Comments on Judge Wagner's Proposed Recommendation

As you may be aware, the Chief Judge informed the parties to the settlement
proceeding this afternoon that he intends to recommend to the Commission that
it employ the June 19 rate methodology for the refund period from October 2
forward.

Attached are draft comments that Sarah Novosel and I propose to submit to the
Judge and his legal staff tomorrow. While we would like to convince the
Judge that the June 19 methodology is not appropriate, we also provide a
fallback approach.

Please review the comments (they are only 4 pages) and send your comments to
us. We plan to submit the comments tomorrow.

Thanks

Ray and Sarah