XII. Comments on the Proposed Decision

The Proposed Decision of ALJ Pulsifer was mailed to parties on January 8, 2002. Pursuant to Section 311(d), the Commission will not take action on this matter for 30 days. Consistent with Rule 77.2, comments are due on the proposed decision within 20 days of its date of mailing. No extensions of this comment period will be granted, nor will any late-filed comments be accepted. Pursuant to Rule 87, we will reduce the reply comment period provided for in Rule 77.5 to four days. Because the fifth day following opening comments falls on a weekend, good cause exists for shortening the reply period to four days to provide sufficient time for review of reply comments. Therefore, comments must be filed and served by January 28 and reply comments must be filed and served by February 1. Comments and reply comments should be served on the ALJ electronically at trp@cpuc.ca.gov.

Findings of Fact

1. AB1X, among other things, authorized DWR to purchase power on behalf of retail customers in the service territories of PG&E, SCE, and SDG&E.

2. AB1X authorized DWR to determine its revenue requirement sufficient to recover its procurement-related costs, and required the Commission to implement the cost recovery of DWR's revenue requirement.

3. Timely implementation of DWR's revenue requirement cost recovery is necessary to support the sale of bonds as prescribed under California Water Code Section 80130.

4. Up until the present time, DWR has been relying on interim borrowings as its funding source pending the sale of bonds, currently expected to occur in the second quarter of 2002.

5. DWR's revenue requirement represents the amounts to be collected from customers in the service territories of the three major electric utilities covering the 2001-2002 time period, after deducting the proceeds from interim loans.

6. DWR submitted an initial estimated revenue requirement on May 2, 2001, covering the 18 months from January 2001 to May 31, 2002.

7. DWR provided the Commission with an updated revenue requirement on July 23, 2001, covering 24 months ending December 2002, and provided further updates on August 7, October 19, and November 5, 2001,.

8. Parties of record were provided notice and an opportunity to review DWR's revenue requirement submittals, to participate in technical workshops, and to file comments in response to DWR's submittals.

9. Parties expressed disagreement with various assumptions underlying DWR's revenue requirement, and contested DWR's representation that DWR's costs are "just and reasonable."

10. DWR presents its revenue requirement on an aggregate basis for all three utilities, but defers to the Commission to determine and apply an allocation rationale for assigning the revenue requirement among customers in each service territory

11. In D.01-03-082, the Commission granted a surcharge increase of three-cents per kWh to be collected by SCE and PG&E, prescribing that a portion of that surcharge would be allocated to DWR upon receipt, analysis, and comment on DWR's revenue requirement.

12. In D.01-05-060, the Commission established an initial generation rate component of 6.5 cents/kWh for SDG&E.

13. In D.01-09-059, the Commission provided an interim rate increase to SDG&E to provide for remittance to DWR at 9.02 cents/kWh.

14. DWR forecasts a total revenue requirement to be collected of $10.003 billion, as set forth in Appendix A of this decision, covering the period January 17, 2001 through December 31, 2002.

15. DWR states that it has determined that its revenue requirement is just and reasonable based upon several factors including its competitive solicitation of bids, cost-based recovery, and the true-up provisions of forecast variances that will take place in future adjustments.

16. DWR's revenue requirement includes $5.284 billion in long-term power costs and $9.534 billion for short term purchases procured on behalf of customers in the service territories of the three major electric utilities.

17. DWR's revenue requirement includes $1.102 billion for ancillary service costs incurred by DWR on behalf of customers in the service territories of the three major electric utilities.

18. Pursuant to a FERC Order issued on November 7, 2001, the ISO sent $956 million in invoices to DWR for transactions with third party power suppliers for the period January 17 through July 31, 2001, on behalf of the noncreditworthy entities, PG&E and SCE.

19. The sales that DWR has presented in its revenue requirement model for purposes of computing charges for remittance purposes do not include sales to direct access customers.

20. It is reasonable to implement DWR cost recovery in the form of a discrete amount per kWh sold by DWR to facilitate segregation of DWR funds from those of the utility.

21. DWR's revenue requirement does not include a provision to account for franchise fees associated with power that it sells to utility customers.

22. Unresolved questions remain concerning the rights of municipalities to receive franchise fees on DWR power sales, and the respective obligations of DWR or investor-owned utilities to collect and remit franchise fees on DWR power sales.

23. DWR's revenue requirement is comprised of cost categories as authorized for recovery from utility ratepayers under AB1X, including the costs of long term and short term power contracts, ancillary services, administrative overhead, demand-side management, uncollectibles, and an allowance for leads or lags in cash receipts and disbursements.

24. DWR's revenue requirement is based on forecasts of various costs that may prove to be incorrect over time.

25. The allocation of DWR's revenue requirement as adopted in the ordering paragraphs below results in a revenue responsibility (in dollars and percentages) for PG&E's service territory in the amount of $ 4,765,407,000 (47.6%); for SCE's service territory of $3,674,066,000 (37.7%); and for SDG&E's service territory of $1,563,989,000 (15.6%).

26. The allocation of DWR's revenue requirement as adopted in the ordering paragraphs below results in a uniform cents per kWh charge applicable to billed revenues for PG&E's service territory in the amount of 10.047; for SCE's service territory in the amount of 10.309; and for SDG&E's service territory in the amount of 9.947.

27. The Commission has traditionally recognized the general principle that utility revenues should be allocated among customer classes on the basis of cost causality.

28. Allocation of the DWR revenue requirement is a novel application of the Commission's cost-based ratemaking since it involves allocation across different utility service territories, as opposed to the traditional practice of allocation among customer classes within a single utility service territory.

29. A pro rata allocation of procurement costs on a statewide basis is not inconsistent with cost-based ratemaking principles to the extent that no other objective measure exists to differentiate cost incurrence on more disaggregated basis.

30. The utility-specific adjustments proposed by TURN more accurately reflect cost causality, namely, (a) adjustment of retail net short to exclude WAPA load for PG&E; (b) removal of the effects of PG&E's Helms facility; and (c) adjustment for each utility's self-provided ancillary services.

31. The allocation of revenue requirements based upon cost of service provides for an equitable and economically efficient matching of cost responsibility with service rendered.

32. The allocation approaches proposed by SDG&E and SCE seek to apply a cost-based approach by relating the costs of specific supply sources with specific utility service territories in geographical proximity.

33. The SCE and SDG&E allocations segregate energy sources on a geographic basis, with sources transmitted over facilities (a) north of Path 15 being allocated to PG&E customers, and (b) south of Path 15 being allocated to SCE and SDG&E customers.

34. SDG&E's allocation approach separately allocates both long term and short term energy purchases on a geographically differentiated basis.

35. SCE's allocation approach allocates only short term energy purchases on a regionally differentiated basis, but treats long term purchases as a homogeneous cost to be allocated on a pro rata statewide basis in relation to the net short position of each utility.

36. DWR purchased only short term power during the first few months of 2001, then began procuring long term power in April of 2001.

37. DWR's short term purchases had different terms than long term contracts, but served a similar purpose in supplying the joint needs of customers in the service territories of the three major utilities.

38. DWR's contracts have served to stabilize the power market, to the benefit of all California ratepayers.

39. Most of the DWR's costs and cash reserves related to its power purchase program are not specific to any single utility.

40. DWR generation is not necessarily dedicated to any particular off system sales customers, and disproportionate assignment of DWR revenues of a geographical basis would be arbitrary.

41. SCE fails to provide an objective criterion to justify applying different allocation approaches between long term fixed price contracts and supply sources of 90 days or less.

42. DWR did not procure separate portfolios of supplies for each of the three utility service territories such that specific supply sources could be exclusively identified with service to any one particular utility service territory.

43. DWR's stated procurement policy was to use power purchased under many contracts to meet the net short position in more than one utility service territory, directly or though swaps, exchanges, or otherwise.

44. The allocation of DWR costs on the basis of geographical differentiation between NP15 and SP 15 presumes a cause-and-effect relationship between the location where energy supplies were procured and the specific utility service territory in which the associated electricity was consumed.

45. For certain power supplies procured north of Path 15, DWR incurred usage charges relating to transmitting power from north to south over Path 15 during periods of expected congestion, a situation that has been referred to as a "transmission constraint."

46. Congestion-related usage charges could be imposed simply on the expectation that Path 15 congestion would occur in the day-ahead power market even when there turned out to be no actual transmission congestion in real time.

47. The congestion-related charges incurred by DWR for power transmitted over Path 15 were an artifact of a statewide dysfunctional power market which have subsided after FERC adopted measures to help minimize or eliminate market flaws in the California electric power market.

48. To the extent that Path 15 congestion-related charges were an artifact of a statewide dysfunctional market, those charges cannot be causally related just to one service territory to the exclusion of another, but are a statewide phenomenon.

49. The causes of price differentials between NP 15 and SP 15 were not necessarily related exclusively to congestion, but to some extent were a function of other factors such as when the related contract was signed.

50. The timing of when particular contracts were signed was not linked to specific utility service territories. Instead, DWR was trying to find power wherever it was available, particularly during the early months of 2001, to address the statewide power crisis.

51. Aside from deficiencies in the theoretical soundness of geographically differentiated cost allocations over Path 15, the unreliability of the empirical modeling data underlying the cost differential provides an additional reason not to allocate disproportionately higher costs to PG&E customers.

52. Use of hourly data for allocation purposes has theoretical appeal as a means to promote linkage between DWR costs and revenues, but unanswered questions concerning the availability, complexity, and litigiousness associated with such data make it inadvisable to adopt such a requirement at this time.

53. Pursuant to Executive Orders issued by the Governor, DWR has been given responsibility and has been authorized to implement the 20/20 Rebate Program.

54. The DWR cents per kWh charges are computed by dividing the allocated DWR revenue requirement assigned to each utility's service territory by the applicable kWh sales to the utility's customers provided by DWR.

55. DWR agrees to track its net short energy purchases and ancillary service purchases to compare against the projected accruals of the revenue requirement and will update projections on a monthly basis.

56. DWR's monthly monitoring will be used to determine if there should be any adjustment, up or down, in the revenue requirement and the associated recovery of that revenue requirement from the customers of the respective utility service territories.

57. Although the end user's retail rates will not fluctuate to reflect monthly differences in DWR sales, the rate per kWh that is included in the bill for the power that the utility itself provides through URG sources (i.e., the "effective utility rate") will vary from month to month.

58. With fixed overall retail tariffed rates and a fixed per kWh charge payable to DWR, there is, in effect, an amount that the utility is entitled to receive for its own account for the kWhs that it supplies to its retail customers, referred to as the "imputed utility rate."

59. Truing up the utility balancing account at a later date to account for under or overcollections of DWR revenues will ensure that the utility bills, and its customers pay (over time), the imputed rate for utility-supplied power.

