Scott:
Here are the foundations that ARM will use in its appeal of the PUC decision suspending DA (and threats to make it retroactive to July 1).  You should feel free to share with the business folks but under the condition that they keep it confidential.  And of course, we'd be thrilled if they'd sign on.  If you have any questions, just holler.
Best,
Jeff

The primary reasons cited for why rehearing should be granted are as follows: 
The Decision violates procedural due process guarantees. 
The failure to hold hearings violates Public Utilities Code section 1708.5(f). 
The Commission's reliance on material outside the record violates due process. 
The Decision violates the Commerce Clause of the United States Constitution. 
The threatened retroactivity is contrary to law and in excess of the Commission's authority. 
The Commission acted contrary to law and in excess of its authority. 
The Decision's purported findings are not supported. 
The Commission has impermissibly converted a ratemaking proceeding into a quasi-legislative proceeding.