COMMENTS OF ENRON CORP TO UTILITIES' PHASE 1 COMMON FRAMEWORK PROPOSAL (JANUARY 28, 1998)

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COMMENTS OF ENRON CORP TO UTILITIES' PHASE 1 COMMON FRAMEWORK PROPOSAL
(JANUARY 28, 1998) 

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G. Alan Comnes
MRW & Associates, Inc.

Revenue Cycle Services Credits Proceeding Applications 97-11-007,
97-11-011, 97-12-012
Pacific Gas and Electric Company, Southern California Edison Company,
San Diego Gas & Electric Company


COMMENTS OF ENRON CORP TO 
UTILITIES' PHASE 1 COMMON FRAMEWORK PROPOSAL (JANUARY 28, 1998)
JANUARY 30, 1998

Enron Corp appreciates the opportunity review the utilities' common
framework proposals for Phase 1 and  provides the following comments:

Uncollectables:  Until a universal uncollectables pool is considered and,
possibly, created in the direct access proceeding, the cost of
uncollectables should be made a part of the billing and payment credit.
Utilities should develop methods to estimate the credit by rate schedule.
Enron agrees that credit should include both write offs (uncollectables) as
well as collections and credit costs.

II.A.1 and II.B.1and III.C.1  Enron supports the segmentation of  meter
reading (A.1) ,  services (B.1), and ownership (C.1) credit by rate
schedule rather than meter type. 

II.A.4 Enron does not support on-site/telephone meter reading segmentation
unless current retail rates are currently differentiated by this segment.

II.A.2 Meter Reading Commodity Categories.

Enron recommends the following meter reading  commodity categories for PG&E
and SDG&E:
ESP  reads  gas and electric meter for  combination customers*
ESP  reads  electric meter for electric only  customers
ESP reads  electric meter for  combination customers
ESP reads  gas meter for combination customers*
ESP  reads  gas meter  for  gas only customers *
*Not currently authorized but, in light of recently released CPUC Natural
Gas Strategy,  categories should be created now in Phase 1 for possible
implementation later.

II.D  Billing and Payments

Enron supports the segmentation of bill credits by rate schedule rather
than bill type.

Enron recommends that commodity categories for PG&E and SDG&E:
ESP  provides gas and electric billing to combination customers*
ESP  provides electric billing to electric only  customers
ESP provides electric billing services to combination customers
ESP provides gas billing services to combination customers*
ESP  provides gas billing to gas only customers*
*Not currently authorized but, in light of recently released CPUC Natural
Gas Strategy,  categories should be created now in Phase 1 for possible
implementation later.

Bill credit should include cost of collections, credit, and uncollectables
per comment above.

Enron