60. The applicable kWh sales for computing prospective remittances under the DWR charges established in this order cover the period from March 1, 2002 through December 31, 2002.

61. It will be necessary for each utility to remit to DWR lump sum payments for DWR energy delivered to customers prior to March 1, 2002, to the extent that prior interim remittances to DWR were less than the amounts indicated for those prior periods under the allocation of DWR's $10.003 billion revenue requirement as adopted herein.

62. The servicing agreements that have been approved for each of the utilities includes provisions prescribing the billing, collection, and related services to be performed by each utility relating to AB1X-authorized power purchases by DWR.

63. Although D. 01-09-015 allows PG&E to seek Bankruptcy Court approval of its servicing agreement, the Bankruptcy Court has not yet approved PG&E's servicing agreement.

64. Even though the Bankruptcy Court has not approved PG&E's servicing agreement, the relevant language in PG&E's servicing agreement pertaining specifically to the billing, collection, and remittance of funds to DWR can still be independently extracted and incorporated for use in this order.

65. The FERC has recently confirmed that DWR, as the creditworthy party, is responsible for Imbalance Energy charges for PG&E.

Conclusions of Law

1. Under the provisions of Water Code Section 80110, it is within the authority of the DWR to conduct and determine any just and reasonable review of its revenue requirement pursuant to Public Utilities Code Section 451. Accordingly, this Commission makes no independent conclusions concerning whether the DWR revenue requirement implemented in this order is just and reasonable.

2. DWR is legally entitled to payment for its revenue requirement associated with power it purchases and sells to retail end-use customers pursuant to Division 27 of the California Water Code.

3. Pursuant to the mandates of AB1X, a revenue requirement for DWR should be implemented in accordance with the provisions of this order.

4. Based on the amounts that DWR has submitted pursuant to its authority under Water Code Section 80110, the total revenue requirement to be implemented totals $10.003 billion for the service areas of the three major California utilities, covering the period January 2001 through December 2002.

5. DWR should be entitled to recover revenues in an amount equal to the number of kWh sold by DWR and billed to customers in the service territories of PG&E, SCE, and SDG&E, respectively, multiplied by the relevant charges as set forth in the Ordering Paragraph (O.P.) 3 below.

6. Based upon the estimates of URG revenue requirements that have been submitted as testimony in that phase, there is a range of potential outcomes that could be decided by the Commission that could result in either a shortfall or surplus of revenues for each of the utilities.

7. The effect of this order on the need for retail rate increases for the utilities cannot be determined until after the URG phase of this docket is completed.

8. The effect of this order on the need for interim retail rate increases for SDG&E is subject to consideration in a separate docket (A.00-10-045 et al.).

9. It is reasonable to adopt a statewide pro rata allocation of revenue requirement (with utility-specific adjustments as proposed by TURN) based upon the respective net short position among the service areas of the three utilities.

10. The adoption of a pro rata statewide allocation of DWR revenue requirement represents a reasonable application of a cost-based revenue allocation of the DWR revenue requirement and related DWR charges to be applied among the service areas of the three utilities.

11. The goal of our cost allocation is that electricity customers in each utility's service territory pay for the cost of providing DWR service in that territory.

12. A process should be established whereby the actual costs incurred in each service territory will be compared with the costs that were previously projected in order to set future DWR charges.

13. DWR's periodic adjustment to its revenue requirement should reflect the variances between actual and forecasted costs, and take into account actual and projected fund balances.

14. DWR should provide an adjustment to its revenue requirement at the time of its next update of revenue requirements, reflecting the removal of the interim loan costs if, in fact, DWR still expects the long term bonds to be issued on schedule at the end of June 2002.

15. Upon removal of the interim loan costs from the revenue requirement by DWR, if these sums are not needed to pay interest on the long term bonds or to reimburse the General Fund, the Commission would expect to be able to implement a prompt adjustment to the DWR remittance charges payable by the utilities for the balance of 2002.

16. An interim arrangement calling for utilities to remit franchise fees on DWR power sales should be adopted to provide for municipalities to continue to receive such fees pending further determination of a proper disposition of this issue.

17. The record should be further developed concerning the rights and obligations of municipalities, DWR, and the utilities with respect to the collection and remittance of franchise fees associated with DWR power sales. The ALJ should issue a procedural ruling to solicit further comments for this purpose.

18. The servicing agreements approved for SDG&E and SCE should be applied in prescribing the manner of billing, collection, and remittance to be followed by each of those respective utilities with respect to DWR charges implemented in this order.

19. While the servicing agreement for PG&E has not been approved by the Bankruptcy Court, the pertinent language from its servicing agreement as identified in the ALJ ruling dated December 6, 2001, forms a reasonable basis for prescribing the manner of billing, collection, and remittance to be followed by PG&E with respect to DWR charges implemented in this order.

20. PG&E should also be remitting revenues to DWR for Imbalance Energy in that DWR is responsible for such charges according to the order of the FERC.

21. The impacts of Direct Access customers' responsibility for a share of the DWR revenue requirement allocation has not been reflected in the amounts presented in this order, but the assessment of those potential impacts should be considered in this docket on a timely basis in coordination with A. 98-07-003.

22. In order to facilitate independent charges that will be segregated and remitted directly to DWR, a separate per kWh charge should be used in computing the revenue to be forwarded to DWR by each utility on a monthly basis.

23. To ensure that the utility recovers neither more nor less than it would otherwise recover under its imputed utility rate, the utilities should be authorized to establish interest-bearing balancing accounts as a provision of their filed tariffs.

24. The utilities continue to have the obligation to serve pursuant to Public Utilities Code § 451 and Water Code Section 80002.

ORDER

IT IS ORDERED that:

1. The revenue requirement of the California Department of Water (DWR) in the amount of $10,003,461,000 (as set forth in Appendix A) is hereby implemented as provided in the following ordering paragraphs, covering the period January 17, 2001 through December 31, 2002.

2. The total DWR revenue requirement is hereby allocated among the customers in the service territories of three major utilities as follows: for the service territory of Pacific Gas and Electric Company (PG&E) in the amount of $4,765,407;000 for the service territory of Southern California Edison Company (SCE) in the amount of $3,674,066,000; and the remaining allocation to the service territory of San Diego Gas and Electric Company (SDG&E) in the amount of $1,536,989,000.

3. PG&E, SCE, and SDG&E are directed to begin disbursement of proceeds to DWR, as required by their respective servicing agreements or commission order, using the respective charges in cents per kWh of 10.047 for PG&E, 10.309 for SCE and 9.947 for SDG&E. These charges shall apply to each DWR-supplied kWh included on bills rendered on or after March 1, 2002.

4. The cents per kWh charges referenced in ordering paragraph 3 above shall remain in effect for each utility through December 31, 2002 (unless DWR indicates an earlier adjustment is needed), and shall provide recovery of the DWR revenue requirement applicable through that period. Updated DWR charges shall be scheduled to take effect for customers in each of the utilities' service territories beginning on January 1, 2003, covering the DWR revenue requirement for the forecast period from January 1, 2003 through December 31, 2003.

5. To the extent it has not already done so, each utility shall remit an additional one time lump sum payment to DWR representing DWR power delivered to that utility's customers and billed prior to March 1, 2002. The one-time payments shall be based on the difference between the applicable interim charges that have already been remitted to DWR and the amounts that are due based on the DWR revenue requirement allocated to each utility through March 1, 2002. The utilities shall forward the lump sum payments to DWR within 30 calendar days of the effective date of this order. All other sums to be forwarded to DWR pursuant to this ordering paragraph shall be sent at the time specified in the servicing agreement with which the Commission has ordered the utilities to comply.

6. In the case of PG&E, because its servicing agreement has not been approved by the Bankruptcy Court, PG&E shall remit payments in accordance with the provisions based on excerpts from its servicing agreement as set forth in the ALJ ruling dated December 6, 2001, except that PG&E shall also be required to account for and remit to DWR past amounts owing relating to Imbalance Energy.

7. Each of the three utilities shall establish interest-bearing balancing accounts to provide for segregation of DWR-related billed revenues from URG-related billed revenues. The balancing account shall be credited with revenues based on DWR-related kwhr sales multiplied by the adopted DWR charge per kwhr set forth in this order. The balancing shall be debited with the allocated share of actual costs as determined by DWR in its periodic updates of revenue requirement. The share of under or overcollection in DWR costs shall be chargeable to customers in each utility service territory based upon the adopted percentage allocation adopted in this order multiplied by the total actual under or overcollection.

8. The under or overcollection in the account shall be determined as the difference between (a) the total DWR revenues billed, collected, and remitted to DWR and (b) the share of actual DWR costs allocated to the utility. The balancing accounts shall be trued up, pursuant to a subsequent Commission order, no later than during the next update proceeding for DWR.

9. The schedule for the next update of DWR revenue requirement shall be set to begin June 1, 2002, with DWR charges to be revised effective January 1, 2003. The Commission or the ALJ shall issue further orders or rulings establishing any necessary provisions as to the manner and process for the DWR revenue requirement update proceeding.

10. The assigned ALJ shall issue a procedural ruling calling for further briefing and comments regarding pertinent legal issues as to the rights and obligations of municipalities, utilities and their customers, and DWR with respect to the billing, collection, and remittance of franchise fees associated with DWR electric power sales.

11. The ALJ shall issue any further rulings as necessary to expedite consideration of issues relating to Direct Access Customers' cost responsibility for DWR revenue requirements, including any associated adjustments to the adopted DWR allocation percentages as may be relevant to recognize Direct Access impacts.

This order is effective today.

Dated , at San Francisco, California.

