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\pard \qc\sl0 
{\plain }{\plain \b BEFORE THE PUBLIC UTILITIES COMMISSION\par
}{\plain \b OF THE STATE OF CALIFORNIA}{\plain \par
}\pard \qj\sl0 
{\plain \par
}{\plain \par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Application of Pacific Gas and Electric Company\tab )\par
}\pard \qj\fi-6480\li6480\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480 
{\plain to Identify Cost Savings for Revenue Cycle \tab \tab )\tab \tab A.97-11-004\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Services Provided by Other Entities And to  \tab \tab )\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Propose Credits For End-Use Customers In Such\tab )\par
}\pard \qj\sl0 
{\plain Circumstances For Implementation No Later\tab )\par
}{\plain Than January 1, 1999 \tab \tab \tab \tab )\par
}{\plain __________________________________________)\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Application of Southern California Edison \tab \tab )\par
}\pard \qj\fi-6480\li6480\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480 
{\plain Company to Identify Cost Savings for Revenue \tab )\tab \tab A.97-11-011\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Cycle Services Provided by Other Entities And to  \tab )\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Propose Credits For End-Use Customers In Such\tab )\par
}\pard \qj\fi-4320\li4320\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320 
{\plain Circumstances For Implementation on \tab \tab )\par
}\pard \qj\fi-4320\li4320\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320 
{\plain January 1, 1999 \tab \tab \tab \tab \tab )\par
}\pard \qj\sl0 
{\plain __________________________________________)\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Application of San Diego Gas & Electric \tab \tab )\par
}\pard \qj\fi-6480\li6480\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480 
{\plain Company to Identify Cost Savings for Revenue \tab )\tab \tab A.97-12-012\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Cycle Services Provided by Other Entities And to  \tab )\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain Propose Credits For End-Use Customers In Such\tab )\par
}\pard \qj\fi-4320\li4320\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320 
{\plain Circumstances For Implementation on \tab \tab )\par
}\pard \qj\fi-5040\li5040\sl0\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain January 1, 1999 \tab \tab \tab \tab \tab )\par
}\pard \qj\sl0 
{\plain __________________________________________)\par
}{\plain \par
}{\plain \par
}\pard \qc\sl0 
{\plain }{\plain \b COMMENTS OF \par
}{\plain \b  THE UNIVERSITY OF CALIFORNIA \par
}{\plain \b THE CALIFORNIA STATE UNIVERSITY AND\par
}{\plain \b THE CALIFORNIA DEPARTMENT OF GENERAL SERVICES\par
}{\plain \b ON THE PROPOSED ALTERNATE ORDER OF \par
}{\plain \b COMMISSIONER KNIGHT REGARDING PHASE 1 ISSUES}{\plain \par
}\pard \qj\sl0 
{\plain \par
}\sect \sectd \sbknone\titlepg 
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\pard \qj\sl480 
{\plain \tab Pursuant to Rule 77 of the California Public Utilities Commission (\'93CPUC\'94 or \'93Commission\'94) Rules 
of Practice and Procedure, as well as the June 22, 1998, electronic communications from ALJ Malcolm to 
parties in this proceeding, the University of California, the California State University and the California 
Department of General Services (\'93UC/CSU/DGS \'94) respectfully submit their Comments on the Proposed 
Alternate Order of Commissioner Knight Regarding Phase 1 Issues, (\'93Alternate\'94) mailed June 18, 1998.  
UC/CSU/DGS have been active in this proceeding from its inception and filed comments on the original 
proposed decision (\'93PD\'94).  These comments also address some of the May 26, 1998 revisions made to the 
original PD.\par
}\pard \qj\fi-720\li720\sl480\tx720 
{\plain \b I. \tab }{\plain \b\ul Background}{\plain \par
}\pard \qj\sl480 
{\plain \tab The purpose of Phase 1 to this proceeding is to direct the utilities in the required billing system 
revisions contemplated to allow the credits ultimately adopted in Phase 2 to be flowed through to the end-use customers who will no longer secure revenue cycle services (\'93RCS\'94) from the utility distribution 
companies (UDCs).  The need for these credits stems from the fact that, at this time, although RCS services 
are unbundled and subject to competition, the UDCs do not have unbundled RCS rates.  Credits, if properly 
developed, should ensure that the end-use customer no longer pays for those services it no longer takes 
from the UDC.  If and when RCS rates are unbundled from the distribution rate component, the need for 
RCS crediting would end as to the specific services the customer no longer receives from the UDC.  
