Western Power Trading Forum (WPTF)

WPTF is primarily concerned with the policy issues raised by the IOUs, and in particular is focused on the procurement process and makes suggestions for insuring competitive prices that will provide incentives for investment in new and existing generation. However, before moving on to the policy issues, WPTF does note some problems with the LTPPs and makes suggestions for improving them: PG&E should be allowed to increase its PRM in this docket, but it is best determined in the RA proceeding; SCE should not be allowed to move towards a vertically, integrated market; and the evaluation of RFP bids should be on explicit and public criteria. And, WPTF finds it unrealistic that PG&E and SCE failed to account for the possible opening of DA during the ten-year planning horizon.

The focus of WPTF's policy recommendations was in regard to the procurement policies. WPTF lists 15 recommendations, beginning with advocating that all-source solicitations are the rule and that all generating units should be allowed to bid into a RFO. The utilities, themselves, WPTF claims should not be the judge the winning bidders from a RFO when there is a utility-owned project bidding. In point of fact, from WPTF's perspective, there is no need for there to be any utility-owned generation when independent suppliers can protect ratepayers from unanticipated costs that result from plant ownership.

To further ensure fair RFOs, WPTF recommends that an IE be retained and paid for by the Commission and used in every solicitation. If PRGs are to be retained as part of the procurement review process, WPTF wants DA and CCA representatives to be a part of the PRG if there is the possibility that the costs and benefits of the resource are to be shared by all benefiting customers- because that includes DA and CCA departing load.

In summary, WPTF urges the Commission to adopt policies that promote competitive solicitations that in turn will spur economic investment in the electricity markets in general and California's in particular.

(END OF APPENDIX C)

APPENDIX D

PRG Participation Working Group August 30, 2007

PROPOSAL FOR NEW ADVISORY GROUP FOR PROCUREMENT USING COST ALLOCATION MECHANISM