Appendix A
Table 1
DWR Revenue Requirement
For the Period January 17, 2001 through December 31, 2002
($000s)
Quarter	Retail Sales (GWhs)	A&G	Other	DSM	Contract Power	Residual Net Short	Ancillary Services	Total Commitments	(Lag) Lead Accrual to Cash	Total Operating Expenditures	Financing Cost	Total Expenditures	Revenue Lead (Lag)	Spot Sales Revenue	Estimated Quarterly Fund Balance	Total DWR Revenues Needed	Net Borrowed Proceeds	Customer Revenue Requirement
		A	B	C	D	E	F	G (Sum of A thru F)	H	I (= G + H)	J	K (= I + J)	L	M	N	O (=K - L -M + N)	P	Q (=O - P)
Q1, 2001	12,360	7,848	-	-	-	3,581,465	367,847	3,957,160	(1,619,382)	2,337,778	-	2,337,778	(544,097)	-	293,176	3,175,051	2,400,000	775,051
Q2, 2001	19,620	10,162	-	482	627,601	3,884,229	419,215	4,941,690	6,302	4,947,991	-	4,947,991	(1,030,866)	-	4,239,624	9,925,305	7,908,729	2,016,576
Q3, 2001	16,054	11,346	3,734	226,446	888,404	1,135,727	57,667	2,323,324	(55,479)	2,267,845	(10,481)	2,257,364	(329,133)	-	3,182,822	1,529,696	(116,300)	1,645,996
Q4, 2001	10,365	8,998	4,008	61,968	670,470	248,590	43,889	1,037,923	550,427	1,588,350	-	1,588,350	223,483	20,884	2,963,069	1,124,230	-	1,124,230
Q1, 2002	9,313	15,104	3,667	-	652,644	169,756	51,551	892,722	1,543,844	2,436,567	(45,976)	2,390,591	879,565	24,819	2,499,879	1,023,017	-	1,023,017
Q2, 2002	7,957	15,104	3,211	-	665,651	129,830	42,678	856,474	(19,771)	836,703	471,932	1,308,635	20,355	39,279	2,128,890	878,012	-	878,012
Q3, 2002	12,312	15,104	4,895	-	946,735	220,184	64,080	1,250,998	(25,251)	1,225,748	400,807	1,626,555	(257,440)	45,879	1,643,471	1,352,697	-	1,352,697
Q4, 2002	10,812	15,104	4,249	-	832,758	164,417	54,752	1,071,280	20,493	1,091,773	464,959	1,556,732	194,995	26,043	1,495,658	1,187,882	-	1,187,882
Total	98,793	98,771	23,764	288,896	5,284,264	9,534,199	1,101,678	16,331,571	401,184	16,732,755	1,281,242	18,013,997	(843,139)	156,903		20,195,890	10,192,429	10,003,461

Notes

1. Total Commitments equals sum of A&G, Other (Uncollectables), DSM, Contract Power, Residual Net Short, and Ancillary Services

2. Total Operating Expenditures equals Total Commitments plus (Lag) Lead Accrual to Cash

3. Total Expenditures equals Total Operating Expenditures plus Financing Cost

4. Total DWR Revenues Needed equals Total Expenditures minus Revenue Lead (Lag), minus Spot Sales Revenue, plus Estimated Quarterly Fund Balance

5. Customer Revenue Requirement equals Total DWR Revenues Needed minus Net Borrowed Proceeds

(END OF APPENDIX A)

Appendix B

Summary of Parties' Comments Regarding the Reasonableness
of DWR's Revenue Requirement

This appendix sets forth parties' position regarding various concerns raised in their comments filed on November 13, 2001 regarding their review of the DWR revenue requirement submittal of November 5, 2001. In response to a letter of Commissioner Brown to DWR dated, DWR provided further responses to the concerns raised by parties, as summarized below. These comments are provided for informational purposes, with the understanding that DWR retains responsibility for conducting a "just and reasonable" review of its costs pursuant to Public Utilities Code Section 451.

1. DWR Losses on Surplus Power Sales

DWR's revenue requirements include costs associated with surplus power that is sold off-system. PG&E argues that under Water Code Section 80116, DWR may not charge retail end-use customers for losses incurred on off-system sales of surplus power because retail end-use customers are only liable for the costs of the power actually sold to them.

DWR states that it is impossible to identify which specific purchases by DWR are subsequently sold off system to non utility customers, precluding DWR from quantifying a true "cost" of surplus power. DWR did provide, however, a weighted average monthly summary through September 2001 and quarterly thereafter of cost and volume of long term power, residual net short purchases, and off-system sales.

DWR disagrees with PG&E's characterization of any DWR purchases as being made for any purpose other than for the provision of the utilities net short position. DWR explains that from time to time, it may purchase more energy than is currently required to serve retail customers net short. The excess energy is sold into wholesale markets to provide off system revenues which are used to decrease revenue requirements recovered from retail customers. DWR states that such balancing of needs by periodic off system sales is standard industry practice. Therefore, DWR asserts that it is appropriate to consider all purchased power costs (including losses) incurred in DWR's revenue requirement.

2. Spot Electricity Prices in Q3-2001

PG&E has noted that DWR's estimate of spot electricity prices for Q-3 in the November 5 Revenue Requirement (Table 6, pg. 16) of $117MWH price is significantly above the FERC-mandated price cap in effect during Q3- 2001. PG&E claims that DWR's Q3-2001 prices are inflated by as much as $700 Million due to this effect.

PG&E asked that DWR explain the re-classification of its short-term contracts (90-days or less) that are now part of the "Residual Net Short," and indicate to what extent these 90-day contracts have caused the residual net short average costs to exceed the FERC price cap during third quarter 2001. PG&E asked that DWR provide detailed workpapers regarding the dates, amounts and costs of such 90-day contracts entered into during the period immediately prior to and during third quarter 2001, especially after adoption of FERC's price mitigation order.

In its December 13 reply, DWR explains that it has not reclassified short term contracts, nor are the 90-day contracts responsible for the residual net short average to rise above the FERC price cap. In its reply, DWR provides a table summarizing the prices and volumes for components of the net short by month during third quarter 2001. DWR explains that actual purchases in each of the spot markets are all below the current FERC non-Stage 1 alert price cap of $101.06/mWh. Yet, in computing its reported third quarter prices, DWR includes the net effects of off-system sales, causing reported unit prices to exceed the FERC price cap in the month of July 2001.

3. Line Losses

PG&E claimed that the 9% assumed by the DWR for PG&E's transmission and distribution losses should be reduced to no more than 6.4%. PG&E assumes a 0.6% reduction of transmission losses due to the fact that the ISO typically requires generators to make up the associated transmission losses. PG&E claims that DWR's revenue requirement constitutes double-charging of PG&E customers by about $390 Million because it includes ISO's Unaccounted-for Energy (UFE) charges for PG&E, but also assumes additional energy is procured by DWR for UFE.

DWR disagrees with PG&E's contention that line losses should be reduced to 6.4% and denies any double counting of UFE charges. DWR states that the fact that the ISO requires generators to make up line losses does not mean that losses do not occur, or that DWR does not incur costs for associated energy to account for those line losses. DWR further states that no explicit UFE charges were considered in the revenue requirement after August 2001. UFE amounts are inherently included as part of the forecast of energy procured by DWR.

4. Direct Access Estimates for PG&E

In its October 26 comments to DWR, PG&E provided updated estimates for the fourth quarter of 2001 for direct access, although DWR has not incorporated PG&E's update in its latest revenue requirement. However, PG&E now believes that the actual direct access amount for the fourth quarter of 2001 and for all of 2002 will be even higher than previously forecasted.

DWR states that it cannot confirm with reasonable certainty PG&E's estimates of direct access. Because of the multiple uncertainties surrounding the future of direct access, DWR does not believe it is appropriate at this time to alter its estimates of direct access based on more recent estimates. DWR states that it will consider expected changes to California's retail electricity markets when developing its next determination of revenue requirements.

5. WAPA Loads

PG&E claims that DWR's estimate of Western Area Power Administration (WAPA) loads of 5,429 GWh is too high. PG&E provided DWR an estimate of 5,026 GWh for 2001 and 3,837 GWh for 2002 for WAPA loads in its October 26 comments, corresponding to a reduction in DWR's revenue requirement for PG&E by about $90 Million.

DWR states that it will continue to review PG&E's updated WAPA load estimates and incorporate any changes in DWR's true up process relating to updating its future determinations of revenue requirement.

6. Treatment of Wholesale Contracts

SCE questions whether DWR has been consistent in its treatment of SCE's wholesale contract obligations, in particular, SCE's exchange contracts, or whether these contracts were considered in estimating SCE's net short position.

DWR asserts that it has been consistent in its treatment of wholesale obligations and exchanges between the three utilities. DWR explains that many of the utility-to-municipal exchanges are included within the PROSYM simulations. While other exchanges are not explicitly modeled within PROSYM, they are included in DWR's true up to actual costs.

7. Short-Term Load Resource Balance

On page A-20 of its revenue requirement submittal, DWR notes that it is limiting imports into California to generation owned by the utilities as part of their retained generation, out-of-state generation owned by municipal utilities, or existing bilateral contracts with out-of-state suppliers. PG&E has claimed that this understates the amount of power that could be imported into California.

DWR responds that PG&E misinterprets the explanatory notes to Table III-1 in the November 5 Determination. DWR is not limiting its power procurement only to new, in-state generation without consideration of imports. Table III-1 is indicative of resources firmly committed to consumers in California at the summer peak hour over DWR's revenue requirement period. DWR states that other, non-firm, out-of-state resources expected to be available have been incorporated into its estimates of power to meet net short requirements.

8. DWR Reserve Requirements

DWR revenue requirements include cash to fund reserve requirements. According to DWR, the cash reserves are needed for debt service reserves and for handling future cost and revenue volatility under different "stress scenarios" involving variations in natural gas and spot market prices, and forced outages at generating plants.

Aglet observes that DWR's reserve requirements are large compared to normal utility working cash requirements, and argues that the Commission should not require utility customers to fund any DWR cash reserve requirements. Aglet claims there are better ways to protect DWR from cash flow volatility. Aglet argues that for large firms, and by extension for DWR, the preferred response to operating volatility is the use of credit facilities-not cash reserves. Creditworthy utilities respond to cost volatility by relying on lines of credit, commercial paper and other short-term borrowing and lending. Aglet believes the Commission and DWR should cooperatively seek a "line of credit" or equivalent financial backup from the State.

If the Commission insists that customers put up the requested cash reserves, then Aglet argues that customers should be credited with interest accruals on the full amount of the DWR's cash reserve, consistent with rate base reductions ordered for utilities with contributions in aid of construction. Aglet asks the Commission to encourage DWR to return unneeded reserves to customers promptly after the State issues its bonds and in any other circumstance where DWR recognizes that its cash flows will become less volatile.

9. Uncollectibles Factor

DWR includes in its revenue requirement an allowance for uncollectibles, based on a factor of 0.0033. (Reference Item E, transcript of October 22, 2001 workshop, RT 81:22-82:12.) Aglet opposes DWR cost recovery of uncollectibles based on the untested average rate of 0.0033, but instead advocates use of the most recently authorized uncollectibles factor for each utility. For example, the authorized factor for PG&E is 0.00267, which is 19% lower than DWR's figure. (Decision 01-10-031, Ordering Paragraph 27, slip op. at 45.)

Aglet argues that reliance on Commission-authorized uncollectibles factors will treat customers fairly and will have no effect on DWR's achieved revenues. Customer rates for each utility would include an uncollectibles allowance based on the authorized rate, billed revenues would be reduced using the authorized rate, and remaining cash revenues would be available for transmittal to DWR. Aglet argues that this outcome is administratively efficient because each utility will use a single uncollectibles factor for all of its retail rates, rather than determining rates based on two different factors.

