Comments on 1/29/98 "Revenue Cycle Phase 1 Issues"

ORA appreciates the opportunity to review the utilities' status report on a
common framework for credits for revenue cycle services.  This status report
appears to reflect much of the input offered by the interested parties in
this proceeding, and therefore few comments are needed at this time.  The
following comments are offered in the hope of further narrowing the range of
issues.

First, the framework of analysis and credits for combined gas/ electric
utilities should include options where an ESP performs both gas and electric
meter reading and billing, even though this proceeding is not currently
expected to implement credits on customers' gas bills.  Even in this
context, allowing credits reflecting combined gas and electric meter reading
and billing will be appropriate because even before revenue cycle unbundling
is undertaken in the gas industry, an ESP who provides electric revenue
cycle services could serve as a contractor to the utility for gas meter
reading and billing.

Second, the description of uncollectibles is unclear whether the cost of
write-offs is still being included in electric revenue cycle unbundling
credits to be proposed in this proceeding.  The cost of write-offs should be
included in the framework in this proceeding because the January 26 ACR only
puts the issue of a universal uncollectibles pool into the direct access
proceeding -- not the issue of the cost of uncollectibles.

Third, the credits for billing should address whether different amounts are
appropriate for partial vs. full consolidated ESP billing.  The activities
involved in these two options may differ because, for example, under full
consolidated ESP billing the UDC does not need to inform the ESP of the
amount due for distribution, CTC, and other UDC charges.

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