attached.  Edits, comments etc. most welcome.  As Paul knows, I'm hoping to
publish this sometime this spring.  One other thing you guys should be aware
of is that I have been working this with the environmental community almost
from the inception and have their strong support.  I designed the concept to
appeal across a broad coalition, recognizing that I may NOT be able to get
Commission support and so had better have broad customer/stakeholder support. 
I don't know where you all are with the environmental community but I wanted
to mention this.  Hope to see you soon.