DA suspension date

Sue and others - assuming we will have this 30 day comment period on direct
access suspension coming out of Thursday's order, here's a direction we could
head with the comments:

CDWR has until 1/1/03 to fill the utility short position. They will be doing
the fill over that time, maybe up-front, maybe not. DA should be allowed to
proceed without inconvenience to CDWR so long as :

the net short to be filled minus the portion of the short already filled is
greater than the direct access load.

In other words, say net short to be filled is 40% on a utility, at a given
point in time the portion already filled is 30%, DA should proceed as long as
it doesn't exceed 10% at that time. The balance could be calculated weekly,
if necessary, up to say September 1, 2002, at which time DA would definitely
be closed. If the amount available for DA is close to CDWR's remaining short
to be filled, CDWR gives two weeks notice and DA is then suspended per
Commission order before September 1, 2002.

This approach makes the calculation utility specific, does not impede CDWR's
efforts, gives the legislature maximum time to give a different DA fix, and
gives the CPUC a graceful way out. If the CPUC wanted to slam the door
immediately, seems to me they would have done that in the draft order.

Let's collect comments on this and then see what AReM and others are up to.