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Enron Mail |
Peter,
The concern about customers who were never on utility service is not just a large customer issue. I have thousands of customers that did not contribute to the DWR undercollection and should not have to repay it. On the other hand, a large customer who went DA today, should have to repay it because they enjoyed the benefits of DWR procurement for half a year. Rick -----Original Message----- From: Peter.Bray@NewPower.com [mailto:Peter.Bray@NewPower.com] Sent: Thursday, August 09, 2001 2:41 PM To: arem@electric.com; douglass@earthlink.net Cc: jeff.dasovich@enron.com; johnlatimer@capitoladvocacy.com; nplotkin@rcsis.com Subject: Comments: Emergency AReM Pleading ? The "special preference for green customers" should be less vague, or dropped. This includes the reference in the 2nd paragraph in the "Conclusions" section. Rick, do you have something in mind? ? On its face, this bullet looks like it's reaching (too far): "End-users who never received procurement services from either the utility or DWR as of the effective date of the Commission order implementing this proposal would be exempt from the DRC related to the bonds and the UDRC related to the utility's past procurement-related debt." [From Option A; there is a parallel provision in Option B.] The bullet (currently) reads as if there is a special pass to be handed out to those (large customers) able to make quick DA contracting decisions. That's not OK. I assume that the author's intent is clearly covered in the two bullets that follow the offensive bullet (both in Option A and B). Therefore, rather than convoluting (to correct) the offensive paragraph(s), let's just drop it (them). ? Given the e-mail exchange with Bill Booth, I believe that CLECA would join TURN to OPPOSE an AReM proposal (perhaps even the motion), and in particular, the Option B element: "Utility customers who choose Direct Access would be required to pay:?[a] long-term dedicated rate component ("LTDRC") to cover the customer's proportionate share of any above-market costs associated with DWR's long-term contracts?." While I do not propose that AReM adapt its positioning to accommodate CLECA, I observe that AReM would be leading with its chin. Dan, you've done a killer job in close to zero real-time. Wow. Kudos. Peter To: <arem@electric.com<, <Peter.Bray@NewPower.com< cc: <nplotkin@rcsis.com<, <johnlatimer@capitoladvocacy.com<, <jeff.dasovich@enron.com< Subject: Re: Emergency AReM Pleading "Dan Douglass" <douglass@earthlink.net< 08/09/01 11:57 AM ----------------------------------+ Just in advance of the conference scheduled for a few minutes from now, attached for your review and comment are the following two documents: 1. A motion for permission to file supplemental comments on the draft decision of ALJ Barnett and the alternate draft decision of Commissioner Bilas; and 2. The supplemental comments, in which the proposal circulated yesterday is included. Please note there have been some changes to the bullet point proposal. Some is merely wording to make it read more smoothly. However, Option A also includes Peter Bray's suggestion that the participation limit include a 20% DA capacity reservation for residential and small commercial customers, with preference for those using green power. Also, this has been dated for filing on Monday, rather than Friday, because Rick Counihan and I could not see how parties could provide comments and have us agree on a final version by Friday. All comments will be greatly appreciated, as soon as possible. Dan Law Offices of Daniel W. Douglass 5959 Topanga Canyon Blvd. Suite 244 Woodland Hills, CA 91367 Tel: (818) 596-2201 Fax: (818) 346-6502 douglass@earthlink.net (See attached file: 8-13-01 AReM Supp Comments - Draft 1.doc)(See attached file: Motion to File Supplemental Comments.doc)
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