COMPARISON OF JULY 15, 1996 RATE & PRODUCT UNBUNDLING REPORTS

         ISSUE                          SDG&E                                PG&E                                 SCE                 
---------------------     --------------------------------    --------------------------------     -------------------------------
Total Revenue             · 1998 base rate revenues           · Based on that authorized in 1996   · Nongeneration base rate          
Requirement               determined from escalated 1996      GRC · Will be adjusted based on      revenues and Hydro PBR revenues    
                          authorized PBR base rate revenues   1997 Base Revenue Filing ·           escalated from 1995 GRC adopted    
                          · Combined with most recently       Describes how rate freeze proposal   levels · Base rate PBR             
                          adopted ECAC revenue requirement    and Rate Settlement are consistent   exclusions to be held at 1995      
                                                              with PG&E's unbundling proposal ·    GRC adopted levels · Recovery of   
                                                              Proposes to maintain                 costs which are fixed with         
                                                              schedule-specific rate levels as     respect to divestiture of fossil   
                                                              of 1/1/96, effective 1/1/97          units, A&G and general plant not   
                                                              through 2001                         included in the ICIP price         
                                                                                                   through the Nongeneration PBR ·    
                                                                                                   Reduced scope ECAC remains for     
                                                                                                   minor, limited fuel costs          

Transition of Current     · Describes need to eliminate       · Endorses streamlined regulatory    · Describes schedule for           
Cost Recovery             1999 GRC due to CPUC's rate cap,    process, but points out that some    unbundling and restructuring       
Proceedings               the success of SDG&E's PBR, and     rate cases may continue to be        proceedings                        
                          limited resources of CPUC staff,    needed · GRC shouldn't be                                               
                          utility and intervenors             eliminated before PBR mechanism is                                      
                                                              approved · Revenue allocation and                                       
                                                              rate design phases of GRC should                                        
                                                              be retained                                                             

CTC Revenue Requirements  · Will be developed in SDG&E's      · Details will be provided in        · Proposes a residual              
                          8/30/96 CTC filing                  8/30/96 filing                       calculation of CTC revenues to     
                                                                                                   obviate need for a separate        
                                                                                                   allocation and rate design         

Functional Unbundling     · Generation revenues will be       · Presents discussion of             · These costs are contained in     
of Generation             derived in SDG&E's Generation PBR   "Physical" versus "Contractual"      SCE's July 15 PBR application ·    
                          · O&M and capital-related costs     generation and the interaction       Describes the mapping process      
                          will be directly assigned to        with PX and ISO · Describes a        that was used for direct, joint    
                          business functions · Methods of     "mapping" approach for aggregated    and common costs                   
                          assigning A&G, general plant and    costs and allocation of shared                                          
                          common plant expenses are           costs · Result is $5.1 billion                                          
                          described                           (includes CTC, which will be                                            
                                                              identified in 8/30 filing)                                              

Functional Unbundling     · Transmission revenues will be     · Demarcation between transmission   · Expects the revenue              
of Transmission           determined by the FERC and will     and distribution must be resolved    requirement for transmission       
                          be subtracted from total revenue    · Transmission will include          will be authorized by FERC based   
                          requirements · Implications of      revenue requirements for all         on ISO Phase II filings in early   
                          FERC and CPUC scenarios are         facilities 60 kV and greater ·       1997 · Proposes a revenue-credit   
                          discussed but no preference is      Result is $272 million               methodology to separate FERC       
                          stated                                                                   jurisdictional revenue             
                                                                                                   requirements                       

Functional Unbundling     · Once the transmission revenue     · Estimated using a mapping          · Proposes to calculate by         
of Distribution           requirement is identified, it       approach · Result is $1.7 billion    subtracting the FERC-adopted       
                          will be subtracted from the total                                        transmission revenue requirement   
                          T&D amount to obtain the                                                 from the non-PBR revenue           
                          distribution revenue requirement                                         requirement that the CPUC will     
                                                                                                   adopt. · More fully described in   
                                                                                                   PBR proposal                       