DWR has explained that its forecasted allowance for uncollectibles was developed assuming a pro rata share of recently observed utility uncollectible accounts. (Reference Item C, DWR, November 5 revenue requirement document, p. 19.) As stated previously, DWR is charged with determining the justness and reasonableness of its revenue requirement, and this proceeding is not the forum in which to litigate the reasonableness of DWR's determination of this element of its revenue requirements. In the true up of DWR's forcasted versus actual revenue requirement, relevant differences in uncollectibles expense can be taken into account.

(END OF APPENDIX B)

Appendix C

Natural Gas Pricing Assumptions

Natural gas prices are an input in DWR's estimated power prices in meeting utility customers' net short requirements. DWR provides a detailed discussion of its assumptions underlying natural gas prices in Appendix VI of its November 5^th submittal. Estimated prices have been developed using a proprietary forecasting model developed by Navigant.

The Appendix C Table below shows the cost of natural gas assumed in the development of both contract power costs as well as the cost of residual net short power resources for the DWR revenue requirement. Fuel transportation charges are estimated in DWR's generation dispatch model based upon regional location of generating sources. During the summer of 2001, minor volumes of gas were procured for part of 2001 and the first quarter of 2002 for some of those contracts under which DWR has rights to purchase or supply fuel to a generator. Those costs are included in DWR's contract energy costs. All fuel costs included in the contracts and the spot market purchases are assumed to be equal to the average spot market price of natural gas.

TABLE GAS PRICE ASSUMPTIONS ($/MMBTU IN 2001 DOLLARS)
	SoCal Border	Malin	PG&E City Gate
Q3 2001	3.72	3.59	3.87
Q4 2001	3.54	3.01	3.49
Q12002	3.55	3.02	3.51
Q2 2002	3.52	2.99	3.47
Q3 2002	3.36	2.86	3.33
Q4 2002	I 3.78	I 3.22	I 3.72

(END OF APPENDIX C)

