Wood Alternate Comment Dec. Final Opinion Approval with Modifications of the Interim Settlement Enhancing and Enabling Competitive Markets on the SoCalGas Company System and Other Decisiions on the Promising Options Set Forth in D.99-07-015

IV. CONCLUSION

SoCalGas, SDG&E, and other parties have been highly responsive to the Commission's direction in this proceeding. However, recent events lead us to conclude that we should not, at this point, adopt the centerpiece of this investigation, the unbundling of intrastate transmission and the implementation of a system of firm, tradable intrastate transmission and storage rights. This unbundling is the basis of the CS, and we cannot approve it. We will, however, review SoCalGas' most recent firm transmission rights proposal in the currently pending BCAP.

We are convinced that the IS generally balances the various interests at stake for the period of the settlement. Thus, we find that the IS, as modified, is reasonable in light of the whole record, consistent with the law and in the public interest.

Based on the record in R.98-01-011 and I.99-07-003, we also find that now is the time for other gas industry reforms. These include the elimination of core contribution to the ITCS, and the elimination of core.