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                        BEFORE THE PUBLIC UTILITIES COMMISSION
                              OF THE STATE OF CALIFORNIA


          __________________________________   
                                               )
          Order Instituting Rulemaking on the  )
          Commission's Proposed Policies       )
          Governing Restructuring California's )
          Electric Services Industry and       )
          Reforming Regulation                 )            R.94-04-031
                                               )
          ___________________________________  )
                                               )
          Order Instituting Investigation on   )
          the Commission's Proposed Policies   )
          Governing Restructuring California's )
          Electric Services Industry and       )            I.94-04-032
          Reforming Regulation                 )
                                               )
          ___________________________________  )


                                   EEI COMMENTS TO

                      THE CALIFORNIA PUBLIC UTILITIES COMMISSION

                          ON COMPETITIVE WHOLESALE MARKETS:

                             ROLE, STRUCTURE AND EFFICACY


          The  Edison Electric Institute (EEI)  is pleased to present these

          comments  on  competitive  wholesale  markets  in  light  of  the

          Commission's  April 20 Blue Book  proposal.  EEI  is the national

          association  of  the  investor-owned  electric utilities  in  the

          United  States.  Its members generate approximately 79 percent of

          all  the electricity  in the  country and  provide service  to 76

          percent  of all ultimate electric  customers in the  nation.  All

          the electric utilities that are  regulated by this Commission are

          members of EEI. 


          The issues raised in the  Commission's proposal and addressed  by 