************ APPEARANCES ************ Gerald Lahr ABAG POWER 101 8TH STREET OAKLAND CA 94607 (510) 464-7908 jerryl@abag.ca.gov For: ASSOCIATION OF BAY AREA GOVERNMENTS (ABAG) Katherine S. Poole ADAMS BROADWELL JOSEPH & CARDOZO 651 GATEWAY BLVD., SUITE 900 SOUTH SAN FRANCISCO CA 94080 (650) 589-1660 kpoole@adamsbroadwell.com For: The Coalition of California Utility Employees Marc D. Joseph Attorney At Law ADAMS BROADWELL JOSEPH & CARDOZO 651 GATEWAY BOULEVARD, SUITE 900 SOUTH SAN FRANCISCO CA 94080 (650) 589-1660 mdjoseph@adamsbroadwell.com For: The Coalition of California Utility Employees William P. Adams ADAMS ELECTRICAL SAFETY CONSULTING 716 BRETT AVENUE ROHNERT PARK CA 94928-4012 (707) 795-7549 For: SELF Aaron Thomas AES NEWENERGY, INC. 350 S. GRAND AVENUE, SUITE 2950 LOS ANGELES CA 90071 (213) 996-6136 athomas@newenergy.com For: New Energy Ventures, Inc. Patrick Mcdonnell AGLAND ENERGY 2000 NICASIO VALLEY ROAD NICASIO CA 94946 (415) 662-6944 aglandenergy@earthlink.net For: Enserch Energy Services	James Weil AGLET CONSUMER ALLIANCE PO BOX 1599 FORESTHILL CA 95631 (530) 367-3300 jweil@aglet.org For: AGLET CONSUMER ALLIANCE Michael Aguirre Attorney At Law AGUIRRE & MEYER 1060 8TH AVENUE, SUITE 300 SAN DIEGO CA 92101 (619) 235-8636 julesan@aol.com For: RATEPAYERS/UCAN James H. Butz AIR PRODUCTS AND CHEMICALS, INC. 7201 HAMILTON BLVD. ALLENTOWN PA 18195 (610) 481-4239 butzjh@apci.com C. Fairley Spillman AKIN, GUMP, STRAUSS, HAUER & FELD, LLP 1333 NEW HAMPSHIRE AVENUE, NW WASHINGTON DC 20036 fspillman@akingump.com Donald Brookhyser Attorney At Law ALCANTAR & KAHL 1300 S.W. 5TH AVENUE, SUITE 1750 PORTLAND OR 97201 (503) 402-8702 deb@a-klaw.com For: Cogeneration Association of California Evelyn Kahl Attorney At Law ALCANTAR & KAHL, LLP 120 MONTGOMERY STREET, SUITE 2200 SAN FRANCISCO CA 94104 (415) 421-4143 ek@a-klaw.com For: Energy Producers & Users Coalition Chris King Executive Director AMERICAN ENERGY INSTITUTE 842 OXFORD ST. BERKELEY CA 94707 (510) 435-5189 ckingaei@yahoo.com
Barbara R. Barkovich BARKOVICH AND YAP, INC. 31 EUCALYPTUS LANE SAN RAFAEL CA 94901 (415) 457-5537 brbarkovich@earthlink.net For: California Large Energy Consumers Association (CLECA) Reed V. Schmidt BARTLE WELLS ASSOCIATES 1889 ALCATRAZ AVENUE BERKELEY CA 94703 (510) 653-3399 rschmidt@bartlewells.com For: California City County Streetlight Association (CAL-SLA) Marco Gomez Attorney At Law BAY AREA RAPID TRANSIT DISTRICT 800 MADISON STREET, 5TH FLOOR OAKLAND CA 94607 (510) 464-6058 mgomez1@bart.gov For: Bay Area Rapid Transit District C. Susie Berlin Attorney At Law 2105 HAMILTON AVENUE, SUITE 140 SAN JOSE CA 95037 (408) 558-0950 sberlin@mccarthylaw.com For: NORTHERN CALIFORNIA POWER AGENCY Roger Berliner BERLINER, CANDON & JIMISON 1225 19TH STREET, N.W., SUITE 800 WASHINGTON DC 20036 (202) 955-6067 rogerberliner@bcjlaw.com For: Internal Services Department of Los Angeles County (LACISD) A Brubaker BRUBAKER & ASSOCIATES, INC. 1215 FERN RIDGE PARKWAY, SUITE 208 ST. LOUIS MO 63141 (314) 275-7007 mbrubaker@consultbai.com For: Brubaker & Associates, Inc. Jonathan M. Weisgall V.P. Legislative & Regulatory Affairs CALENERGY COMPANY, INC. 1200 NEW HAMPSHIRE AVE., NW, SUITE 300 WASHINGTON DC 20036 (202) 828-1378 jweisgall@aol.com	Jennifer Tachera CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS-14 SACRAMENTO CA 95814-5504 (916) 654-3870 jtachera@energy.state.ca.us Karen Norene Mills Attorney At Law CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO CA 95833 (916) 561-5655 kmills@cfbf.com For: California Farm Bureau Federation Ronald Liebert Attorney At Law CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO CA 95833 (916) 561-5657 rliebert@cfbf.com For: California Farm Bureau Federation Ed Yates CALIFORNIA LEAGUE OF FOOD PROCESSORS 980 NINTH STREET, SUITE 230 SACRAMENTO CA 95814 (916) 444-9260 ed@clfp.com For: California League of Food Processors Susan Rossi Attorney At Law CALIFORNIA POWER EXCHANGE CORPORATION 200 S. LOS ROBLES AVENUE, SUITE 400 PASADENA CA 91101-2482 (626) 685-9857 sdrossi@calpx.com For: CALIFORNIA POWER EXCHANGE Tom Smegal CALIFORNIA WATER SERVICE 1720 NORTH FIRST STREET SAN JOSE CA 95112 (408) 367-8235 tsmegal@calwater.com For: California Water Association
Jennifer Chamberlin CHEVRON ENERGY SOLUTIONS 345 CALIFORNIA ST., 32ND FLOOR SAN FRANCISCO CA 94104 (415) 733-4661 jnnc@chevron.com For: Chevron Energy Solutions Theresa Mueller Deputy City Attorney CITY AND COUNTY OF SAN FRANCISCO 1 DR. CARLTON B. GOODLETT PLACE SAN FRANCISCO CA 94102 (415) 554-4640 theresa_mueller@ci.sf.ca.us For: City & County of San Francisco Bill Mc Callum CITY OF FRESNO 5607 W. JENSEN AVENUE FRESNO CA 93607 (559) 498-1728 bill.mccallum@ci.fresno.ca.us For: CITY OF FRESNO Jesse J. Avila Assistant City Attorney CITY OF FRESNO 2600 FRESNO STREET FRESNO CA 93721 (559) 498-1326 jesse.avila@ci.fresno.ca.us Frederick Ortlieb Deputy City Attorney CITY OF SAN DIEGO 1200 THIRD AVENUE, 11TH FLOOR SAN DIEGO CA 92101 (619) 236-6220 fmo@sdcity.sannet.gov For: CITY OF SAN DIEGO John Tooker City Manager CITY OF YUCAIPA 34272 YUCAIPA BLVD. YUCAIPA CA 92399 (909) 797-2489 Howard Choy Energy Management Division Manager COUNTY OF LOS ANGELES INTERNAL SERVICES DEPARTMENT 1100 NORTHEASTERN AVENUE LOS ANGELES CA 90063 (323) 881-3939 hchoy@isd.co.la.ca.us For: COUNTY OF LOS ANGELES	Patrick Mcguire TOM BEACH CROSSBORDER ENERGY 2560 NINTH STREET, SUITE 316 BERKELEY CA 94710 (510) 649-9790 patrickm@crossborderenergy.com For: Watson Cogeneration Company Tom Beach CROSSBORDER ENERGY 2560 NINTH STREET., SUITE 316 BERKELEY CA 94710 (510) 649-9790 tomb@crossborderenergy.com For: Watson Cogeneration Company Robert C. Cagen Legal Division RM. 5026 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2197 rcc@cpuc.ca.gov For: Office of Ratepayers Advocate Lindsey How-Downing Attorney At Law DAVIS WRIGHT TREMAINE LLP ONE EMBARCADERO CENTER, STE 600 SAN FRANCISCO CA 94111-3834 (415) 276-6500 lindseyhowdowning@dwt.com For: CALPINE CORPORATION Edward W. O'Neill Attorney At Law DAVIS WRIGHT TREMAINE, LLP ONE EMBARCADERO CENTER, SUITE 600 SAN FRANCISCO CA 94111-3834 (415) 276-6500 edwardoneill@dwt.com For: El Paso Natural Gas Company Treg Tremont Attorney At Law DAVIS WRIGHT TREMAINE, LLP ONE EMBARCADERO CENTER, SUITE 600 SAN FRANCISCO CA 94111-3834 (415) 276-6500 tregtremont@dwt.com For: Costco Wholesale Corporation
Norman J. Furuta Attorney At Law DEPARTMENT OF THE NAVY 2001 JUNIPERO SERRA BLVD., SUITE 600 DALY CITY CA 94014-1976 (650) 746-7312 FurutaNJ@efawest.navfac.navy.mil For: Federal Executive Agencies Dan L. Carroll Attorney At Law DOWNEY BRAND SEYMOUR & ROHWER, LLP 555 CAPITOL MALL, 10TH FLOOR SACRAMENTO CA 95814 (916) 441-0131 dcarroll@dbsr.com For: CALIFORNIA INDUSTRIAL USERS Colin L. Pearce DUANE MORRIS & HECKSCHER 100 SPEAR STREET, SUITE 1500 SAN FRANCISCO CA 94105 (415) 371-2200 clpearce@duanemorris.com For: Sacramento Municipal Utility District (SMUD) Thomas M. Berliner Attorneys At Law DUANE MORRIS & HECKSCHER 100 SPEAR STREET, SUITE 1500 SAN FRANCISCO CA 94105 (415) 371-2200 tmberliner@duanemorris.com For: Sacramento Municipal Utility District Ron Knecht ECONOMICS & TECH ANALYSIS GROUP 1465 MARLBAROUGH AVENUE LOS ALTOS CA 94024-5742 (650) 968-0115 ronknecht@aol.com For: SELF Lynn M. Haug ANDY BROWN Attorney At Law ELLISON & SCHNEIDER 2015 H STREET SACRAMENTO CA 95814-3109 (916) 447-2166 lmh@eslawfirm.com For: East Bay Municipal Utility District (EBMUD)	Andrew B. Brown Attorney At Law ELLISON, SCHNEIDER & HARRIS 2015 H STREET SACRAMENTO CA 95814 (916) 447-2166 abb@eslawfirm.com For: CALIFORNIA DEPARTMENT OF GENERAL SERVICES (DGS) Douglas K. Kerner Attorney At Law ELLISON, SCHNEIDER & HARRIS 2015 H STREET SACRAMENTO CA 95814 (916) 447-2166 dkk@eslawfirm.com For: Independent Energy Producers Association Andrew J. Skaff Attorney At Law ENERGY LAW GROUP, LLP 1999 HARRISON ST., SUITE 2700 OAKLAND CA 94612 (510) 874-4370 askaff@energy-law-group.com For: New York Mercantile Exchange/Dynegy, Inc. Diane Fellman ENERGY LAW GROUP, LLP 1999 HARRISON STREET, SUITE 2700 OAKLAND CA 94612-3572 (415) 703-6000 difellman@energy-law-group.com For: PacificCrockett Energy, Inc. Carolyn Kehrein ENERGY MANAGEMENT SERVICES 1505 DUNLAP COURT DIXON CA 95620-4208 (707) 678-9506 cmkehrein@ems-ca.com For: Energy Users Forum Nancy Ryan ENVIRONMENTAL DEFENSE 5655 COLLEGE AVENUE OAKLAND CA 94618 (510) 658-8008 nryan@environmentaldefense.org For: Environmental Defense
