              Tier 3           3,686,054,464           $0.14321        $527,879,860       $105,575,972       $633,455,832        $0.17185
          200% to 300% Baseline              Tier 4           2,098,985,131           $0.14321        $300,595,661       $120,238,264       $420,833,925        $0.20049
          Over 300% Baseline                 Tier 5           1,219,788,651           $0.14321        $174,685,933       $190,428,430       $365,114,363        $0.29933

          Discounts, Credits & Nonalloc. Revenue                                                    ($3,398,220,915)                        ($291,282,413)

          Total                                              23,367,450,386 kWh                      $2,815,656,090       $416,242,666     $3,231,898,756

EL-1      Energy                     Smr    Tier 1              728,352,160           $0.09812         $71,465,914                           $71,465,914        $0.09812
                                            Tier 2              260,969,916           $0.11284         $29,447,845                           $29,447,845        $0.11284
                                     Winter Tier 1              693,690,541           $0.09812         $68,064,916                           $68,064,916        $0.09812
                                            Tier 2              239,382,784           $0.11284         $27,011,953                           $27,011,953        $0.11284

          0% to 100% Baseline                Tier 1           1,422,042,701                                       $0
          100% to 200% Baseline              Tier 2             400,083,059                                       $0
          n/a                                Tier 3                     -                                         $0
          200% to 300% Baseline              Tier 4              74,567,902                                       $0
          Over 300% Baseline                 Tier 5              25,701,739                                       $0

          Discounts, Credits & Nonalloc. Revenue                                                       ($27,870,617)                         ($27,870,617)

          Total                                               1,922,395,400 kWh                       $168,120,011                 $0        $168,120,011

E-7       Energy                     Smr     On Peak             85,099,696           $0.32524         $27,677,825        $10,211,963        $37,889,788        $0.44524
                                             Off Peak           481,411,229           $0.09515         $45,806,278        $18,819,249        $64,625,527        $0.13424
                                     Wtr     Part Peak           94,181,097           $0.12636         $11,900,723         $4,709,055        $16,609,778        $0.17636
                                             Off Peak           538,319,039           $0.09851         $53,029,808        $21,043,879        $74,073,688        $0.13760

                                     Smr     Tier 1 Credit      228,479,417          ($0.01559)         ($3,561,537)      ($9,139,177)       ($12,700,714)     ($0.05559)
                                     Smr     Tier 2 Credit       61,170,261           $0.00000                   $0       ($2,446,810)        ($2,446,810)     ($0.04000)
                                     Wtr     Tier 1 Credit      277,608,105          ($0.01559)         ($4,327,355)     ($11,104,324)       ($15,431,679)     ($0.05559)
                                     Wtr     Tier 2 Credit       68,295,591           $0.00000                   $0       ($2,731,824)        ($2,731,824)     ($0.04000)

          0% to 100% Baseline                Tier 1             506,087,522
          100% to 130% Baseline              Tier 2             129,465,853
          130% to 200% Baseline              Tier 3             229,081,544
          200% to 300% Baseline              Tier 4             184,012,818
          Over 300% Baseline                 Tier 5             150,363,324
          Discounts, Credits & Nonalloc. Revenue                                                       ($8,301,108)                           ($8,301,108)
          Total                                               1,199,011,059 kWh                       $122,224,635         $29,362,011       $151,586,646

EL-7      Energy                     Smr     On Peak              1,140,406           $0.31524            $359,502                              $359,502        $0.31524
                                             Off Peak             5,395,901           $0.08515            $459,461                              $459,461        $0.08515
                                     Wtr     On Peak              1,141,183           $0.11636            $132,788                              $132,788        $0.11636
                                             Off Peak             6,168,357           $0.08851            $545,961                              $545,961        $0.08851

                                     Smr     Tier 1 Credit        3,649,646          ($0.01732)            ($63,212)                             ($63,212)     ($0.01732)
                                     Wtr     Tier 1 Credit        4,401,935          ($0.01732)            ($76,242)                             ($76,242)     ($0.01732)

