Attached for your information is a joint petition for modification of the
1998 Revenue Adjustment Proceeding ("RAP") decision filed today by SCE, PG&E
and SDG&E.  The utilities request that, on an expedited basis, the
Commission limit the scope of the PX Credit audit which WPTF obtained in a
negotiated settlement in the 1998 RAP proceeding to remaining year 2000
calculations and thereafter order that the audit be terminated.  They state
that the audit is both irrelevant and costly and that "common sense demands"
the Commission reconsider the decision.

They ask that comments in opposition be filed by August 3, reply comments on
August 10 and a Commission decision at its meeting scheduled for August 23.
They also ask the Commission to waive the period provided in Rule 77.7 for
comments and reply comments on a draft decision in order that the decision
become final immediately.

The filing states that there have been dramatic changes in energy markets,
the number of DA customers has declined significantly and that ratepayers
should not have to pay for the audit.  Of course, they don't mention that
the reason for the decline in DA customers is their own failure to pay the
PX Credit.  It is instead attributed to the "dysfunctional restructuring
scheme and concommitant rise in wholesale energy prices."  They justify
their request legally by stating that their filing demonstrates that there
are "significant new facts" and a "material change in conditions."  The
third criteria for reopening or modifying a Commission decision, a basic
misconception of law or fact by the Commission, is not alleged to have
occurred.

They also state that DA penetration will continue to decline because
"Assembly Bills X1-1 and X1-6 have effectively reregulated the market."

Attached to the filing are declarations from the three ESP members of the
Audit Committee, Bob Anderson of APSES,  Aaron Thomas of AES NewEnergy and
Marilynn Semro of Seattle City Light Department, in support of the
utilities' petition.  I have not reviewed the specific wording changes to
the RAP decision to determine if there are any problems with the proposed
modifications.

Dan

Law Offices of Daniel W. Douglass
5959 Topanga Canyon Blvd.  Suite 244
Woodland Hills, CA 91367
Tel:   (818) 596-2201
Fax:  (818) 346-6502
douglass@energyattorney.com

 - 7-10-01 RAP Joint Petition.PDF