Brian Cragg Attorney At Law GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP 505 SANSOME ST., 9TH FLOOR SAN FRANCISCO CA 94111 (415) 392-7900 bcragg@gmssr.com For: Enron Energy Services James D. Squeri Attorney At Law GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP 505 SANSOME STREET, SUITE 900 SAN FRANCISCO CA 94102 (415) 392-7900 jsqueri@gmssr.com For: California Retailers Association Jeanne M. Bennett Attorney At Law GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP 505 SANSOME STREET, SUITE 900 SAN FRANCISCO CA 94111 (415) 392-7900 jbennett@gmssr.com For: Alliance for Retail Markets and Enron Corporation Michael B. Day Attorney At Law GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP 505 SANSOME STREET, SUITE 900 SAN FRANCISCO CA 94111-3133 (415) 392-7900 mday@gmssr.com For: ENRON ENERGY SERVICES, INC., ENRON NORTH AMERICA Richard H. Counihan GREENMOUNTAIN.COM 50 CALIFORNIA STREET, SUITE 1500 SAN FRANCISCO CA 94111 (415) 439-5310 rick.counihan@greenmountain.com For: GREEN MOUNTAIN ENERGY RESOURCES Anne C. Selting Attorney At Law GRUENEICH RESOURCE ADVOCATES 582 MARKET STREET, SUITE 1020 SAN FRANCISCO CA 94104 (415) 834-2300 aselting@gralegal.com	Morten Henrik Greidung HAFSLUND ENERGY TRADING, LLC 101 ELLIOT AVE., SUITE 510 SEATTLE WA 98119 (206) 436-0640 mhg@hetrading.com For: HAFSLUND ENERGY TRADING, LLC James Hodges 4720 BRAND WAY SACRAMENTO CA 95819 (916) 451-7011 hodgesjl@pacbell.net For: TELACU and Maravilla Foundation Jan Smutny-Jones Association INDEPENDENT ENERGY PRODUCERS 1112 I STREET, STE. 380 SACRAMENTO CA 95814-2896 (916) 448-9499 smutny@iepa.com William B. Marcus JBS ENERGY, INC. 311 D STREET, SUITE A WEST SACRAMENTO CA 95605 (916) 372-0534 bill@jbsenergy.com For: TURN (EXPERT WITNESS) Norman A. Pedersen Esquire JONES DAY REAVES & POGUE 555 WEST FIFTH STREET, SUITE 4600 LOS ANGELES CA 90013-1025 (213) 243-2810 napedersen@jonesday.com For: Commonwealth Energy Corporation and Automated Power Exchange Inc. & Frito Lay, Inc. 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 JAMES WEIL SUITE 200 720 MARKET STREET SAN FRANCISCO CA 94102 (415) 781-5348 harrington@ggra.org For: GOLDEN GATE RESTAURANT ASSOCIATION
Daniel L. Rial KINDER MORGAN ENERGY PARTNERS 1100 TOWN & COUNTRY ROAD ORANGE CA 92868 (714) 560-4854 riald@kindermorgan.com For: Kinder Morgan Energy Partners, SFPP, L.P., CALNEV Thomas S. Knox Attorney At Law KNOX, LEMMON & ANAPOCSKY, LLP ONE CAPITOL MALL, SUITE 700 SACRAMENTO CA 95814 (916) 498-9911 tknox@klalawfirm.com For: Leprino Foods Susan E. Brown Attorney At Law LATINO ISSUES FORUM 785 MARKET STREET, 3RD FLOOR SAN FRANCISCO CA 94103-2003 (415) 284-7224 lifcentral@lif.org For: LATINO ISSUES FORUM Daniel W. Douglass Attorney At Law LAW OFFICES OF DANIEL W. DOUGLASS 5959 TOPANGA CANYON BLVD., STE 244 WOODLAND HILLS CA 91367 (818) 596-2201 douglass@energyattorney.com For: ALLIANCE OF RETAIL MARKETS and WESTERN POWER TRADING FORUM William H. Booth Attorney At Law LAW OFFICES OF WILLIAM H. BOOTH 1500 NEWELL AVENUE, 5TH FLOOR WALNUT CREEK CA 94596 (925) 296-2460 wbooth@booth-law.com For: California Large Energy Consumers Assn. Christopher A. Hilen Attorney At Law LEBOEUF LAMB GREENE & MACRAE LLP ONE EMBARCADERO CENTER, SUITE 400 SAN FRANCISCO CA 94111 (415) 951-1141 chilen@llgm.com For: RELIANT ENERGY POWER GENERATION, INC.	John W. Leslie Attorney At Law LUCE FORWARD HAMILTON & SCRIPPS, LLP 600 WEST BROADWAY, SUITE 2600 SAN DIEGO CA 92101-3391 (619) 699-2536 jleslie@luce.com For: SHELL ENERGY SERVICES, LLC Steven Moss M.CUBED 673 KANSAS STREET SAN FRANCISCO CA 94107 (415) 643-9578 smoss@hooked.net For: WESTERN MOBILHOME PARK ASSOCIATION David Huard RANDALL KEEN MANATT, PHELPS & PHILLIPS 11355 W. OLYMPIC BLVD LOS ANGELES CA 90064 (310) 312-4247 dhuard@manatt.com For: CALIFORNIA HEALTHCARE ASSOCIATION Matthew V. Brady Attorney At Law MATTHEW V. BRADY & ASSOCIATES 300 CAPITOL MALL, SUITE 1100 SACRAMENTO CA 95814 (916) 442-5600 bradylaw@pacbell.net For: Shasta Hydroelectric, Inc. David J. Byers Attorney At Law MCCRACKEN, BYERS & HAESLOOP 840 MALCOLM ROAD, SUITE 100 BURLINGAME CA 94010 (650) 259-5979 btenney@landuselaw.com For: California City County Streetlight Association (CAL-SLA) Terry J. Houlihan Attorney At Law MCCUTCHEN DOYLE BROWN & ENERSEN LLP 3 EMBARCADERO CENTER, 18TH FLOOR SAN FRANCISCO CA 94111 (415) 393-2000 thoulihan@mdbe.com For: RELIANT ENERGY POWER GENERATION, INC.
Jeffrey H. Goldfien Assistant City Attorney MEYERS, NAVE, RIBACK, SILVER & WILSON 777 DAVIS STREET, SUITE 300 SAN LEANDRO CA 94577 (510) 351-4300 jhg@meyersnave.com For: City of San Leandro Christopher W. Reardon MFRS COUNCIL OF THE CENTRAL VALLEY PO BOX 1564 MODESTO CA 95353 (209) 523-0886 cwrmccv@worldnet.att.net For: Manufacturers Council of the Central Valley (MCCV) Kevin R. Mcspadden Attorney At Law MILBANK TWEED HADLEY & MCCLOY 601 SOUTH FIGUEROA, 30TH FLOOR LOS ANGELES CA 90017 (213) 892-4563 kmcspadden@milbank.com For: MILBANK, TWEED, HADLEY & MC CLOY Scott T. Steffen Attorney At Law MODESTO IRRIGATION DISTRICT 1231 ELEVENTH STREET MODESTO CA 95354 (209) 526-7387 scottst@mid.org For: MODESTO IRRIGATION DISTRICT (MID) Diane E. Pritchard Attorney At Law MORRISON & FOERSTER, LLP 425 MARKET STREET SAN FRANCISCO CA 94105-2482 (415) 268-7188 dpritchard@mofo.com For: E&J Gallo Winery, The Wine Institute and the Agricultural Energy Consumers Association. Peter Hanschen Attorney At Law MORRISON & FOERSTER, LLP 425 MARKET STREET SAN FRANCISCO CA 94105 (415) 268-7214 phanschen@mofo.com For: Agricultural Energy Consumers Assn.	Sara Steck Myers Attorney At Law 122 28TH AVENUE SAN FRANCISCO CA 94121 (415) 387-1904 ssmyers@worldnet.att.net For: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE TECHOLOGIES (CEERT) Richard Roos-Collins Attorney At Law NATURAL HERITAGE INSTITUTE 2140 SHATTUCK AVENUE, SUITE 500 BERKELEY CA 94704-1222 (510) 644-2900 rrcollins@n-h-i.org For: California Hydropower Reform Coalition Janie Mollon Manager Regulatory Affairs NEW WEST ENERGY 1521 N. PROJECT DRIVE PHOENIX AZ 85082 (602) 629-7758 jsmollon@newwestenergy.com For: NEW WEST ENERGY Jose E. Guzman, Jr. Attorney At Law NOSSAMAN GUTHNER KNOX & ELLIOTT LLP 50 CALIFORNIA STREET, 34TH FLOOR SAN FRANCISCO CA 94111-4799 (415) 398-3600 jguzman@nossaman.com For: Cargill Corporation Christine Ferrari Depurty City Attorney OFFICE OF THE CITY ATTORNEY CITY HALL ROOM 234 1 DR. CARLTON B. GOODLETT PLACE SAN FRANCISCO CA 94102-4682 (415) 554-4634 christine_ferrari@ci.sf.ca.us Joseph M. Malkin Attorney At Law ORRICK, HERRINGTON & SUTCLIFFE LLP 400 SANSOME STREET SAN FRANCISCO CA 94111-3143 (415) 773-5505 jmalkin@orrick.com For: THE AES CORPORATION
William H. Edwards KELLY M. MORTON, JAMES L. LOPES PACIFIC GAS AND ELECTRIC CO. 77 BEALE STREET PO BOX 7442, RM 3115-B30A SAN FRANCISCO CA 94120-7442 (415) 973-2768 whe1@pge.com For: PG&E Cecilia Montana PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MAIL CODE B9A SAN FRANCISCO CA 94105 (415) 973-1595 cfm3@pge.com For: Pacific Gas and Electric Company J Michael Reidenbach PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MAIL CODE B30A SAN FRANCISCO CA 94105 (415) 973-2491 jmrb@pge.com For: Pacific Gas and Electric Company Peter Ouborg Attorney At Law PACIFIC GAS AND ELECTRIC COMPANY PO BOX 7442, B30A SAN FRANCISCO CA 94120 (415) 973-2286 pxo2@pge.com For: Pacific Gas and Electric Company Peter Bray PETER BRAY AND ASSOCIATES 3566 17TH STREET, NO. 2 SAN FRANCISCO CA 94110-1093 (415) 437-1633 tor58dog@pacbell.net For: The New Power Company Patrick J. Power Attorney At Law 1300 CLAY STREET, SUITE 600 OAKLAND CA 94612 (510) 446-7742 pjpowerlaw@aol.com For: City of Long Beach; Universal Studios Inc.	Lon W. House RCRC ENERGY ADVISOR 4901 FLYING C ROAD CAMERON PARK CA 95682 (530) 676-8956 lwhouse@el-dorado.ca.us For: Regional Council of Rural Counties Don Schoenbeck RCS CONSULTING, INC. 900 WASHINGTON STREET, SUITE 1000 VANCOUVER WA 98660 (360) 737-3877 dws@keywaycorp.com For: Coalinga Cogenerator James Ross RCS CONSULTING, INC. 500 CHESTERFIELD CENTER, SUITE 320 CHESTERFIELD MO 63017 (636) 530-9544 jimross@r-c-s-inc.com For: Midway Sunset Cogeneration Steven Greenberg REALENERGY 300 CAPITOL MALL, SUITE 300 SACRAMENTO CA 95814 (916) 325-2500 sgreenberg@realenergy.com For: RealEnergy Keith Sappenfield RELIANT ENERGY RETAIL, INC. PO BOX 1409 HOUSTON TX 77251-1409 (713) 207-5570 keith-sappenfield@reliantenergy.com For: Reliant Energy Retail, Inc. Randy Britt ROBINSONS-MAY 6160 LAUREL CANYON BLVD. NORTH HOLLYWOOD CA 91606 (818) 509-4777 randy_britt@mayco.com For: Robinsons-May Arlin Orchard Attorney At Law SACRAMENTO MUNICIPAL UTILITY DISTRICT PO BOX 15830, MAIL STOP-B406 SACRAMENTO CA 95852-1830 (916) 732-5830 aorchar@smud.org For: Sacramento Municipal Utility District
Dana S. Appling General Counsel SACRAMENTO MUNICIPAL UTILITY DISTRICT LEGAL DEPARTMENT MSB406 PO BOX 15830 SACRAMENTO CA 95852-1830 (916) 732-6126 Phillip J. Muller SCD ENERGY SOLUTIONS 436 NOVA ALBION WAY SAN RAFAEL CA 94903 (415) 479-1710 pjmuller@ricochet.net For: Southern Company Energy Marketing Jeffrey M. Parrott LYNN G. VAN WAGENEN Attorney At Law SEMPRA ENERGY 101 ASH STREET SAN DIEGO CA 92101-3017 (619) 699-5063 jparrott@sempra.com For: San Diego Gas & Electric Company Judy Young Attorney At Law SEMPRA ENERGY 555 W. 5TH STREET, M.L.G.T. 14E7 LOS ANGELES CA 90013 (213) 244-2955 jlyoung@sempra.com For: Southern California Gas Company Keith W. Melville DAVID R. CLARK Attorney At Law SEMPRA ENERGY 101 ASH STREET SAN DIEGO CA 92101-3017 (619) 699-5039 kmelville@sempra.com For: San Diego Gas & Electric Company Andrew Chau Attorney At Law SHELL ENERGY SERVICES COMPANY, L.L.C. 1221 LAMAR STREET, SUITE 1000 HOUSTON TX 77010 (713) 241-8939 anchau@shellus.com	Justin D. Bradley SILICON VALLEY MANUFACTURING GROUP 226 AIRPORT PARKWAY, SUITE 190 SAN JOSE CA 95110 (408) 501-7852 jbradley@svmg.org For: Silicon Valley Manufacturing Group Beth A. Fox Attorney At Law SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE, RM. 535 ROSEMEAD CA 91770 (626) 302-6897 beth.fox@sce.com For: SOUTHERN CALIFORNIA EDISON COMPANY (SCE) James P. Shotwell Attorney At Law SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE., ROOM 337 ROSEMEAD CA 91770-0001 (626) 302-4531 j.p.shotwell@sce.com For: SOUTHERN CALIFORNIA EDISON COMPANY (SCE) James C. Paine Attorney At Law STOEL RIVES LLP 900 S.W. FIFTH AVENUE, STE 2600 PORTLAND OR 97204-1268 (503) 294-9246 jcpaine@stoel.com For: PacifiCorp James Bushee SUTHERLAND, ASBILL & BRENNAN 1275 PENNSYLVANIA AVENUE WASHINGTON DC 20004 (202) 383-0100 jbushee@sablaw.com For: CALIFORNIA MANUFACTURERS ASSOCIATION (CMA) Keith Mc Crea Attorney At Law SUTHERLAND, ASBILL & BRENNAN 1275 PENNSYLVANIA AVENUE, N.W. WASHINGTON DC 20004-2415 (202) 383-0705 kmccrea@sablaw.com For: CALIFORNIA MANUFACTURERS & TECHNOLOGY ASSN.
