Rule 22 Tariff Review Group - Comments on Proposed Edison Changes

The following comments are submitted on behalf of AEP Energy Services,
Inc., NorAm Energy Management and the members of the Western Power
Trading Forum, a trade association  established to promote the
development of competition and efficiency in the electricity
marketplace.  Among its members, the Western Power Trading Forum
includes the following parties:

   Arizona Public Service Co.
   California Power Exchange Corporation
   Coral Energy
   Edison Source
   Electric Clearinghouse, Inc.
   Sempra Energy Solutions
   Enron Corp.
   The Montana Power Trading & Marketing Company
   New Energy Ventures, LLC
   PG&E Energy Services Corporation

        Southern California Edison has proposed a number of suggested
revisions to its Rule 22 direct access tariff.  Without addressing the
specific merits of each change, it is fair to say that most of the
changes are stylistic in nature and provide only minor clarifications to
its existing tariff.  The parties named above object to these additions,
to the extent that such changes would apply to Edison only, because they
encourage greater diversity among the tariffs of Edison, PG&E and SDG&E,
as opposed to greater conformity.  This is contrary to the Commission's
goal of achieving a uniform statewide tariff for electricity
competition.
        The Commission made it expressly clear in D.97-10-087 that, "we
have attempted to move toward the use of a uniform direct access tariff
for statewide use. Current system constraints prevent the use of such a
statewide tariff at this time. However, in the near future, a uniform
tariff is a distinct possibility. Such a tariff will eliminate
inconsistent and differing rules among the utilities."  Edison's
proposed modifications, no matter how well motivated by a desire for
greater clarity and precision, contradicts the Commission's basic goal
to achieve a uniform statewide tariff.  By proposing these changes,
Edison would require PG&E and SDG&E to make similar changes, or risk
violating the express intent of the Commission to achieve a uniform
statewide tariff.
        In its decision, the Commission gave an express charter to the
Rule 22 working group to, "see how the adopted direct access tariff
provisions are working, and to make recommendations as to how the
tariffs should be changed. This working group process will provide us
with an opportunity to fine-tune the direct access tariffs, and to
eventually have all the UDCs in this state using a uniform direct access
tariff."  It can be suggested that Edison's efforts are directed toward
achieving this sort of "fine-tuning."  However, we would recommend that
the group should focus first on the major issues affecting direct access
implementation and the role of the utilities' tariffs in facilitating
that process.  The sort of "fine-tuning" proposed by Edison should be a
second or third tier effort which takes place only after major and
intermediate issues have been fully debated and resolved.
        The Rule 22 Group should not be spending its time debating fine
stylistic wording changes at this point, when far more major issues are
still pending.  Such an effort diverts the Group from focusing on more
important issues.  We recommend that Edison temporarily withdraw its
proposed changes and consider renewing its suggestions some months from
now, after the group has acted on the more pressing issues affecting the
implementation of competition in the electricity marketplace.


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