DGS/UC/CSU believe that unbundled RCS rates are preferable to the crediting mechanism because those 
rates would provide a better price signal to the customer in terms of comparing costs for specific services.\par
}{\plain \tab It is also important to recognize that customers }{\plain \i currently}{\plain  taking direct access commodity and RCS 
services from an electric service provider (\'93ESP\'94) are }{\plain \i currently}{\plain  paying twice for the RCS service: first to 
the ESP who is actually providing that range of services and also to the UDCs--}{\plain \i who are not providing the 
RCS service}{\plain --via the fact that RCS-related revenues are embedded in the distribution rate element.  
Therefore, it is imperative that some correction be made as soon as possible--either through credits or via 
RCS rates--to end this inequitable situation.\par
\pard \qj\fi-720\li720\keep\keepn\tx720 
}{\plain \b II.\tab The Assertion that Customers Do Not Secure Revenue Cycle Services is at Odds with the 
Commission\'92s Pro-Competition Policies.}{\plain \par
}\pard \qj\keep\keepn 
{\plain \par
}\pard \qj\sl480\keep 
{\plain \tab Customers do have options in regards to RCS service provision.  The Alternate fails to recognize 
that a customer could potentially select different entities to provide the commodity, the meter and data 
management, as well as meter services.  Therefore UC/CSU/DGS believe that the assertion that \'93End-use 
customers do not procure revenue cycle service\'94 is inaccurate (Alternate, page 12).  Insofar as this appears 
to be the premise to the proposed inquiry into, \'93whether it is necessary to have the credit appear on 
consumers bill [sic] for the market to function\'94 (Alternate, page 13), UC/CSU/DGS respectfully suggest 
that the ultimate purpose of reflecting information regarding the credit has been lost.  That purpose--undeniably--is to inform the }{\plain \i end-use customer that he is not being double billed for services}{\plain .  As long as 
the end-use customer pays a UDC distribution rate that has embedded RCS elements, the customer must 
directly see the credits.  Otherwise the customer cannot conclude that he is no longer paying the UDC for 
services the UDC no longer performs.  While UC/CSU/DGS firmly believe that the need for credits (and 
the reflection thereof on the customers bill) can end once rates for the individual RCS services are 
unbundled from the UDC distribution rate (a goal which must be realized no later than the end of the 
transition period), until that occurs customers must be able to see the crediting information.\par
}\pard \qj\sl480 
{\plain \tab Additionally, the Alternate\'92s assertion that, \'93[i]t is the ESP\'92s decisions and actions that cause 
revenue cycle services costs to be avoided by the utility\'94 is not entirely accurate.  While it is true that the 
presence of ESPs who may provide RCS allows for the UDCs to avoid those costs, }{\plain \i it is really the 
customer\'92s ultimate service elections that determine the degree of savings.}{\plain   Insofar as an ESP may offer 
the customer the option of dual billing or full or partial consolidated ESP billing, the }{\plain \i customer\'92s}{\plain  election--}{\plain \ul not the ESP\'92s offering}{\plain --will determine the number and size of applicable RCS credits.  Therefore, customers 
will need to see these credits directly, unless, of course, the UDC distribution rate element is further 
unbundled to provide distinct rates for the individual RCS services.  In that case, the presence of stand alone 
rates would remove the need for the credits insofar as the customer\'92s election for certain RCS from the ESP 
means that the UDC would not charge the customer directly.\par
}\pard \qj\fi-720\li720\tx720 
{\plain }{\plain \b III.\tab The Flow-Through of Credits to End-Use Customers Is Consistent with the Commission\'92s 
Pro-Competition Policies}{\plain \par
}\pard \qj 
{\plain \par
}\pard \qj\sl480 
{\plain \tab Under the contemplated use of RCS credits, customers (as well as ESPs) will be provided some 
form of price signal regarding the provision of the various RCS services.  The details and methodology are 
the subject of Phase 2.  Irrespective of the ultimate methodology used to develop the credits, customers will 
look at the cost (and/or credit) associated with the specific service and the nature of the service when 
choosing their service options.  While innovative service offerings may differ from the services currently 
provided under the bundled distribution rate, the customer will have some information regarding relative 
costs and values for those services (assuming the customer understands, under the UDCs\'92 methodology, 
that the credits would not necessarily reflect all costs currently supported by the customer).  This provision 
of information from the marketplace is a central feature of a competitive market and the Commission has 
