SDG&E	PG&E	SCE
Functional Unbundling of Generation	Generation revenues will be derived in SDG&E's Generation PBR O&M and capital-related costs will be directly assigned to business functions Methods of assigning A&G, general plant and common plant expenses are described	Presents discussion of "Physical" versus "Contractual" generation and the interaction with PX and ISO Describes a "mapping" approach for aggregated costs and allocation of shared costs Result is $5.1 billion (includes CTC, which will be identified in 8/30 filing)	These costs are contained in SCE's July 15 PBR application Describes the mapping process that was used for direct, joint and common costs
Functional Unbundling of Transmission	Transmission revenues will be determined by the FERC and will be subtracted from total revenue requirements Implications of FERC and CPUC scenarios are discussed but no preference is stated	Demarcation between transmission and distribution must be resolved Transmission will include revenue requirements for all facilities 60 kV and greater Result is $272 million	Expects the revenue requirement for transmission will be authorized by FERC based on ISO Phase II filings in early 1997 Proposes a revenue-credit methodology to separate FERC jurisdictional revenue requirements
Functional Unbundling of Distribution	Once the transmission revenue requirement is identified, it will be subtracted from the total T&D amount to obtain the distribution revenue requirement	Estimated using a mapping approach Result is $1.7 billion	Proposes to calculate by subtracting the FERC-adopted transmission revenue requirement from the non-PBR revenue requirement that the CPUC will adopt. More fully described in PBR proposal
Further Unbundling of Distribution Functions	Emphasizes that meaningful competition cannot be achieved so long as services are bundled Unbundling should occur by 1/1/98 Examples of unbundled services are provided Classifying and costing methodology is described in detail	Believes that unbundling the five cost categories satisfy the criterion in the June 21 ACR Further unbundling should use the same principles as the Commission applied to the unbundling of generation: no cost-shifting, rate cap, and stranded cost recovery	Further unbundling first requires determination of whether it provides customer value Believes that the CPUC's deadline of 1/1/98 requires deferring this determination Notes that parties were directed to focus "only on resolving issues that are necessary for implementation by January 1, 1998"

ISSUE	SDG&E	PG&E	SCE
Revenue Allocation	Minimize revenue shifting by continuing use of capped EPMC methodology Use residual approaches for CTC and PGC costs to avoid cost shifting Supports cost-based, uncapped, allocation in the long-term	Provides a step-by-step methodology which minimizes revenue shifting Use FERC's method for Transmission allocation, and EPMC for Distribution Use a residual approach for CTC costs to avoid cost shifting	Plans to use the currently adopted marginal costs to allocate the unbundled revenue requirements to the maximum extent possible consistent with the new market structure
Rate Design	Proposes a single average cost of PX energy for non-RTP customers To minimize bill impacts and to encourage demand side bidding, continue to recover UDC costs via TOU energy charges during a five-year transition period Proposed that all utilities use fixed charges and demand charges to recover distribution costs	Describes how the unbundled components will add to the current rate The rate freeze proposal and CTC residual allocation will keep rates capped and avoid cost-shifting	Believes that the existing rate structures should remain the same as rates are unbundled Therefore, no change in the relative size of charges in any rate schedule Anything else would violate the goal of no cost-shifting
Transmission Rate Design	Presents illustrative rates based on noncoincident demand and energy use (not a 12 CP rate design)	States that the FERC must approve any proposed rate design Transmission charges could consist of both energy and demand charges	Assumes CPUC jurisdiction of rate design for retail customers Proposes allocation and rate design be based on marginal costs
RTP Metering	Proposes universal metering for all customers on a state-wide basis within 5 years, beginning 1/1/98	No discussion

ISSUE	SDG&E	PG&E	SCE
CTC Recovery	Recover CTCs implicit in UDC rate design to avoid bill impacts CTC percentage and amount can be identified on customer bills	Recover CTCs residually to avoid rate impacts	Recover CTCs residually to avoid bill impacts
Public Purpose Programs (PGC, CARE, etc.)	Recover program costs implicit in UDC rate design to avoid bill impacts If required, percentage and amount can be identified on customer bills	Proposes that PPP include: DSM, RD&D, Low-income programs, economic development, and LEVs Estimates program costs at $122 million	Proposes recovery as a percent of all applicable charges on the rate schedule If costs are 1% of total revenue requirements, then 1% would be charged on each rate schedule
Billing Information	Concerned that there may be too many line-items Proposes that Low-Income Surcharge be included in UDC rates	Describes how many line items could be developed and shown, but emphasizes that customers may not need or want all this information Recommends that other means be considered for communication of this information Proposes that the Ratesetting Working Group address this issue	Emphasizes that many of the CPUC's proposed line-items would be very small No details provided on what should be on bills
Rate Closure	Proposes to close many generation-related TOU options to new customers	Not mentioned	Not mentioned