ADDITIONAL ITEM FOR MONDAY'S CONFERENCE CALL

A member of our group asked me to add the following item to the agenda for
Monday's conference call:

5. Would there be any utility in invoking the ISO's arbitration procedures
(naming the ISO as a defendant and interpleading SCE and PG&E) for purposes
of obtaining a ruling that the ISO, SCE and PG&E have violated the ISO's
tariff by defaulting to market participants? Similarly, would there be any
utility in invoking the PX's arbitration procedures seeking a determination
that SCE and PG&E have violated the PX's tariff in their defaults, and
whether we are presently enjoined from pursuing this option against the PX in
light of the automatic stay? In addition to seeking repayment (which
obviously is presently problematic), the purpose we would seek a full
accounting of outstanding amounts owed by and to whom in the arbitration, and
to obtain a finding by the arbitrators that could be helpful in possible
future litigation against SCE and PG&E.