2. Background

The Commission adopted the Affiliate Transaction Rules in Decision (D.) 97-12-088, as modified by D.98-08-035, and as further clarified in D.98-11-027. Edison filed this petition for modification on December 14, 1998. Edison requests that the Commission grant Edison a limited exemption to the disclaimer requirement of Rule V.F.1 of the Affiliate Transaction Rules in the following four situations: (a) building signage; (b) company vehicles; (c) employee uniforms; and (d) installed equipment on customer premises. Edison requests the Commission clarify that Rule V.F.1 does not apply to the above four situations, in a similar fashion as the Commission clarified Rule V.F.1 in another context in D.98-11-027.

On January 13, 1999, The Office of Ratepayer Advocates (ORA) and The Utility Reform Network (TURN) filed a joint response to Edison's petition. ORA and TURN request that Edison amend its petition to clarify its compliance plan for Rule V.F.1 and to provide a detailed and case-specific justification for any exemptions it its seeking to Rule V.F.1. Absent such amendment, ORA and TURN request that the petition be denied. On February 1, 1999, Edison filed a reply to ORA and TURN, where Edison more particularly described the specific situations for which it seeks exemption.