COMMENTS

A draft alternate Resolution was mailed to parties in accordance with Public Utilities Code Section 311(g) on October 6, 2000. Comments were received from SCE. SCE states that since the draft alternate provides acceptable relief, SCE agrees that the draft alternate, with minor modifications, should be adopted. As a result of these comments, a number of changes, corrections, and clarifications have been made in the draft alternate Resolution.

A revised draft alternate Resolution was mailed to all parties on October 23, 2000. Comments were received from SCE on November 8, 2000. SCE requests three modifications to the revised draft alternate Resolution. First, SCE believes the revised draft alternate Resolution inappropriately deletes EDR customer's opportunity to opt-out of their agreements without paying liquidated damages, and requests that the deleted language be restored. Second, concerning the closure of EDRs to new customers, SCE requests the revised draft alternate provide that SCE may propose revised EDRs that incorporate elements of demand responsiveness. Third, SCE renews its objection to the revised draft alternate Resolution's ratification of the Energy Division Director's suspension of the advice letter. We considered these comments in adopting Resolution E-3707, and made changes as necessary.