With their arguments for an order instituting a rulemaking to establish rules governing relationships between California’s natural gas local distribution companies and electric utilities and their affiliated, unregulated marketing entities, Petitioners propose specific rules. By ruling, Petitioners were directed to also provide a summary of the orders or decisions the proposed rulemaking would change, and a deadline for filing responses was set. [ Responses were filed by the California Energy Commission (CEC); California Department of General Services, University of California, and California State University (DGS/UC/CSU); Coastal Gas Marketing Company (Coastal); Indicated Producers; National Association of Energy Service Companies (NAESCO); Office of Ratepayer Advocates; Pacific Gas and Electric Company (PG&E); San Diego Gas & Electric Company (SDG&E); Southern California Edison Company (Edison); Southern California Gas Company (SCG); Southern California Utility Power Pool (SCUPP); and Vantus Energy Corporation and Vantus Power Services (Vantus).] Most respondents do not specifically address the proposed rules, but they do address the broader issues of whether a rulemaking is appropriate, how new rules would interact with existing rules, and what the Petitioners call "minimum, generic standards." These generic standards are: nondiscrimination standards, disclosure and information standards, separation standards, and complaint and penalty procedures.
We will take up these broader issues and then the generic standards. We will then address the Petitioners’ request that utilities be required to have their nonregulated activities conducted by their affiliate companies and we will consider how to best coordinate utility-affiliate rules under consideration in a number of dockets with the proposed rulemaking.