Dear President Fessler:

The Commission's December 20, 1995, policy decision and March 13, 1996, roadmap decision adopted implementation principles and schedule for electric industry restructuring. In the areas of unbundling/ pricing/ rate design and performance based ratemaking (PBR) (sections 4.a and 4.b of the Roadmap decision, respectively), the utilities are ordered to file proposals and applications on July 15, 1996.

The March 13, 1996, Roadmap decision encourages interested parties to form Working Groups in response to the major groups of implementation issues that it placed under the supervision of Assigned Commissioners. The Roadmap decision asks the parties working in this collaborative process to seek recognition as a Working Group. We, the undersigned, ask that you formally recognize our ongoing efforts as a Working Group for the unbundling/ pricing/ rate design and performance based ratemaking tasks described in sections 4.a and 4.b of the Roadmap decision.

We met initially on April 15, 1996, to establish the organization of this Working Group; the resulting proposed Mission Statement and Practices are attached, and minutes are available. All parties to the restructuring proceeding were notified in advance of this meeting. Sixty-three people attended that meeting, representing 34 organizations, including individual customers, coalitions of customers, investor-owned utilities, municipal utilities and other suppliers, government agencies, and other organizations. Additional parties have contacted the meeting's organizer and are included on the group's mailing list in addition to those who attended on April 15. Any interested party may join the Working Group, and all meetings will be open to the public.

Future meetings of the Working Group, and three to six subteams, will focus on specific issues including identification of unbundled services, cost studies, rate design, interpretation of existing tariffs, billing structures, and performance based ratemaking, and on coordination of the Working Group's activities. (Participants in the April 15 meeting agreed that revenue allocation for CTC should be considered by this Working Group, but that CTC revenue requirement and allocation are sufficiently differ to be placed in a different Working Group.)

The landmark dates for the functioning of the working group are those set in the Commission's Roadmap decision: (1) utility proposals on July 15, 1996, on separating their rates into identifiable components, and applications for PBR for utility distribution and limited portions of utility-owned generation services, and (2) a target completion date of June 30, 1997, leading to the January 1, 1998 (or earlier) beginning of the Power Exchange, Independent System Operator, direct access phase-in, etc. Details of work products and related timing will be discussed further at future meetings.

The efforts on these issues will be coordinated with other Working Groups, and with the Commission's advisory staff. Indeed, some members of this Working Group are active participants in the WEPEX, Direct Access, and other Working Groups.

We thank you for inviting this request for recognition, and look forward to any guidance you wish to provide for our ongoing activities. By agreement of the participants at the proposed Working Group's second meeting on May 9, 1996, I am submitting this request on behalf of all the undersigned. If you have any questions or suggestions, please contact me at (415) 703-1797.

Sincerely,

James E. Price
Division of Ratepayer Advocates

On behalf of:

Agland Energy Services, Inc.
Bay Area Rapid Transit District
California City/ County Street Light Assn.
California Energy Commission
California Farm Bureau Federation
California Industrial Users
California Large Energy Consumers Assn.
CellNet Data Systems
Division of Ratepayer Advocates
Economic Sciences Corporation
Pacific Gas and Electric Co.
Safeway, Inc.
San Diego Gas and Electric Co.
Southern California Edison Co.
Southern California Gas Co.
U.S. Dept. of Defense