The draft language on SB 27X appears to be consistent with ideas offered by
Bowen's staffer Lingbloom and TURN.  It makes the following changes in the
language the direct access coalition proposed:

1. It reinserts the provision allowing a customer to select direct
access for that portion of its load not served by DWR.  Neither the
utilities nor customers nor ESPs like this.  It should be deleted.

2. It provides for an open season to switch to DA until June 1 instead
of Oct 1 as the DA coalition proposed.  We believe customers will need more
time to choose what they want to do.

3. It omits the language in (d) of the DA coalition draft which ensures
all customers pay for unrecovered bond costs.  This can be covered by the
other language in the bill but it could leave some gaps.

4. Residential and small commercial DA is unrestricted only to the
extent of load growth on the entire utility system.  This may be too
restrictive to implement AB 48X easily.  It is also somewhat unfair to
allocate all load growth to the residential class.

5.  The language about large customers switching is ok, but fails to
clarify that the standard is limited to the long term contracts of DWR (> 1
yr.) so that we are not squeezed by their short term purchases, too.

6. It omits our language that customers can select DA on an first come
first served basis for each of  these "open enrollement" options.  This is
an important clarification.

7. It omits the required notices that DWR and large customers must give
each other that they are about to switch or have power contracts commence or
terminate.  This is important for large customers in particular so that they
know when they will have chances to elect DA as the DWR sheds contracts over
time.

8. It omits the section requring for public access to the exit fees or
their calculation in advance, so customers know what their choices are.
This is very important.


Bottom Line:  All the provisions they deleted from our proposal are
worthwhile and we would like to reinsert them.  They do not alter tha basic
framework of this amendment, they just make it work better.