PROTESTS

Advice Letter 1461-E was protested by ORA on July 21, 2000. ORA claims SCE has violated Commission procedures by unilaterally reducing EDR customer rates and asking for retroactive approval. ORA believes that EDR customers signed a contract and should be held to that contract. ORA is concerned that if the proposed change is made other customers will be forced to make up the lost revenues.

ORA recommends, in order of preference that we:

1. Deny the advice letter and defer EDR issues to the Post Transition Rate Design Application (A.) 00-01-009.

2. Enforce the current minimum charge, by placing the difference between the higher EDR rate and the OAT in a memorandum account subject to refund pending a decision in A. 00-01-009.

3. Order rates capped at the OAT rate for those SCE bundled service customers who apply for the Hourly PX Pricing Option.

SCE responded to the protest of ORA on July 28, 2000. SCE believes ORA's recommendations are flawed and do not address the inequity to the EDR customers. SCE is concerned that waiting for a decision in A.00-01-009 will involve months of delay while customers need relief now, or a least a ruling, so they can decide whether or not to terminate the EDR agreements. SCE also does not support ORA's recommendation for the Hourly PX Price option. Stating SCE believes that customers should not be forced to accept it, that the tariff would need revision, that customers would need to purchase hourly meters, and that SCE does not believe the Hourly PX Price Option will create demand responsiveness.