Here's a cut at the taxonomy of regulatory risks associated with Direct Access. Please let me know if there are others I missed, or if there are changes needed to the ones listed.

  
1.	Retroactive Suspension of DA Contracts:  The PUC rules in a subsequent decision that DA is suspended on some date 	between July 1 and September 20th.  

2.	Contract renewal forbidden:  The PUC includes contract renewal under the suspension of DA.

3.	No incremental "DASR'ing":  The PUC includes incremental additions and subtractions of DA customer's load under the 	suspension of DA (e.g., fast food chains, University campus)

4.	Cost allocation: the PUC adds new costs to DA accounts and/or disproportionately shifts existing costs to DA accounts.  	Costs with greatest risk of being shifted to DA customers include: IOU undercollection, bonds to repay the state general fund, 	and DWR contracts.  The costs associated with these categories are substantial. 

Key risks associated with each category:
Adverse to P/L 
Adverse to hedge (demand risk)