Some thoughts for folks to think about in advance of Friday:

1.  Decision is great on defining LRMC-adopt ARM/ORA vs. UDCs
2.  Decision identifies specific adjustments to ORA from Utilities, but 
doesn't identify specific adjustments to ORA from ARM (which Dan has done) 
and which we can point to in comments. The table that compares all proposals 
is excellent!  (It's in Dan's memo) That is a great cross-reference.
3.  Need to determine whether we support an average for the state, or 
utility-specific.  Which will be more defensible?  I think utility specific.
4.  I have some challenges to the adjustments that Neeper ultimately adopted.
5.  The decision requires that the utility procurement function interact with 
the other utility functions on a comparable basis as ESPs, including access 
to information.  (Good decision language.  Don't know how to enforce.)

Here is a table summarizing the thought process of the revised alternate 
decision.  ORA-ADJ UDC, is the adjustments to ORA's proposal incorporating 
criticisms of the UDCs.  The next line (ORA-ADJ ACCPT) are those UDC 
criticisms accepted by Neeper.  The last is the machinations to average and 
incorporate a bump for ARM's participation.  

Cents per MWh

	PG&E	SCE	SDG&E
UDC	0	.02	3
ORA	48	40	15
ARM	59	67	65
ORA-ADJ UDC	18	.8	6
ORA-ADJ ACCPT	48	28	13
DECISION-AVG+	32	32	32

I think the items that Dan has identified will provide more than a 2 cent/MWh 
adjustment, so worth quantifying for the record.  These include adjustment 
for common costs and overheads (FF#27), which ORA said we did a better job 
than they had.  Also, ARM's itemization of procurement related costs, which 
ORA seemed to agree with, is more extensive. 


Challenges to Adjustments Adopted by Neeper (ORA-ADJ ACCPT)

SDG&E-(pg. 37)
1.  Would have disallowed $1.2 million.  Neeper disallowed $.2 million (pg. 
38) because those costs are being recovered in 376.  

I will research SDG&E's 376 Settlement Decision, which I believe allows for 
consideration of those costs in future unbundling proceedings.  (Not sure 
about SDG&E, sure about SCE)

PG&E-(pg. 38)
Criticizes ORA for not doing a PG&E-specific study.  PG&E's criticism ORA for 
including customer service costs related to its distribution function.  
Neeper (pg. 40) Says ORA's proxy analysis to SCE is ok.  Discounts PG&E's 
criticism on customer service costs citing to the RAP decision that those 
costs should be included in the PX credit.

This seems to be the best place to advocate use of our numbers over ORA's.  
We did a PG&E specific study, which I think would be a valid criticism to 
ORA's numbers.  

SCE-(pg.39)
Would reduce ORA's Energy Service and Marketing costs from $12.3 to $4 
million, because it includes costs related to supply from generation 
sources.  Would reduce Customer Service and Information from $21.1 milion to 
$7.7 million saying that is the amount of CS&I the Commission had allocated 
to generation.  Neeper (pg. 40) accepts reduction of ES&M to $4 million.  
Neeper does not discuss CS&I.

Need MRW input on whether SCE's criticisms are valid.  Seems like we have 
many areas to supplement ORA's numbers, based on the table in Dan's note.