PROTESTS

On August 24, 2000, Premier Utility Consultants, Inc (Premier) protested Advice Letter 1479-E. Premier states that when customers agreed to participate in Schedules D-APS and GS-APS the program and the limit on interruptions was clearly enumerated. In exchange for a discount, the customers would agree to be curtailed up to 15 times a year for no more than six hours per occurrence. Premier does not support changing the terms of the agreement. Premier recommends that if the proposed change is adopted, customers be notified of the program change and be given to opportunity to exit the program without penalty. Premier also expresses concern that SCE's motivation for the proposed change may be economic rather than reliability based.

On September 7, 2000, the Energy Division received from SCE a response to the Protest of Premier. SCE states that a customer served by Schedule D-APS or GS-APS can transfer to another rate schedule so long as it has taken service under Schedule D-APS of GS-APS for at least one year. SCE also states its proposal was not made with the intention of inconveniencing the affected customers, nor is its intention to shift the costs of procuring energy to customers.