RE: Comments on PSWG Minutes

From:	Anthony Mazy
	Office of Ratepayer Advocates

First, as seems to be customary, the writer misconstrues ORA's position.
ORA does not believe that costs are of no interest to ratepayers; only
that costs are meaningful only with respect to benefits and that
long-term or life-cycle costs are more important that first, cash, or
short-term costs.  There is no cost-benefit analysis that can justify
decisions to "erect barriers to competition".   

I respectfully suggest that PSWG attendees focus on representing their
own enterprises, however problematic, and leave the position statements
of other parties to their own chosen representatives.

Second, ORA quite agrees that formal recitations of the costs and
benefits of proposals would be informative and desirable when available.
I can think of no party to these proceedings which would fail to provide
such documentation when available as it could only further discussions
in a constructive fashion where so much confusion otherwise prevails.
However, no requirement to make such presentations mandatory would be
practical in the constrained time allowed for the PSWG nor do I believe
any such mandatory requirement was ever considered.

The nature of the remainder of the comments are, I believe, self-evident
and require no further remark.


> -----Original Message-----
> From:	Greg Lizak [SMTP:Greg.Lizak@itron.com]
> Sent:	Monday, June 01, 1998 10:24 AM
> To:	Kirsten Stacey; pswg@dra1.cpuc.ca.gov; pswgweb@dra1.cpuc.ca.gov
> Subject:	Comments on PSWG Minutes
> 
> Kirsten,
> 
> Last week you asked for comments on the minutes of previous PSWG
> meetings.
> I wanted to add one that should be reflected in the minutes.  These
> comments pertain to, I believe the May 12 PSWG Communications sub
> group
> meeting.
> 
> At the meeting there was a discussion regarding that proposals include
> economic impacts, cost and benefits.  This consideration is
> particularly
> important for  contentious proposals such as C12.19.
> 
> At a previous PSWG meeting I thought it was agreed that addressing
> economic/cost implications was to be included in proposals.  The
> meeting
> minutes should reflect this discussion as well as what I thought was
> the
> strong insistence by the ORA (Office of Rate Payer Advocates) that
> economic
> considerations such as cost to customers and market participants is
> not
> appropriate for consideration and should not be included.  Also, the
> minutes should reflect that no specific CPUC decisions in the
> Conclusions
> of Law or Order sections were identified that state the economic
> considerations including cost to customers or the market are not to be
> considered.  As I stated, I have reviewed these sections and am not
> able to
> find any Order or Conclusion of Law that prohibits economic
> considerations.
> Perhaps if someone can reference a particular section, I'd be happy to
> reconsider the issue.
> 
> 
> Thank you,
> 
> Gregory Lizak
> Star Data Services
> 
.