10. Comments on Draft Decision

On September 27, 2005, the draft decision was filed and served on parties in accordance with Pub. Util. Code § 311(g)(1) and Rule 77.7 of the Commission's Rules of Practice and Procedure. Comments were filed on October 17, 2005, and replies were filed on October 24, 2005. We have made several changes to the draft decision in response to the comments. Among the more significant revisions are the following:

· Section 4.1 - We have extended the generator obligation to real time.

· Section 4.4 - We have identified essential elements of a contract that
would qualify to satisfy RA obligations.


· Section 7.4 - We have changed the grandfather date from September 27 to October 27, 2005 and modified the provisions for phasing out the extent to which LD contracts qualify for RAR purposes during 2006, 2007, and 2008.