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


                                              COMMENTS OF
                    
                            INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS


                  Pursuant to  the Assigned  Commissioner's Ruling in  the above-captioned

            proceedings,  dated  July 8,  1994,  International  Brotherhood of  Electrical

            Workers (IBEW) hereby  submits its  written comments to  the Public  Utilities

            Commission,  State of California (Commission)  on some of  the issues involved

            with Competitive Wholesale Electric Markets:  Role, Structure, and Efficacy.


                  The IBEW  finds it interesting and  reasonable that, as a  result of the

            first  and second hearings and  comments, the Commission  is reconsidering the

            viability  of  the  initial  retail wheeling/direct  access  emphasis  of  its  


            Rulemaking  and   Investigation  Orders.    We  believe   an  expanded,  fully

            competitive  regional wholesale  market  may satisfy  the  Commission goal  of

            ensuring    that   California's    consumers   receive    reasonably   priced,

            environmentally  sound, and reliable electric  service.  However,  even if the

            entirety of  the Commission's  stated goals  are not  completely met  within a

            given  period of  time  with  a  fully  developed  wholesale  wheeling  market

            structure with attendant pricing mechanisms firmly established, the Commission

            could, at  that time, reevaluate the  effects of these structural  changes and

            determine what, if any, modifications would be appropriate.  The IBEW restates

            that  the institution  of retail  wheeling  at any  time  would ultimately  be

            counter-productive  to the Commission's goal of efficiency gains and lower Kwh

            costs to the consumer.


                  The  very nature of  retail wheeling, as has  been addressed by numerous

            comments  and  examples filed  thus far,  introduces  high risk  of electrical

            system  unreliability,  insufficiency,  and  failure --  such  aspects  surely

            counterproductive  in attracting  new  industry to  the  state.   The cost  of

            electrical  power  is decidedly  not the  only  issue considered  by companies

            contemplating relocation:  siting and environmental costs; available qualified

            work  force; product  distribution  costs; earthquake  and  fire hazards;  and

            taxes; etc., are  all obvious and well-reported factors which are given weight

            in the migration of industry and erosion of employment in California.


                  While the IBEW  is not submitting a blueprint for  the construction of a

            new  wholesale structure, we  do submit the  following issues  which should be


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            taken into consideration as the new foundations and framework of the  electric

            utility industry are re-created and re-drawn for the future.


                  The   Western  Systems  Power  Pool  is  the  most  likely  vehicle  for

            encompassing the scope of the expansion of wholesale wheeling for the state of

            California.   The proven ability  of the  pool to meet  its members  needs for

            system reliability  and backup, beneficial wholesale  energy transactions, and

            various  short-term trades for  energy and transmission  services, lends much-

            needed  practical experience and substance  to some of  the highly conjectural

            scenarios being submitted to the Commission at present.  The  pool can provide

            the  framework for expansion of the critical communications network needed and

            also form the structural basis for developing procedures for inclusion of  the

            presently non-member power generators.


                  Within this new structure, maintenance of the present utility franchised

            service  areas  will still  be  desirable  for  several  reasons.   First  and

            foremost, any  reduction in cost in  the wholesale power market  can easily be

            passed  on to  all consumers  served  by the  distributing utility,  as it  is

            presently done.  Utilities  would also continue to provide  ancillary services

            such  as  frequency regulation,  reactive  power,  and power  supply  back-up.

            Allowing local  utilities to  continue to function  as their own  power broker

            within the wholesale market  will provide that necessary function  with little

            or no increase in present cost.


                  In closing, the IBEW would  again advise, "Festina lente" -- make  haste

            slowly.   The avalanche of  comments generated by  the Commission's order  has


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            revealed numerous  transparent commenters  seeking short- or  long-term profit

            opportunities with no consideration of  the consequences to average consumers,

            the  contributions of the industry and its employees, or utility stockholders.

            There is no industry  development attributable to that type  of opportunism --

            no promise of betterment for any but themselves.


                                          Respectfully,


                                          J. J. Barry
                                          International President

            Dated:  July 27, 1994


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