MAVI Petition To Modify - Review Prior to Submission



The MAVI Committee has completed its review of the Calif. VEE Rules for
Interval Data and has developed the attached DRAFT Petition to Modify and
VEE Rule Changes.  Specifically, proposes the following changes:
Rule changes to tighten the data estimation process
1.  Narrow the high/low usage check
2.  Require revalidation of estimated data
Optional Data Estimation Procedures
1.  Allow option of going back one calendar year when estimating interval
data.
2.  Provide option of considering customer Special Holidays to estimate
data.
3.  Allow MDMAs to take Special Conditions into account when estimating
data.
4.  Allow the use of prorated intervals for use in estimation

These six changes will take affect within six months of Commission approval.
Please review the attached DRAFT documents and limit comments to the above 6
proposed changes.  Any and all feedback prior to October 6th will be
appreciated.  Please forward all comments Armando Silva (PG&E) at
AXSj@pge.com and myself at the below address.

Brian Musthaler
Essential Solutions Corp.
bmusthaler@essential-energy.com

DA

Calif_VEE_Strike_Through_V2.0.doc