          0% to 100% Baseline                Tier 1               8,050,526
          100% to 200% Baseline              Tier 2               1,560,538
          n/a                                Tier 3                     -
          200% to 300% Baseline              Tier 4               2,713,368
          Over 300% Baseline                 Tier 5               1,521,415

          Discounts, Credits & Nonalloc. Revenue                                                           ($95,859)                             ($95,859)

          Total                                                  13,845,847 kWh                          $1,262,400                $0          $1,262,400
                                                                                                                                               $1,262,400

E-8       Energy                     Smr                      1,108,352,630           $0.13017        $144,274,262                          $144,274,262        $0.13017
        APPENDIX C


SOUTHERN CALIFORNIA EDISON
     PROPOSED RATES
                                                                                                             Revenue     New Total
                                                             2001 Sales     Current Total    Total Revenue   Increase    Revenue
                      Rate Group                              Forecast         Rate              ($MM)        ($MM)       ($MM)       New Rate


Residential
 NON-CARE
               Energy Charges - ¢/kWh
                                                 Baseline       11,799.1             13.01       $1,534.9                  $1,534.9       13.01
                                       130 % of Baseline         2,372.5             15.16         $359.6                    $359.6       15.16
                                      130% - 200% of BL          3,615.3             15.16         $548.0        $65.5       $613.5       16.97
                                      200% - 300% of BL            2392.4            15.16         $362.6       $108.5       $471.1       19.69
                                        Over 300% of BL          2,082.5             15.16         $315.6       $189.3       $504.9       24.25
                     Fixed Charges
                    Single Family Basic Charge - $/month      21,027,996              1.00          $21.0                     $21.0
                    Multi. Family Basic Charge - $/month      18,782,674              0.76          $14.3                     $14.3
                                       Total NON-CARE           22,261.8            14.18        $3,156.1       $363.3     $3,519.4      15.81


 CARE
               Energy Charges - ¢/kWh
                                                 Baseline        1,837.9             10.14         $186.4                    $186.4       10.14
                                       130 % of Baseline           278.5             11.97          $33.3                     $33.3       11.97
                                      130% - 200% of BL            331.0             11.97          $39.6                     $39.6       11.97
                                        Over 200% of BL            209.1             11.97          $25.0                     $25.0       11.97
                     Fixed Charges
                    Single Family Basic Charge - $/month       3,160,669              0.85           $2.7                      $2.7
                    Multi. Family Basic Charge - $/month       2,823,180              0.65           $1.8                      $1.8
                                            Total CARE           2,656.5            10.87          $288.9         $0.0       $288.9      10.87


Total Residential                                               24,918.4            13.83        $3,445.0       $363.3     $3,808.3      15.28


Small & Med. Commercial
 GS-1
               Energy Charges - ¢/kWh
                                                 Summer          1,767.7             12.76         $225.6       $155.7       $381.2       21.57
                                                   Winter        3,184.2             12.76         $406.3        $66.7       $473.0       14.86
                     Fixed Charges
                             Customer Charge - $/month         5,127,373            14.60           $74.9                     $74.9
                                              Total GS-1         4,952.0            14.27          $706.7       $222.4       $929.1      18.76


 TC-1
               Energy Charges - ¢/kWh
                                                  Energy           186.2              7.49          $13.9         $8.4        $22.3       11.98
                     Fixed Charges
                             Customer Charge - $/month           156,930            10.65            $1.7                      $1.7
                                               Total TC-1          186.2              8.38          $15.6         $8.4        $24.0      12.88


 GS-2
               Energy Charges - ¢/kWh
                                                  1st Tier      19,565.6              8.69       $1,700.6       $587.0     $2,287.6       11.69
                                                 2nd Tier        4,902.5              5.39         $264.3       $511.8       $776.1       15.83
                     Fixed Charges
                             Customer Charge - $/month         1,413,115            60.30           $85.2                     $85.2
                                   Facility-Related - $/kW        80,039              5.40         $432.2                    $432.2
                                     Time-Related - $/kW          27,521              7.75         $213.3                    $213.3
                                              Total GS-2        24,468.1            11.02        $2,695.6     $1,098.8     $3,794.4      15.51