promoted the dissemination of information and accurate price signals as a means of developing the 
competitive market.  Therefore, UC/CSU/DGS believe that this information is valuable to customers and 
should not be eliminated.\par
}{\plain \tab While it is true that, under certain contractual arrangements, the customer may give to the ESP the 
UDC credits which refund RCS costs embedded in distribution rates, it is not necessarily the case that the 
customer would be indifferent to knowing whether he has received the benefit of those credits.  We believe 
this to be fundamental to the current structure.  Conversely, if the unbundled revenue cycle services  had 
their own rates unbundled from the distribution rate, the customer would be able to know that he has not 
been charged by the UDC for those services the UDC does not provide.  \par
}\pard \qj\fi-720\li720\tx720 
{\plain \b IV.\tab The Proposed Decision Should Minimize the Need to Revisit Billing System Modifications 
At a Later Date.}{\plain \par
}\pard \qj 
{\plain \par
}\pard \qj\sl480 
{\plain \tab As noted in our prior comments, subsequent revisions of utility billing systems may in fact require 
more work and entail more costs.  UC/CSU/DGS believe that the need for subsequent revisions should be 
minimized to the fullest extent practicable.  This means, for the purposes of Phase 1 and assuming there is 
no reversal of the policy that these credits should be in place }{\plain \i no later than}{\plain  January 1, 1999, the full range 
of potential outcomes should be incorporated at this time.  This is necessary--as noted in the Alternate at 
pages 3 and 4 as well as the briefs in this phase--that the utilities receive direction with adequate lead-time 
to develop the required programming.  We are concerned that the Alternate jeopardizes this goal by : 
(a)\~tacking on an additional \'93sub-phase\'94 regarding the credit issues (}{\plain \ul see}{\plain , Alternate page 13; Conclusion of 
Law No. 3); and, (b)\~allowing for later utility applications regarding purchases of existing meters in place 
(}{\plain \ul see}{\plain , Alternate page 7; Conclusion of Law 4; Ordering Paragraph No. 4).  Additionally, the May 26, 1998 
revised PD of ALJ Malcolm is likely to lead to costly programming modifications as it contemplates a 
potential revisiting of the number of bill credit lines in a year.  (}{\plain \ul See}{\plain , ALJ Malcolm Proposed Decision, May 
26, 1998 revision page 11).\par
}\pard \qj\fi-720\li720\sl480\tx720 
{\plain \b V.\tab Conclusion}{\plain \par
}\pard \qj\sl480 
{\plain \tab For the reasons set forth above, UC/CSU/DGS believe that the Alternate seriously undermines the  
purpose of Phase 1 by jeopardizing the UDCs\'92 ability to implement billing system revisions to reflect RCS 
credits no later than January 1, 1999.  While the goal of minimizing the need for billing system changes is 
laudable, we do not believe this is possible }{\plain \i unless rates for individual RCS services are unbundled from 
the UDC distribution rate}{\plain .  Because it is the end-user who pays the UDC distribution rate, and because 
those rates as currently designed include those costs associated with RCS, the end-use customer must be 
able to see the credits to ensure that he is not paying twice for RCS services.  Therefore, UC/CSU/DGS  
oppose the Alternate because it appears in conflict with the dual goals of timely implementation of the 
credits and of providing meaningful price signals directly to end-use customers.\par
}\pard \qj\fi-5040\li5040\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040 
{\plain \tab Dated: June 25, 1998\tab \tab \tab \tab Respectfully submitted, \par
}\pard \qj 
{\plain \par
}{\plain \par
}{\plain \par
}{\plain \tab \tab \tab \tab \tab \tab \tab ____________________________________________\par
}{\plain \par
}{\plain \tab \tab \tab \tab \tab \tab \tab Christopher T. Ellison\par
}{\plain \tab \tab \tab \tab \tab \tab \tab Andrew B. Brown\par
}{\plain \tab \tab \tab \tab \tab \tab \tab ELLISON & SCHNEIDER\par
}{\plain \tab \tab \tab \tab \tab \tab \tab 2015 H Street\par
}{\plain \tab \tab \tab \tab \tab \tab \tab Sacramento, California 95814\par
}\pard \qj\fi-6480\li6480\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480 
{\plain \tab \tab \tab \tab \tab \tab \tab Telephone:\tab 916/447-2166\par
}\pard \qj\fi-6480\li6480\tx720\tx1440\tx2160\tx2880\tx3600\tx4320\tx5040\tx5760\tx6480 
{\plain \tab \tab \tab \tab \tab \tab \tab Facsimile:\tab 916/447-3512\par
}\pard \qj 
{\plain \tab \tab \tab \tab \tab \tab \tab E-mail: abb@eslawfirm.com\par
}{\plain \par
}{\plain \tab \tab \tab \tab \tab \tab \tab Attorneys for the California\par
}\sect \sectd \sbknone\footery1920\titlepg 
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{\plain \tab \tab \tab \tab \tab \tab \tab Department of General Services{\*\bkmkstart BM_1_}{\*\bkmkend BM_1_}\pard \qj 
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