Itzel Iberrio THE GREENLINING INSTITUTE 785 MARKET STREET, 3RD FLOOR SAN FRANCISCO CA 94103-2003 (415) 284-7202 iberrio@greenlining.org For: THE GREENLINING INSTITUTE Denis George Energy Manager THE KROGER COMPANY 1014 VINE STREET CINCINNATI OH 45202 (513) 762-4538 dgeorge@kroger.com For: The Kroger Company Matthew Freedman Attorney At Law THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO CA 94102 (415) 929-8876 EX314 freedman@turn.org For: The Utility Reform Network (TURN) Robert Finkelstein Attorney At Law THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO CA 94102 (415) 929-8876 X-301 bfinkelstein@turn.org For: The Utility Reform Network (TURN) Michael Shames Attorney At Law UTILITY CONSUMERS' ACTION NETWORK 3100 FIFTH AVE., SUITE B SAN DIEGO CA 92103 (619) 696-6966 mshames@ucan.org For: Utility Consumers' Action Network (UCAN) Bernardo R. Garcia UTILITY WORKERS UNION OF AMERICA,AFL-CIO PO BOX 5198 OCEANSIDE CA 92052-5198 (949) 369-9936 uwuaregion5@earthlink.net For: Utility Workers Union of America, AFL-CIO	Jerry Bloom MARGARET ROSTKER (EMAIL: ROSTKMA@LAWHITE Attorney At Law WHITE & CASE TWO EMBARCADERO CENTER, SUITE 650 SAN FRANCISCO CA 94111 (415) 544-1104 bloomje@la.whitecase.com For: California Cogeneration Council Jason J. Zeller Legal Division RM. 5002 505 VAN NESS AVE San Francisco CA 94102 (415) 703-4673 jjz@cpuc.ca.gov For: Office of Ratepayer Advocates ********** STATE EMPLOYEE *********** Truman L. Burns Office of Ratepayer Advocates RM. 4209 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2932 txb@cpuc.ca.gov For: OFFICE OF RATEPAYER ADVOCATES Michael W. Neville Attorney At Law CALIFORNIA ATTORNEY GENERAL'S OFFICE 455 GOLDEN GATE AVENUE, SUITE 11000 SAN FRANCISCO CA 94102-7004 (415) 703-5523 michael.neville@doj.ca.gov For: CALIFORNIA RESOURCES AGENCY Michael Jaske CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS-22 SACRAMENTO CA 95814 (916) 654-4777 mjaske@energy.state.ca.us Monica Schwebs Attorney At Law CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS-14 SACRAMENTO CA 95814-5512 (916) 654-5207 mschwebs@energy.state.ca.us
Robert Pernell CALIFORNIA ENERGY COMMISSION 1516 9TH STREET SACRAMENTO CA 95829 (916) 654-5036 rpernell@energy.state.ca.us For: CALIFORNIA ENERGY COMMISSION (CEC) Ruben Tavares Electricity Analysis Office CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS 20 SACRAMENTO CA 95814 (916) 654-5171 rtavares@energy.state.ca.us For: California Energy Commission Shirley Liu CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS-20 SACRAMENTO CA 95814-5504 (916) 651-9856 sliu@energy.state.ca.us Angela Minkin Administrative Law Judge CALIFORNIA PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE, ROOM 5116 SAN FRANCISCO CA 94102 a0011038@cpuc.ca.gov For: cpuc Roderick A Campbell Energy Division 770 L STREET, SUITE 1050 Sacramento CA 95814 (916) 327-1418 rax@cpuc.ca.gov Sean F. Casey Office of Ratepayer Advocates RM. 4205 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1667 sfc@cpuc.ca.gov For: Office of Ratepayer Advocates Amy W Chan Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1509 amy@cpuc.ca.gov For: Energy Division	Robert Miyashiro DEPT. OF FINANCE STATE CAPITOL, RM 1145 SACRAMENTO CA 95814 (916) 445-8610 firmiyas@dof.ca.gov For: DEPT. OF FINANCE (DOF) Christopher Danforth Office of Ratepayer Advocates RM. 4101 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1481 ctd@cpuc.ca.gov For: Office of Ratepayer Advocates Joseph R. DeUlloa Administrative Law Judge Division RM. 5105 505 VAN NESS AVE San Francisco CA 94102 (415) 703-3124 jrd@cpuc.ca.gov Pamela Durgin Energy Division RM. 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1124 pmd@cpuc.ca.gov Robert T. Feraru Executive Division RM. 5303 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2074 rtf@cpuc.ca.gov For: Public Advisor's Office Faline Fua Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2481 fua@cpuc.ca.gov
Julie Halligan Executive Division RM. 5215 505 VAN NESS AVE San Francisco CA 94102 (415) 703-3491 jmh@cpuc.ca.gov Audra Hartmann Executive Division 770 L STREET, SUITE 1050 Sacramento CA 95814 (916) 327-1417 ath@cpuc.ca.gov Kayode Kajopaiye Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2557 kok@cpuc.ca.gov For: Energy Division Dexter E. Khoury Office of Ratepayer Advocates RM. 4205 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1200 bsl@cpuc.ca.gov For: Office of Ratepayer Advocates Robert Kinosian Executive Division RM. 4209 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1500 gig@cpuc.ca.gov For: Office of Ratepayer Advocates Laura L. Krannawitter Executive Division RM. 5210 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2538 llk@cpuc.ca.gov	Donald J. Lafrenz Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1063 dlf@cpuc.ca.gov For: Energy Division Steve Linsey Office of Ratepayer Advocates RM. 4101 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1341 car@cpuc.ca.gov For: Office of Ratepayer Advocates Kimberly Lippi Legal Division RM. 4107 505 VAN NESS AVE San Francisco CA 94102 (415) 703-5822 kjl@cpuc.ca.gov Jeanette Lo Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1825 jlo@cpuc.ca.gov For: Energy Division Anne W. Premo Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1247 awp@cpuc.ca.gov For: CPUC ENERGY DIVISION Thomas R. Pulsifer Administrative Law Judge Division RM. 5005 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2386 trp@cpuc.ca.gov
Steve Roscow Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1189 scr@cpuc.ca.gov Steven C Ross Office of Ratepayer Advocates RM. 4102 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2140 sro@cpuc.ca.gov Randy Chinn SENATE ENERGY COMMITTEE ROMM 408 STATE CAPITOL SACRAMENTO CA 95814 randy.chinn@senate.ca.gov Linda Serizawa Executive Division RM. 5119 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1383 lss@cpuc.ca.gov Maria E. Stevens Executive Division RM. 500 320 WEST 4TH STREET SUITE 500 Los Angeles CA 90013 (213) 576-7012 mer@cpuc.ca.gov Maria Vanko Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2818 mv1@cpuc.ca.gov For: Energy Division Christine M. Walwyn Administrative Law Judge Division RM. 5101 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2301 cmw@cpuc.ca.gov	Rosalina White Executive Division RM. 5303 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2074 raw@cpuc.ca.gov John S. Wong Administrative Law Judge Division RM. 5019 505 VAN NESS AVE San Francisco CA 94102 (415) 703-3130 jsw@cpuc.ca.gov Helen W. Yee Legal Division RM. 5031 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2474 yee@cpuc.ca.gov Amy C Yip-Kikugawa Legal Division RM. 5135 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2004 ayk@cpuc.ca.gov ********* INFORMATION ONLY ********** David Marcus ADAMS BROADWELL & JOSEPH PO BOX 1287 BERKELEY CA 94701-1287 (510) 528-0728 dmarcus@slip.net For: Coalition of California Utility Employees Michael Alcantar Attorney At Law ALCANTAR & KAHL LLP 120 MONTGOMERY STREET, SUITE 2200 SAN FRANCISCO CA 94104 mpa@a-klaw.com Ira Schoenholtz President AMERICAN ASSN OF BUSINESS PERSONS W/DIS 2 WOODHOLLOW IRVINE CA 92604-3229 (949) 559-1516 For: American Association of Business Persons with Disabilities
Frank Annunziato President AMERICAN UTILITY NETWORK INC. 1746 N VALLEJO WAY UPLAND CA 91784 (909) 989-4000 ROTT1@aol.com Edward G. Poole Attorney At Law ANDERSON & POOLE 601 CALIFORNIA STREET, SUITE 1300 SAN FRANCISCO CA 94108-2818 (415) 956-6413 epoole@adplaw.com For: INDEPENDENT OIL PRODUCERS AGENCY (IOPA) Robert E. Anderson APS ENERGY SERVICES 1500 FIRST AVENUE ROCHESTER MN 55906 (507) 289-0800 bob_anderson@apses.com For: APS ENERGY SERVICES Ed Cazalet AUTOMATED POWER EXCHANGE, INC. 5201 GREAT AMERICA PARKWAY SANTA CLARA CA 95054 (408) 517-2900 ed@apx.com For: Automated Power Exchange, Inc. Scott Blaising Attorney At Law BRAUN & ASSOCIATES, P.C. 8980 MOONEY ROAD ELK GROVE CA 95624 (916) 682-9702 blaising@braunlegal.com Paul A. Harris BRIDGE NEWS 44 MONTGOMERY, SUITE 2410 SAN FRANCISCO CA 94104 (415) 835-7641 paul.harris@bridge.com For: BRIDGE NEWS Mona Patel BROWN & WOOD LLP 555 CALIFORNIA STREET, 50TH FLOOR SAN FRANCISCO CA 94104 (415) 772-1265 mpatel@sidley.com	Stephen Layman CALIFORNIA ENERGY COMMISSION, EIAD 1516 9TH STREET, MS-20 SACRAMENTO CA 95814 (916) 654-4845 Slayman@energy.state.ca.us Derk Pippin CALIFORNIA ENERGY MARKETS 9 ROSCOE STREET SAN FRANCISCO CA 94110-5921 (415) 824-3222 derkp@newsdata.com For: CALIFORNIA ENERGY MARKETS (CEM) J. A. Savage CALIFORNIA ENERGY MARKETS 3006 SHEFFIELD AVENUE OAKLAND CA 94602-1545 (510) 534-9109 honest@compuserve.com For: California Energy Markets Lulu Weinzimer CALIFORNIA ENERGY MARKETS 9 ROSCOE STREET SAN FRANCISCO CA 94110 (415) 824-3222 luluw@newsdata.com William Dombrowski CALIFORNIA RETAILERS ASSOCIATION 980 9TH STREET, SUITE 2100 SACRAMENTO CA 95814-2741 (916) 443-1975 Alexandre B. Makler CALPINE CORPORATION PO BOX 11749 PLEASANTON CA 94588-1749 (925) 479-6600 alexm@calpine.com For: CALPINE CORPORATION Bill Woods CALPINE CORPORATION PO BOX 11749 PLEASANTON CA 94588-1749 (925) 479-6600 billw@calpine.com
