In its ATCP filed on October 2, 2000, SDG&E's testimony demonstrates that it 
will purposefully overcollect CTCs October 1, 2000 through December 31, 2002, 
in order to help subsidize the undercollections due to its Energy Rate 
Ceiling.  Not only is SDG&E trying to apply the stranded benefits caused by 
the high market prices for energy from QFs, SONGS ICIP, and Purchased Power 
Agreements with PGE and PNM, SDG&E is trying to artificially keep the CTC 
rates charged to retail customers in place in order to accumulate 
overcollections to apply against its undercollections due to its Energy Rate 
Ceiling.  This amounts to a subsidy from customers who do not benefit from 
the ceiling, primarily large customers.  This is evidenced by the fact that 
SDG&E expects a TCBA overcollection of $229 million at the end of December 
31. 2001 based on CTC rates designed to collect $115 million in 2001 from 
retail customers per their Application. 99-09-011.  (Their is not a decision 
on this application yet, we may want to file comments if we can.)  In the 
current application filed on October 2, SDG&E proposed to continue with the 
CTC rates designed to collect $115 million plus expects an overcollection in 
stranded benefits of $37 million in stranded benefits.  An overcollection of 
$229 million at the end of 2001 combined with an additional overcollection of 
$152 million in 2002, results in a whopping $381 million overcollection that 
to apply against their estimated $528 million undercollection from the Energy 
Rate Ceiling.

This has to be illegal; overcharging all customers to benefit a few.  
Further, I have fundamental problems with the fact the SDG&E is not passing 
on stranded benefits to all customers while prices are high, because you know 
that all customers will have to pay the stranded costs when commodity prices 
are low.

We need to do something about the 2001 and 2002 CTC rates that SDG&E plans to 
put into effect.

Roger