ATTACHMENT 2
                                
                 SUMMARY OF ISSUES FOR COMMENTS

               
1.   We ask for comment on whether Section 202(b) of the
Federal Power Act permits this Commission to apply to
FERC to require utilities to participate in a federally
regulated pool.  

2.   We ask for comment as to where the line should be
drawn to determine where transmission ends and
distribution begins.     

3.   We ask for comment on the impact of this proposal
to the regulatory compact.  
4.   We ask for comment on whether Sierra Pacific and
Pacificorp should be  required to participate in the
wholesale pool for purposes of serving their California
loads.

5.    We ask for comment on the appropriate pricing
methodology to determine the wholesale pool market
clearing price and to account for transmission
constraints in the pool price.  

6.   We ask parties in their comments to propose
transmission pricing methodologies which would best
reflect transmission congestion and encourage efficient
transmission investment.         

7.   We seek comments on how to address the issue of
concentrated market power in transmission-sensitive
locations.  

8.   We ask for comment on whether disaggregating the
utility to form separate operating units, including a
local distribution company, (1) makes sense in light of
FERC's open access NOPR, (2) is technically feasible,
and (3) would be an efficient structure to achieve
wholesale competition while clarifying jurisdictional
boundaries and working towards retail competition.  

9.   We ask for comment on (a) whether Section 202(b) of
the Federal Power Act is broad enough to preempt our
order to require utilities to participate in a pool; 
(b)  whether this Commission could apply to FERC under
Section 202(b) to order establishment of the pool, and
if not, why not; and  (c) whether we can apply to FERC
to require the independent system operator to perform
the function of merit order dispatch of competing
generation facilities to provide price revelation.
     
10.  We ask parties to comment on the method to apply
different performance-based ratemaking techniques to
various types of generating plants.   

11.  We ask the utilities to comment upon changes they
may need to make to their pending PBR filings in order
to comply with our proposed policy.  

12.   We solicit comments on the best method to use to
vertically disaggregate all utility generation assets,
except for nuclear and hydroelectric plants  In
particular, we request comments on whether movement of
generation assets to affiliates or subsidiaries within
the utility's corporate structure would provide
sufficient protection against problems associated with
market power.

13.  We ask for comment upon the antitrust implications
of our proposal under the varying ownership structures
proposed.    

14.  We invite comment on the issue whether divestiture
of generation assets is best considered after having
obtained experience with the pool or should be
addressed immediately.

15.  We request comment on the best methodology for an
upfront transition cost estimation.  

16.  We invite comments on how periodic transition cost
administrative proceedings should serve as a true up to
a prior forecast for that period.

17.  We seek comments on how to use performance-based ratemaking to ensure efficient operation of
remaining utility generation assets.  

18.    We seek comments from parties on how to calculate
transition costs related to nuclear plants if there are
no settlement provisions governing the dispatch and
pricing for power from one or more nuclear plant.

19.   We invite comments on how a proper method for an
auction should be designed to yield the highest
reasonable bids.
     
20.   Parties should comment on an appropriate
methodology to observe the market value of the spun off
generation assets such as to observe the market price
of the first 30 or 100 trading days after the
completion of the spinoff. 
     
21.   We seek comments on the proper allocation of the
future benefits associated with declining QF contract
prices. 

22.  We seek comments regarding which specific
regulatory obligations should be allowed in transition
costs.

23.  We ask for comment on whether the proposed cost
collection mechanism, an equal percentage surcharge on
the bill of each customer receiving distribution
services, is appropriate and within our jurisdiction.

24.  We request comments from parties' specific
suggestions for implementation of a methodology to
track and collect transition costs over time,
consistent with our goal that transition costs should
not result in any rate increases to any custoemr class.

25.  We encourage parties' comment on a strategy to
ensure the sustainability of state resource diversity
and energy efficiency efforts.  

26.  Parties are asked to respond to the following
questions related to CEQA:

     a.   Do any of the policies proposed herein
          constitute a "project" subject to CEQA, as
          defined in Public Resources Code {21065 and
          interpreted by the courts?  Comments should
          specify which policy elements, if any, are
          believed to trigger definition as a CEQA
          "project," as well as cite authority for the
          party's analysis and conclusions.

     b.   Do any changes proposed by the party to this
          Proposed Policy either trigger definition as a
          CEQA project OR remove such definition?  Again,
          comments should specify which changes, if any,
          are believed to affect definition as a CEQA
          "project," as well as cite authority for this
          conclusion.    

27.   We ask parties to comment on our outline for
implementation.

                      (End of Attachment 2)