Karen Cann 3100 ZINFANDEL DRIVE, SUITE 600 RANCHO CORDOVA CA 95670-6026 (916) 631-4055 kcann@navigantconsulting.com Kevin Duggan CAPSTONE TURBINE CORPORATION 21211 NORDHOFF STREET CHATSWORTH CA 91311 (818) 734-5455 kduggan@capstoneturbine.com Douglas L. Anderson Vice President And General Counsel CE GENERATION, LLC 302 SOUTH 36TH STREET, SUITE 400 OMAHA NE 68131 (402) 231-1642 doug.anderson@calenergy.com John A. Barthrop General Counsel COMMONWEALTH ENERGY CORP. 15901 RED HILL AVE., SUITE 100 TUSTIN CA 92780 (714) 259-2586 jbarthrop@electric.com For: Commonwealth Energy Corp. Angela Oh Advisor COMMUNITY TECHNOLOGY POLICY COUNCIL PMB 7000-639 REDONDO BEACH CA 90277 June M. Skillman COMPLETE ENERGY SERVICES, INC. 650 E. PARKRIDGE AVENUE, UNIT 110 CORONA CA 92879 (909) 280-9411 jskillman@prodigy.net Melanie Gillette DUKE ENERGY NORTH AMERICA 980 NINTH STREET, SUITE 1540 SACRAMENTO CA 95814 (916) 319-4620 mlgillette@duke-energy.com	Joseph M. Paul DYNEGY MARKETING & TRADE 5976 WEST LAS POSITAS BLVD., STE. 200 PLEASANTON CA 94588 (925) 469-2314 joe.paul@dynegy.com Gregory T. Blue Manager, State Regulatory Affairs DYNEGY, INC. 5976 W. LAS POSITAS BLVD., STE. 200 PLEASANTON CA 94588 (925) 469-2355 gtbl@dynegy.com For: Dynegy, Inc. Joseph A. Young EAST BAY MUNICIPAL UTILITY DISTRICT PO BOX 24055 OAKLAND CA 94623-1055 (510) 287-0147 joeyoung@ebmud.com Wendy Illingworth ECONOMIC INSIGHTS 320 FEATHER LANE SANTA CRUZ CA 95060 (831) 427-2163 wendy@econinsights.com Jon S. Silva Government Affairs Associate EDISON SOURCE 955 OVERLAND COURT SAN DIMAS CA 91773 (909) 450-6035 Susan A. Huse Research Analyst EES CONSULTING, INC. 12011 BEL-RED ROAD, SUITE 200 BELLEVUE WA 98005-2471 (425) 452-9200 huse@eesconsulting.com Jeffrey D. Harris Attorney At Law ELLISON & SCHNEIDER 2015 H STREET SACRAMENTO CA 95814-3105 (916) 447-2166 jdh@eslawfirm.com For: Sacramento Municipal Utility District
James Meyn Senior Structure Power Representative ENGAGE ENERGY US, L.P. 8880 RIO SAN DIEGO DRIVE SAN DIEGO CA 92108-1634 (619) 702-9501 Gary B. Ackerman FOOTHILL SERVICES, INC. 340 AUGUST CIRCLE MENLO PARK CA 94025 foothill@lmi.net For: Western Power Trading Forum Robert D. Schasel FRITO-LAY, INC. 7701 LEGACY DRIVE (4C-101) PLANO TX 75024-4099 (972) 334-7000 robert.d.schasel@fritolay.com H. Bradley Donovan Senior Vice President GEORGE WEISS ASSOCIATES, INC. 660 MADISON AVENUE, 16TH FLOOR NEW YORK NY 10021-8405 (212) 415-4567 hbd@gweiss.com Douglas E. Davie HENWOOD ENERGY SERVICES, INC. 2710 GATEWAY OAKS DRIVE, STE. 300 NORTH SACRAMENTO CA 95833 (916) 569-0985 ddavie@hesinet.com Jeffrey D. Schlichting HMH RESOURCES, INC. 100 LARKSPUR LANDING, SUITE 213 LARKSPUR CA 94939 (415) 289-4080 jeff@hmhresources.com Miriam Maxian J.P. MORGAN SECURITIES, INC. 101 CALIFORNIA STREET, 37TH FLOOR SAN FRANCISCO CA 94111 (415) 954-3297 maxian_miriam@jpmorgan.com	Joelle Ogg JOHN & HENGERER 1200 17TH STREET, NW, STE 600 WASHINGTON DC 20036 (202) 429-8812 jogg@jhenergy.com Ralph Smith LARKIN & ASSOCIATES, INC. 15728 FARMINGTON ROAD LIVONIA MI 48154 (734) 522-3420 ad046@detroit.freenet.org For: Larkin & Associates, Inc. Karen Lindh LINDH & ASSOCIATES 7909 WALERGA ROAD, ROOM 112, PMB 119 ANTELOPE CA 95843 (916) 729-1562 karen@klindh.com For: California Manufacturers Assn. Richard Mccann Ph.D M.CUBED 2655 PORTAGE BAY, SUITE 3 DAVIS CA 95616 (530) 757-6363 rmccann@cal.net Candace A. Younger MANATT, PHELPS & PHILLIPS, LLP 11355 WEST OLYMPIC BOULEVARD LOS ANGELES CA 90064 (310) 312-4000 cyounger@manatt.com Randall W. Keen MANATT, PHELPS & PHILLIPS, LLP 11355 WEST OLYMPIC BLVD. LOS ANGELES CA 90064 (310) 312-4000 rkeen@manatt.com Andrew Ulmer Attorney At Law MBV LAW, LLP 855 FRONT STREET SAN FRANCISCO CA 94111 (415) 781-4400 andrew@mbvlaw.com
Thomas S. Hixson MCCUTCHEN, DOYLE, BROWN & ENERSEN, LLP THREE EMBARCADERO CENTER SAN FRANCISCO CA 94111 (415) 393-2000 thixson@mdbe.com Christopher J. Mayer MODESTO IRRIGATION DISTRICT PO BOX 4060 MODESTO CA 95352-4060 (209) 526-7430 chrism@mid.org For: MODESTO IRRIGATION DISTRICT (MID) Robert B. Weisenmiller MRW & ASSOCIATES 1999 HARRISON STREET, SUITE 1440 OAKLAND CA 94612-3517 (510) 834-1999 rbw@mrwassoc.com For: MRW & Associaes Gary Herbert MSDW ONE TOWER BRIDGE, 11TH FLOOR WEST CONSHOHOCKEN PA 19428 (610) 940-4524 gerhordt.herbert@msdw.com Stephen St. Marie NAVIGANT CONSULTING, INC. 3100 ZINFANDEL DRIVE, SUITE 600 RANCHO CORDOVA CA 95670-6026 (916) 631-3200 sstmarie@navigantconsulting.com Kay Davoodi NAVY RATE INTERVENTION OFFICE WASHINGTON NAVY YARD 1314 HARWOOD STREET SE WASHINGTON NAVY YARD DC 20374-5018 (202) 685-0130 DavoodiKR@efaches.navfac.navy.mil For: Navy Rate Intervention Martin Mattes Attorney At Law NOSSAMAN GUTHNER KNOX & ELLIOTT, LLP 50 CALIFORNIA STREET, 34TH FLOOR SAN FRANCISCO CA 94111-4799 (415) 438-7273 mmattes@nossaman.com	Kris Cheh O'MELVENY & MYERS LLP 400 SOUTH HOPE STREET LOS ANGELES CA 90071 (213) 430-6463 kcheh@omm.com Eve Mitchell OAKLAND TRIBUNE 401 13TH ST. OAKLAND CA 94612 (510) 208-6474 emitchel@angnewspapers.com Michael D. Hornstein ORRICK,HERRINGTON&SUTCHLIFFE LLP WASHINGTON HARBOUR 3050 K STREET, NW WASHINGTON DC 20007-5135 (202) 339-8461 mhornstein@orrick.com Merrill L. Kramer ORRICK,HERRINGTON&SUTCLIFFE,LLP 3050 K STREET, NW WASHINGTON DC 20007-5135 (202) 399-8442 mkramer@orrick.com Carl K. Oshiro Attorney At Law 100 FIRST STREET, SUITE 2540 SAN FRANCISCO CA 94105 (415) 927-0158 oshirock@pacbell.net For: CALIFORNIA SMALL BUSINESS ASSOCIATION AND CALIFORNIA SMALL BUSINESS ROUNDTABLE Jonathan Jacobs PA CONSULTING GROUP 75 NOVA DRIVE PIEDMONT CA 94610-1037 (510) 654-9495 jon.jacobs@paconsulting.com For: PA CONSULTING GROUP Gail L. Slocum Attorney At Law PACIFIC GAS AND ELECTRIC CO. 77 BEALE ST. RM 3143 SAN FRANCISCO CA 94105 (415) 973-6583 glsg@pge.com
Bruce Bowen Mailcode B10a PACIFIC GAS AND ELECTRIC COMPANY PO BOX 770000 SAN FRANCISCO CA 94177 brb3@pge.com Dan Pease PACIFIC GAS AND ELECTRIC COMPANY MAILCODE B10B PO BOX 70000 SAN FRANCISCO CA 94177 drp6@pge.com Ed Lucha PACIFIC GAS AND ELECTRIC COMPANY MAIL CODE: B9A PO BOX 770000 SAN FRANCISCO CA 94177 (415) 973-3872 ell5@pge.com Janice Frazier-Hampton PACIFIC GAS AND ELECTRIC COMPANY MAIL CODE B9A PO BOX 770000 SAN FRANCISCO CA 94177 (415) 973-2254 jyf1@pge.com Mark R. Huffman Attorney PACIFIC GAS AND ELECTRIC COMPANY MAIL CODE B30A PO BOX 77000 SAN FRANCISCO CA 94177 (415) 973-3842 mrh2@pge.com Niels Kjellund PACIFIC GAS AND ELECTRIC COMPANY MAIL CODE 859A PO BOX 770000 SAN FRANCISCO CA 94177 NXK2@pge.com Roger J. Peters PACIFIC GAS AND ELECTRIC COMPANY MAIL CODE B30A PO BOX 7442 SAN FRANCISCO CA 94120 RJP2@pge.com	Ron Helgens PACIFIC GAS AND ELECTRIC COMPANY MAIL CODE B9A PO BOX 770000 SAN FRANCISCO CA 94177 (415) 973-7524 rrh3@pge.com Roxanne Piccillo Regulatory Analysis PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE ST., ROOM 1075 SAN FRANCISCO CA 94105 (415) 973-6593 rtp1@pge.com George A. Perrault 1813 FAYMONT AVENUE MANHATTAN BEACH CA 90266 (310) 379-0901 perrault@perrcon.net Margery Neis PRICEWATERHOUSECOOPERS, LLP 199 FREMONT STREET, 8TH FLOOR SAN FRANCISCO CA 94105 margery.a.neis@us.pwcglobal.com Jean Pierre Batmale REALENERGY, INC. 5957 VARIEL AVE. WOODLAND HIILS CA 91367 (818) 610-2300 jpbatmale@realenergy.com Carrie Peyton SACRAMENTO BEE PO BOX 15779 SACRAMENTO CA 95852 (916) 321-1086 cpeyton@sacbee.com Tim Haines SACRAMENTO MUNICIPAL UTILITY DISTRICT PO BOX 15830 SACRAMENTO CA 95852-1830 (916) 732-6342 thaines@smud.org For: Sacramento Municipal Utility District
Michael Bazeley SAN JOSE MERCURY NEWS 111 ELLIS STREET, 3RD FLOOR SAN FRANCISCO CA 94102 (415) 434-1018 mbazeley@sjmercury.com James E. Hay SEMPRA ENERGY 101 ASH STREET SAN DIEGO CA 92112 (619) 696-2141 jhay@sempra.com For: Sempra Judy Peck Admin. State Regulatory Relations SEMPRA ENERGY 601 VAN NESS AVENUE, SUITE 2060 SAN FRANCISCO CA 94102 (415) 202-9986 jpeck@sempra.com Lynn G. Van Wagenen Regulatory Affairs Project Manager SEMPRA ENERGY 101 ASH STREET, ROOM 10A SAN DIEGO CA 92101 (619) 696-4055 LVanWagenen@sempra.com For: Sempra Energy Theodore Roberts Attorney At Law SEMPRA ENERGY 101 ASH STREET, HQ 13D SAN DIEGO CA 92101 (619) 699-5195 troberts@sempra.com G. Darryl Reed SIDLEY & AUSTIN 10 S. DEARBORN CHICAGO IL 60603 (312) 853-7766 gdreed@sidley.com For: SIDLEY & AUSTIN 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 SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE ROSEMEAD CA 91770 (626) 302-3115 frank.cooley@sce.com For: SOUTHERN CALIFORNIA EDISON COMPANY (SCE) Stephen E. Pickett RONALD L. OLSON Attorney At Law SOUTHERN CALIFORNIA EDISON COMPANY 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 Paul C. Lacourciere THELEN REID & PRIEST LLP 101 SECOND STREET, SUITE 1800 SAN FRANCISCO CA 94105-3601 (415) 369-8765 placourciere@thelenreid.com Fred Wesley Monier TURLOCK IRRIGATION DISTRICT PO BOX 949 333 EAST CANAL DRIVE TURLOCK CA 95381-0949 (209) 883-8321 fwmonier@tid.org Bill C. Wells Lt. Col. TYNDALL AFB 139 BARNES DRIVE, SUITE 1 TYNDALL AFB FL 32403-5319 (850) 283-6347 bill.wells@tyndall.af.mil For: AIR FORCE LEGAL SERVICES AGENCY
Patricia Vanmidde Consultant 22006 N 55TH ST. PHOENIX AZ 85054 (480) 515-2849 pvanmidde@earthlink.net Tony Wetzel 631 HANCOCK DRIVE FOLSOM CA 95630 (916) 985-3499 tonywetzel@home.com Sam Wise 4045 PALOS VERDES DR. NORTH ROLLING HILLS ESTATES CA 90274 (310) 377-1577

(END OF APPENDIX D)