Further Unbundling of     · Emphasizes that meaningful        · Believes that unbundling the       · Further unbundling first         
Distribution Functions    competition cannot be achieved so   five cost categories satisfy the     requires determination of          
                          long as services are bundled ·      criterion in the June 21 ACR ·       whether it provides customer       
                          Unbundling should occur by 1/1/98   Further unbundling should use the    value · Believes that the CPUC's   
                          · Examples of unbundled services    same principles as the Commission    deadline of 1/1/98 requires        
                          are provided · Classifying and      applied to the unbundling of         deferring this determination ·     
                          costing methodology is described    generation: no cost-shifting, rate   Notes that parties were directed   
                          in detail                           cap, and stranded cost recovery      to focus "only on resolving        
                                                                                                   issues that are necessary for      
                                                                                                   implementation by January 1,       
                                                                                                   1998"                              

Revenue Allocation        · Minimize revenue shifting by      · Provides a step-by-step            · Plans to use the currently       
                          continuing use of capped EPMC       methodology which minimizes          adopted marginal costs to          
                          methodology · Use residual          revenue shifting · Use FERC's        allocate the unbundled revenue     
                          approaches for CTC and PGC costs    method for Transmission              requirements to the maximum        
                          to avoid cost shifting · Supports   allocation, and EPMC for             extent possible consistent with    
                          cost-based, uncapped, allocation    Distribution · Use a residual        the new market structure           
                          in the long-term                    approach for CTC costs to avoid                                         
                                                              cost shifting                                                           

Rate Design               · Proposes a single average cost    · Describes how the unbundled        · Believes that the existing       
                          of PX energy for non-RTP            components will add to the current   rate structures should remain      
                          customers · To minimize bill        rate · The rate freeze proposal      the same as rates are unbundled    
                          impacts and to encourage demand     and CTC residual allocation will     · Therefore, no change in the      
                          side bidding, continue to recover   keep rates capped and avoid          relative size of charges in any    
                          UDC costs via TOU energy charges    cost-shifting                        rate schedule · Anything else      
                          during a five-year transition                                            would violate the goal of no       
                          period · Proposed that all                                               cost-shifting                      
                          utilities use fixed charges and                                                                             
                          demand charges to recover                                                                                   
                          distribution costs                                                                                          

Transmission Rate Design  · Presents illustrative rates       · States that the FERC must          · Assumes CPUC jurisdiction of     
                          based on noncoincident demand and   approve any proposed rate design ·   rate design for retail customers   
                          energy use (not a 12 CP rate        Transmission charges could consist   · Proposes allocation and rate     
                          design)                             of both energy and demand charges    design be based on marginal costs  

RTP Metering              · Proposes universal metering for   · No discussion                                                         
                          all customers on a state-wide                                                                               
                          basis within 5 years, beginning                                                                             
                          1/1/98                                                                                                      

CTC Recovery              · Recover CTCs implicit in UDC      · Recover CTCs residually to avoid   · Recover CTCs residually to       
                          rate design to avoid bill impacts   rate impacts                         avoid bill impacts                 
                          · CTC percentage and amount can                                                                             
                          be identified on customer bills                                                                             

Public Purpose Programs   · Recover program costs implicit    · Proposes that PPP include: DSM,    · Proposes recovery as a percent   
(PGC, CARE, etc.)         in UDC rate design to avoid bill    RD&D, Low-income programs,           of all applicable charges on the   
                          impacts · If required, percentage   economic development, and LEVs ·     rate schedule · If costs are 1%    
                          and amount can be identified on     Estimates program costs at $122      of total revenue requirements,     
                          customer bills                      million                              then 1% would be charged on each   
                                                                                                   rate schedule                      

Billing Information       · Concerned that there may be too   · Describes how many line items      · Emphasizes that many of the      
                          many line-items · Proposes that     could be developed and shown, but    CPUC's proposed line-items would   
                          Low-Income Surcharge be included    emphasizes that customers may not    be very small · No details         
                          in UDC rates                        need or want all this information    provided on what should be on      
                                                              · Recommends that other means be     bills                              
                                                              considered for communication of                                         
                                                              this information · Proposes that                                        
                                                              the Ratesetting Working Group                                           
                                                              address this issue                                                      

Rate Closure              · Proposes to close many            · Not mentioned                      · Not mentioned                    
                          generation-related TOU options to                                                                           
                          new customers