Subject: RE: Comments: Emergency AReM Pleading
From: [email-masked]
To: [email-masked], [email-masked], [email-masked]
Cc: [email-masked]
Date: Fri, 10 Aug 2001 07:01:33 -0700 (PDT)

Peter,

The concern about customers who were never on utility service is not
just a large customer issue.  I have thousands of customers that did not
contribute to the DWR undercollection and should not have to repay it.
On the other hand, a large customer who went DA today, should have to
repay it because they enjoyed the benefits of DWR procurement for half a
year.

Rick

-----Original Message-----
From: [email-masked] [mailto:[email-masked]]
Sent: Thursday, August 09, 2001 2:41 PM
To: [email-masked]; [email-masked]
Cc: [email-masked]; [email-masked];
[email-masked]
Subject: Comments: Emergency AReM Pleading

?    The "special preference for green customers" should be less vague,
or
dropped.  This includes the reference in the 2nd paragraph in the
"Conclusions" section.  Rick, do you have something in mind?

?  On its face, this bullet looks like it's reaching (too far):
"End-users
   who never received procurement services from either the utility or
DWR
   as of the effective date of the Commission order implementing this
   proposal would be exempt from the DRC related to the bonds and the
UDRC
   related to the utility's past procurement-related debt."  [From
Option
   A; there is a parallel provision in Option B.]  The bullet
(currently)
   reads as if there is a special pass to be handed out to those (large
   customers) able to make quick DA contracting decisions.  That's not
OK.
   I assume that the author's intent is clearly covered in the two
bullets
   that follow the offensive bullet (both in Option A and B).
Therefore,
   rather than convoluting (to correct) the offensive paragraph(s),
let's
   just drop it (them).

?  Given the e-mail exchange with Bill Booth, I believe that CLECA would
   join TURN to OPPOSE an AReM proposal (perhaps even the motion), and
in
   particular, the Option B element: "Utility customers who choose
Direct
   Access would be required to pay:?[a] long-term dedicated rate
component
   ("LTDRC") to cover the customer's proportionate share of any
   above-market costs associated with DWR's long-term contracts?."
While I
   do not propose that AReM adapt its positioning to accommodate CLECA,
I
   observe that AReM would be leading with its chin.

Dan, you've done a killer job in close to zero real-time.  Wow.  Kudos.

Peter

 

                                               To:  <[email-masked]>,
<[email-masked]>                
                                               cc:
<[email-masked]>, <[email-masked]>,      
 
<[email-masked]>                                     
                                               Subject:    Re: Emergency
AReM Pleading                            
                    "Dan Douglass"

               <[email-masked]>

                08/09/01     11:57 AM

          ----------------------------------+

Just in advance of the conference scheduled for a few minutes from now,
attached for your review and comment are the following two documents:

1.  A motion for permission to file supplemental comments on the draft
decision of ALJ Barnett and the alternate draft decision of Commissioner
Bilas; and
2.  The supplemental comments, in which the proposal circulated
yesterday
is
included.

Please note there have been some changes to the bullet point proposal.
Some
is merely wording to make it read more smoothly.  However, Option A also
includes Peter Bray's suggestion that the participation limit include a
20%
DA capacity reservation for residential and small commercial customers,
with
preference for those using green power.  Also, this has been dated for
filing on Monday, rather than Friday, because Rick Counihan and I could
not
see how parties could provide comments and have us agree on a final
version
by Friday.

All comments will be greatly appreciated, as soon as possible.

Dan

Law Offices of Daniel W. Douglass
5959 Topanga Canyon Blvd.  Suite 244
Woodland Hills, CA 91367
Tel:   (818) 596-2201
Fax:  (818) 346-6502
[email-masked]

(See attached file: 8-13-01 AReM Supp Comments - Draft 1.doc)(See
attached
file: Motion to File Supplemental Comments.doc)