 TOU-GS-2 (Option B)
               Energy Charges - ¢/kWh
                                      Summer - On Peak              44.3             15.90           $7.0         $6.5        $13.5       30.54
                                                Mid Peak            69.4              7.61           $5.3         $3.1         $8.4       12.10
                                                 Off-Peak          142.1              5.27           $7.5         $5.0        $12.4        8.76
                                       Winter - Mid Peak           201.5              8.81          $17.8         $9.0        $26.8       13.30
                                                 Off-Peak          308.1              5.27          $16.2        $10.8        $27.0        8.76
                     Fixed Charges
                             Customer Charge - $/month            27,723            79.25            $2.2                      $2.2
                                   Facility-Related - $/kW         2,737              5.40          $14.8                     $14.8
                         Time-Related (On Peak) - $/kW               777            16.40           $12.7                     $12.7
                         Time-Related (Mid Peak) - $/kW              884              2.45           $2.2                      $2.2
                                        Total TOUGS-2B             765.4            11.20           $85.7        $34.4       $120.1      15.69


Total Small & Med. Commercial                                   30,371.5            11.54        $3,503.7     $1,363.9     $4,867.6      16.03
Large Power
 TOU-8-Sec
                 Current Structure
                                     Summer - On Peak        716.5     10.49     $75.1      $76.6     $151.7    21.17
                                              Mid Peak       949.3      6.99     $66.3      $42.6     $109.0    11.48
                                                Off-Peak    1,433.7     4.81     $69.0      $50.0     $119.0     8.30
                                      Winter - Mid Peak     2,785.3     8.34    $232.2     $125.1     $357.3    12.83
                                                Off-Peak    3,005.7     4.93    $148.0     $104.9     $252.9     8.42
                   Fixed Charges
                           Customer Charge - $/month        29,937    298.65      $8.9                  $8.9
                                Facility-Related - $/kW     22,038      6.40    $141.0                $141.0
                        Time-Related (On Peak) - $/kW        7,213     17.55    $126.6                $126.6
                       Time-Related (Mid Peak) - $/kW        7,458      2.80     $20.9                 $20.9
                                      Total TOU-8-Sec       8,890.5     9.99    $888.1     $399.2    $1,287.3   14.48


 TOU-8-Pri (Includes special contracts sales)
              Energy Charges - ¢/kWh
                                     Summer - On Peak        542.1     10.42     $56.5      $65.6     $122.1    22.52
                                              Mid Peak       768.4      6.85     $52.6      $34.5      $87.1    11.34
                                                Off-Peak    1,324.0     4.76     $63.0      $46.2     $109.2     8.25
                                      Winter - Mid Peak     2,189.1     8.07    $176.7      $98.3     $275.0    12.56
                                                Off-Peak    2,799.9     4.87    $136.5      $97.7     $234.2     8.36
                   Fixed Charges
                           Customer Charge - $/month        10,438    299.00      $3.1                  $3.1
                                Facility-Related - $/kW     15,833      6.60    $104.5                $104.5
                        Time-Related (On Peak) - $/kW        5,107     17.95     $91.7                 $91.7
                       Time-Related (Mid Peak) - $/kW        5,404      2.70     $14.6                 $14.6
                                       Total TOU-8-Pri      7,623.3     9.17    $699.1     $342.3    $1,041.5   13.66


 TOU-8-Sub (Includes special contracts sales)
              Energy Charges - ¢/kWh
                                     Summer - On Peak        481.2      8.40     $40.4      $70.6     $111.0    23.07
                                              Mid Peak       752.9      6.05     $45.6      $33.8      $79.4    10.54
                                                Off-Peak    1,540.0     4.76     $73.2      $53.8     $127.0     8.25
                                      Winter - Mid Peak     2,196.8     7.09    $155.8      $98.7     $254.5    11.58
                                                Off-Peak    3,360.2     4.87    $163.7     $117.3     $281.0     8.36
                   Fixed Charges
                           Customer Charge - $/month         2,226    349.45      $0.8                  $0.8
                                Facility-Related - $/kW     13,879      0.65      $9.0                  $9.0
                        Time-Related (On Peak) - $/kW        3,621     16.15     $58.5                 $58.5
                       Time-Related (Mid Peak) - $/kW        4,118      2.45     $10.1                 $10.1
                                      Total TOU-8-Sub       8,331.1     6.69    $557.1     $374.1     $931.2    11.18


