Mona,

Your business instincts are correct.  SDG&E's proposed treatment is 
inequitable.  Overcollections recovered from all customer classes should not 
be used to fund the rate cap that benefit only some customer classes.  I do 
not think this is necessarily a DA versus SO issue, but rather mor of a large 
versus small customer issue (however, to the extent that only large SO 
customers can opt in and benefit there is a disparity between large DA and 
SO).  Can you please check with CLECA and CEMA to see what they are doing.  
Given that most of our customers are large customers, we should have an issue 
with this treatment.  There is something extremely anti-competitive in 
over-collecting from all customers in a non-bypassable rate to subsidize 
small customers.  I don't think that small DA and SO customers are being 
treated differently, because the utility is implementing a cap with a PX 
credit for small DA customers.  But correct me if I am wrong.  It may be 
viewed as a DA versus SO issue, since most DA customers are large and very 
few DA customers are small.  Further, we should point this out in SDG&E's 
filing at FERC to use the FERC jurisdictional rate to overcollect and 
subsidize small customers.  Obviously, SDG&E is trying to minimize the 
undercollections from the cap to mitigate shareholder risk of non-recovery in 
the future.  We will need to be careful in our complaints, because of the 
issues that we are pursuing for PG&E and SCE.  We want to cooperate with the 
Governor's programs, but only if the solutions for PG&E and SCE are equitable 
for DA as well.

Roger

 




Mona L Petrochko
10/09/2000 05:22 PM
To: Roger Yang
cc:  
Subject: Re: SDG&E Advice Letters

It is beginning to look like ANY overcollected balance goes into the 
subaccount to offset undercollected procurement costs.  Wouldn't we have an 
interest in raising objections to RMR overcollections going into that 
account, to the extent that those costs were collected from all customers?
---------------------- Forwarded by Mona L Petrochko/SFO/EES on 10/09/2000 
03:21 PM ---------------------------


"Daniel Douglass" <douglass@ArterHadden.com> on 10/09/2000 12:21:08 PM
To: <ryang@enron.com>
cc: <Jeff_Dasovich@enron.com>, <marcie.milner@enron.com>, 
<mpetroch@enron.com>, <Roger_Yang@enron.com>, <susan_j_mara@enron.com> 
Subject: Re: SDG&E Advice Letters


Here is AL 1262-E.

>>> <ryang@enron.com>  10/09/00 11:17AM >>>


We need to take a look at AL1262-E to  ensure that those who do not benefit
from the rate stabilization receive  their fair share of the refunds.

Roger






"Daniel  Douglass" <douglass@ArterHadden.com> on 10/09/2000 01:01:13  PM

To:?? <Jeff_Dasovich@enron.com>,  <marcie.milner@enron.com>,
?????  <mpetroch@enron.com>,  <Roger_Yang@enron.com>,
?????  <susan_j_mara@enron.com>
cc:
Subject:? SDG&E Advice  Letters



Attached are summaries of three recent SDG&E advice  letters.? Two? ought to
be looked at, but may not rise to the level  of protests.

Dan
(See attached file: 10-9-00 SDG&E AL Summary  Chart.doc)



 - 1262-E_1.pdf