Advice Letters:

San Diego filed an advice letter (1260-E) which I faxed two weeks ago dealing 
with the application of the rate cap to DA customers.  Subsequently, October 
30, SDG&E filed an amended advice letter 1260-E-A (replacing 1260-E).  The 
earlier advice letter had a lot more specificity about how to deal with 
applying the credit to DA customers that the amended advice letter omits.  We 
need to determine if we wish SDG&E to include any of the following in their 
treatment of the credit for DA customers.  We have 20 days from October 30 to 
file a protest.

For example:

If the customer received consolidated billing service from the utility, the 
credit from the cap would be applied against the otherwise applicable San 
Diego charges.

If the customer was dual billed, the credit would apply against the San Diego 
portion of the bill.

If the customer received ESP consolidated billing from the ESP, the credit 
would be highlighted through a separate line item.  If the credit surpassed 
SDG&E's charges, there would be no amount payable to SDG&E for that month.  
If there was a credit balance remaining against SDG&E's charges, it could be 
carried over into the next month, or cashed out.  

SDG&E provided a second option.  This would provide the credits to the ESP 
and the ESP would be responsible for any future repayment of the cost.

We have until November 7 to file comments on their proposal.  I think we 
would appreciate a separate line-item identifying the amount of the credit.  
However, I believe the identification should be the same for all customers, 
irrespective of the billing choice.  Because we currently don't have an 
obligation to flow through the PX credit amount to our customers, I don't 
believe we should have an obligation to flow-through the additional credit 
relative to the cap, but we need legal review of my assumption.

We may also want to consider if we have a preference for how we would handle 
the additional credit relative to the cap for our customers.  That may help 
us decide if we want to support having the option of choosing between a 
line-item or managing those funds for our customers.  (This is another way of 
alleviating a customer's concern about a balloon payment at some future date.)

Some ESPs are also approaching SDG&E about an "opt-out" provision of the rate 
cap for DA customers.  I am concerned, and am checking, to see if SDG&E can 
legally do this.

Customer Facilitation Program:

The majority of the ESPs elected to wait until the issue of the 
implementation of the rate cap was decided before doing a mailing.  The 
majority also preferred one mailing to two.  Therefore, this program will not 
kick off until probably some time in January 2001.

Any questions, feel free to contact me.   Thanks.

Mona