PROTESTS

On July 21, 2000, the Commission's Office of Ratepayer Advocates (ORA) protested Advice Letter 1461-E. ORA claims that SCE has violated Commission procedures by unilaterally reducing EDR customer rates and asking for retroactive approval. ORA believes that EDR customers signed a contract and should be held to that contract. ORA is concerned that if the proposed change is approved, other customers will be forced to make up the lost revenues.

ORA recommends, in order of preference, that we:

1. Deny the advice letter, and defer EDR issues to the Post Transition Rate Design Application (A.) 00-01-009.

2. Enforce the current minimum charge, by placing the difference between the higher EDR rate and the OAT in a memorandum account subject to refund pending a decision in A.00-01-009.

3. Order EDR rates capped at OAT rates for SCE bundled service customers who apply for an Hourly PX Pricing Option.

On July 28, 2000, SCE responded to ORA's protest. SCE believes ORA's recommendations are flawed, and do not address inequities to EDR customers. SCE is concerned that waiting for a decision in A.00-01-009 will involve months of delay while customers need relief now. SCE says EDR customers at least need a ruling so that each customer may decide whether or not to terminate its EDR agreement. Further, SCE does not support ORA's recommendation for the Hourly PX Price option. SCE believes the Hourly PX Price option would require that the tariff be revised, customers would need to purchase hourly meters, customers should not be forced to accept this option, and this option will not create demand responsiveness.