Enclosed is a draft presentation of legal issues to be presented at the CPUC
emergency hearings in conjunction with regulatory and economic arguments set
forth in the draft comments previously distributed by Jeff Dasovich.  Jeff
and I will work to merge the legal issues into the full presentation,
subject to the duscussion on the conference call tomorrow morning.  This
presentation has been prepared in anticipation of the fact that we will
likely be limited to a very short verbal presentation tomorrow.  A more
extensive legal analysis of all these points is being prepared to accompany
any briefs or written comments which we are permitted to file later.  Please
e-mail comments using the reply function to MBD at this address before the
conference call if at all possible.  Thank you.  Mike Day


<<X19418.DOC>>

 - X19418.DOC