CLFP proposes the following changes to medium and large commercial
and industrial customer tariffs for electric service provided by Pacific Gas
and Electric Company and Southern California Edison Company.

 CLFP proposes the Commission establish an optional summer on-peak,
peak period consisting of a continuous 3-hour period during the current
summer on-peak period for both utilities.  The 3-hour period would be
selected by the customer.  Specifically:

 Service Eligibility:  Customers served as medium or large
commercial/industrial customers on time-of-use rates and metered
accordingly.  Examples - PG&E's E-19, E-20, etc. and SCE's TOU-8, etc.

 Customer Eligibility:  Electric customers processing, handling,
distributing or processing perishable food and agriculture products.  (As
noted below, since no revenue shift occurs within the class, the Commission
may consider opening the option to others.)

 Customer Charge Surcharge:  A surcharge of $130 per meter per month
for the initial summer period (2001) to offset the utilities cost for
changes to billing procedures.  In the case of optimal billing period
service customers the surcharge shall correspond with such billing period.

 Optional Summer On-Peak Period:  Any continuous 3-hour period during
the summer-on-peak period of time.  Hours may be designated by the customer
consistent with metering capabilities of the customer or changes to metering
capability.

 The reason for designation by the food processor or agriculture
commodity processing customer is in order to take into account the many
factors involved in load shedding.  Labor, harvesting schedules and
coordination with growers, delivery schedules, inspection activity, etc.
All bear upon such an effort.

 Rate for Optional Summer-On-Peak Period Service:  Energy rates for
the 3-hour period would be two times the otherwise applicable charge for
summer-on-peak energy.  The other 3 hours of the 6-hour on-peak period would
be billed at the non-peak rate and equalized for rate/revenue neutrality.
In the event partial peak periods are retained, the rate for the
non-optioned 3-hour period during the on-peak period would be adjusted to
retain revenue neutrality.  These rates would apply, as now, workdays of
Monday - Friday.

 Notice and Service:  An eligible customer must notify the utility in
writing, by fax, email, or hand delivered, to both the appropriate account
representative and the customer billing department of the request for
optional summer-on-peak period service.  The 3-hour period of optional
service and the start date for such service shall be specified.  Start dates
should coincide with billing cycles, with a minimum of seven days notice
prior to such cycle.  Optional optimal billing period customers would be
treated accordingly, except as currently provided, a two-day advance notice.

 Implementation Issues - TOU Meters and Billing.  It appears the
number of customer meters and billing changes potentially required by
optional summer on-peak period service is relatively small compared to the
total number of meters of the utilities.  

 In response to CLFP's data request by PG&E and SCE (attached) the
following is observed.

 For SCE, SIC 20 (food and kindred products) customers account for
approximately 163 meters out of about 10,000 meters.  Of the 163, all but 8
can be managed locally by the Customer Data Acquisition System.  The 8 would
appear to require a field visit.

 For PG&E, out of 11,675 TOU meters on E-19 and E-20 service, 354 or
3% of the total are SIC 20.  Of the 354 nearly half, 175, are hourly
interval meters.  The remaining 179 presumably would need a field visit for
reprogramming.  

 Conclusion:  Based upon the data supplied, metering and billing
changes required by an optional summer on-peak period program for processors
of perishable commodities, there does not seem, in CLFP's opinion, to be a
significant barrier to establishing the program.