IV. CONCLUSION

SoCalGas, SDG&E, and other parties have been highly responsive to the Commission's direction in this proceeding. However, recent events lead us to conclude that the centerpiece of this investigation, the unbundling of intrastate transmission and the implementation of a system of firm, tradable intrastate transmission rights, should be delayed. This unbundling is the basis of the CS, and we cannot approve it. We do not, however, wish to commit to paralysis until 2006, as the PI would have us do. Accordingly, we believe Californians are better served at this juncture by the adoption with modifications of the IS.

We are convinced that the IS generally balances the various interests at stake for the period of the settlement. Thus, we find that the IS, as modified, is reasonable in light of the whole record, consistent with the law and in the public interest.

Based on the record in R.98-01-011 and I.99-07-003, we also find that now is the time for other gas industry reforms. These include the unbundling of core interstate capacity, the elimination of core subscription and the cap on core aggregation programs, the reduction of core aggregation program threshold, and the allowance of billing credits for ESP consolidated billing in return for taking on the responsibility of sending utility information and the mandated customer inserts.