                                   Total Large Power       24,844.9     8.63   $2,144.3   $1,115.7   $3,260.0   13.12
Agriculture & Pumping
 PA-1
               Energy Charges - ¢/kWh                          679.4             10.17     $69.1      $28.2       $97.3    14.33
                   Fixed Charges
                              Customer Charge - $/month      277,602             17.65      $4.9                    $4.9
                                  Connected Load - $/HP        9,795              2.05     $20.1                  $20.1
                                              Total PA-1       679.4             13.85     $94.1      $28.2      $122.3    18.00


 PA-2
               Energy Charges - ¢/kWh
                                                  1st Tier     452.4              9.12     $41.3       $4.5       $45.8    10.12
                                                 2nd Tier      257.0              6.09     $15.7      $15.9       $31.6    12.30
                   Fixed Charges
                              Customer Charge - $/month       24,243             30.35      $0.7                    $0.7
                                   Facility-Related - $/kW     2,220              2.25      $5.0                    $5.0
                                     Time-Related - $/kW         754              7.40      $5.6                    $5.6
                                              Total PA-2       709.4              9.62      68.2      $20.5       $88.7    12.51


 AG-TOU (Option B)
               Energy Charges - ¢/kWh
                                      Summer - On Peak         104.7             12.23     $12.8       $8.4       $21.2    20.27
                                                Mid Peak       138.7              8.26     $11.5       $3.8       $15.3    11.03
                                                 Off-Peak      209.5              4.95     $10.4       $3.7       $14.1     6.72
                                       Winter - Mid Peak       317.5              9.50     $30.2       $8.8       $39.0    12.27
                                                 Off-Peak      342.6              4.95     $17.0       $6.1       $23.0     6.72
                   Fixed Charges
                              Customer Charge - $/month       44,002             42.80      $1.9                    $1.9
                                   Facility-Related - $/kW     3,487              2.85      $9.9                    $9.9
                           Time-Related (On Peak) - $/kW       1,016              9.00      $9.1                    $9.1
                               Total AG-TOU (Option B)        1,112.9             9.23    $102.7      $30.8      $133.5    12.00


 TOU-PA-5
               Energy Charges - ¢/kWh
                                      Summer - On Peak          43.0              8.95      $3.8       $4.4         $8.2   19.11
                                                Mid Peak        61.0              6.14      $3.7       $1.5         $5.2    8.58
                                                 Off-Peak      105.1              5.28      $5.6       $1.5         $7.1    6.72
                                       Winter - Mid Peak       177.7              7.02     $12.5       $4.3       $16.8     9.46
                                                 Off-Peak      227.4              5.92     $13.5       $3.3       $16.7     7.36
                   Fixed Charges
                              Customer Charge - $/month       13,465             40.70      $0.5                    $0.5
                                   Facility-Related - $/kW     1,946              2.85      $5.5                    $5.5
                           Time-Related (On Peak) - $/kW         521              9.00      $4.7                    $4.7
                                         Total TOU-PA-5        614.1              8.12     $49.9      $15.0       $64.8    10.56


                            Total Agriculture & Pumping       3,115.9            10.11    $314.9      $94.5      $409.4    13.14


Street and Area Lighting
 Street Light Summary
               Energy Charges - ¢/kWh
                                         AllNight Service      529.2              6.04     $32.0      $23.8       $55.7    10.53
                                        Mid Night Service         0.1             6.37      $0.0       $0.0         $0.0   10.86
                   Fixed Charges
                              Customer Charge - $/month      117,906 $/month-variable       $2.3                    $2.3
                                   Estimated # of Lamps      694,921 $/lamp-variable       $43.9                  $43.9
                                       Total Street Light      529.3             14.77     $78.2      $23.8      $101.9    19.26


TOTAL SYSTEM                                                 83,780.0            11.32   $9,486.0   $2,961.2   $12,447.2   14.86

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:10
posted:9/24/2011
language:English
pages:109