Ursala:

The CPUC set up many road blocks to forward contracting. The history is complicated. The following note came from a chronology published by CA legislature Republicans.

I think the bullets could say:

? Load serving utilities were given extremely limited authority to enter into PX administered block forward contracts before spring of 2000.
?
? With the run up in spot prices, all three utilities request and receivedthe ability to enter into forward contracts during Summer 2000. However, preapproval or clear review guidelines were not forthcoming by the CPUC. Utilities, faced with second guessing and claims that forward prices were "too high," did not enter into contracts.
?
? By Fall 2000, the utilities still had not forward contracted in any substantial way. Despite numerous requests made to the CPUC, it had taken no meaningful actions to improve the certainty of recovery of prudent foward contracts entered into by utilities. To this day, contracting guidelines do not exist.

Excerpt/Source:
October 16, 2000 PG&E files documents with the FERC showing huge cash
flow shortfalls. PG&E writes Loretta Lynch that after 9 weeks, the CPUC
staff has not produced guidelines for long-term contracts and still has not
done so today. SCE later concurred that they were hitting roadblocks with
the CPUC staff while trying to get approval of long-term contracts. Edison
asks a total of seven times in 20 months for broader authority to make the
kind of electricity buys the governor now says will deliver us from the
crisis. Each time, the CPUC either denies Edison's request or approves it
only after applying significant restrictions that ultimately make it
impractical for the utility.