This is a draft that Jeanne did responding to Roger.  San Diego has inflated 
their revenue requirement for 2001, as evidenced by a $200 million 
overcollection in their 2002 filing.  

I will submit an RCR for this.  We can hold off filing until we get approval.
---------------------- Forwarded by Mona L Petrochko/NA/Enron on 11/30/2000 
12:13 PM ---------------------------


JMB <JBennett@GMSSR.com> on 11/16/2000 12:34:57 PM
To: "'mpetroch@enron.com'" <mpetroch@enron.com>, "'ryang@enron.com'" 
<ryang@enron.com>
cc:  

Subject: Petition for Modification of SDG&E ATCP Decision


Mona / Roger ----

Attached is a draft of the petition for modification to SDG&E ATCP Decision
adopting a $115 million CTC Revenue Requirement for 2001.  It is incomplete
as we need to talk about two items:

(1) if we ask the Commission to modify the $115 million revenue requirement
-- are we proposing something in its stead? Are we asking the Commission to
require SDG&E to file a new proposal???

(2)  In Decision 00-09-040 the Commission authorized SDG&E to establish a
subaccount in the TCBA to record any undercollections from its rate ceiling.
It also authorized SDG&E to offset those undercollection against any
revenues from SONGS, QFs, etc.  In its advice letter implementing the
commission's directive, SDG&E has stated that the shortfall in the new
subaccount will be reduced "by the portion of the monthly TCBA
overcollections allocated to eligible customers a defined in Rule 1"Energy
Rate Ceiling" (i.e., only the portion of the CTC overcollection attributable
to customers under the rate ceiling will be used to offset the rate ceiling
undercollection). In short, SDG&E is not attempting to use the CTC revenue
overcollected from large customers to offset commodity undercollections from
small customers.  Does this make a difference to our  wanting to go for
modification?

We should talk about these items.


 <<X18426.DOC>>

Jeanne

 - X18426.DOC