Thanks, Jeanne:

Couple of thoughts.

1) If California wants to get out of this crisis, it's critical that DWR be 
creditworthy.  Bilas' proposal helps in that regard.  We've been thinking 
pretty hard about the issue and working with DWR to try to fix 
creditworthiness concerns.  Christian, it might make sense to put together 
some comments supporting Bilas' approach and perhaps give him some additional 
recommendations about what the PUC needs to do to get DWR creditworthy? If 
so, (see note below), we have an opportunity to provide those comments to the 
PUC by this Friday.

2) Scott Govenar--on the direct access piece.  Seems like it would be very 
useful to get the DA coalition we're working with in Sacramento to jointly 
file some comments on Friday in response to the Bilas proposal supporting a 
ban on any PUC action on the DA prohibition since the Legislature is still 
working on it.  What are your thoughts?  And if you and the rest of the 
Sacramento team agree, can we work with Jeanne to get some (brief) language 
put together and work to get the rest of the coalition to sign on.  
Alternatively, we could work to get the other folks file individually.  Your 
thoughts on both approaches is appreciated.

Best,
Jeff



	JMB <JBennett@GMSSR.com>
	02/27/2001 10:04 AM
		 
		 To: "'Bob Frank (E-mail)'" <robert.frank@enron.com>, "'Harry Kingerski 
(E-mail)'" <Harry.Kingerski@enron.com>, "'Jeff Dasovich (E-mail)'" 
<jdasovic@enron.com>, "'Sue Mara (E-mail)'" <smara@enron.com>, "'Tamara 
Johnson (E-mail)'" <tjohnso8@enron.com>, "'sstoness@enron.com'" 
<sstoness@enron.com>
		 cc: 
		 Subject: Alternate Decision on CPA Implementation

On Friday (February 23rd), Commissioner Bilas issued an alternate decision
to the February 20th draft ALJ decision on interim implementation of the
California Procurement Adjustment.    Basically what the Bilas alternate
does is give DWR certain assurances, without any money right now.  It
provides Commission recognition that the purchases made by DWR are not
subject to Commission reasonableness review and that once DWR has provided
the Commission with its needed revenue requirement that the Commission must
pass it through to ratepayers.  What it does not do is implement a CPA
mechanism.  The Bilas draft recognizes that the matter is being dressed
through the process established by ALJ Deulloa and a decision on it should
be rendered by the end of March. The Bilas draft also states that the
Commission "shall stay action on implementation of suspension of direct
access under water code section 80110 until further order."

If we want to comment on the Bilas draft, they are due on Friday the 2nd.  I
think Bilas' approach makes sense.  Adoption of the ALJ draft decision would
mean the implementation of an interim CPA mechanism for a few weeks, to
potentially be replaced by another interim mechanism at the end of March, to
ultimately be replaced by a final CPA mechanism.

As for the Bilas language on direct access -- while it is good, I think we
were successful in removing the direct access suspension language from the
ALJ's Draft Decision (it was removed in the version released on the morning
of the last commission meeting), so I think we have that point covered
regardless of which order gets voted out.

I will fax a copy of the draft to Harry and Sue (I don't have an e-mail
version). Let me know if you feel we should comment.

Jeanne Bennett