HomeMy WebLinkAboutAgenda Bill 3.B-Attch4 08/16/20044
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ATTACHMENT iD;
CON.TIINGEINT RISKS
RISK ANALYSIS
Attached as Exhibit A is a table setting forth; ABAG POWER'
s best reasonable effort at
estimating'the maximum reasonable. liability (in total for the .Electric Program) for each of
the listed contingent liabilities. The table allocates , total liability, of the program to individual
Members in accordance with the usage; ratio, or CTC Reversal ratio, as appropriate. The
allocation is for illustrative purposes only. ABAG POWER does not have sufficient
information on which to base an estimate of how thetentit imp_o'sing the liability would
allocate the liabilities 0 r how ABAG POWER and the Members ought to. react to such
allocation.
A. UNINVOICED'ENERGY'CHARGES-
Description of 'Risk
ABAG POWER is distributing to .each of its Electric Program- Members a proportionate share
of the Working Capital contributions made b,y,Members in response to Working Capital calls,
by ABAG POWER -an'd residual funds from operating costs, paid b'y'Members during
Electric Program (Balancing Account): Th.ese'funds were held, p,part in reserve for
payment of charges for electrical energy consumed by, Members of the Electrical Program
during a one =week °period' in August 20,01 When ABAG 'POWER was not..purchasing electricity
on behalf of the Electric Program (Ga'p'Period).
As of February 29, :2004 ABAG POWER has not been invoiced for electricity consumed
during the Gap Period Under the Wind Up Agreement, if. ABAG POWER receives such a bill,
each Member Will..be required to pay its proportionate share.
Backaround
Under normal operating conditions, AB °AG POWER purchased on behalf of the Members of
the Electric Pro 9 lam sufficient energy:,to meet their'estimated needs'. Purchases were made
from a variety f °electri,cit
y y generators and energy remarketers, under'various contractual
formats (fixed price, indexed price, indexed price with "floors" and /or' "ceilings," etc.), and
at various prices. In all instances, one,significant:'factor in6,,the,price o(electricity is the hour
in which it is consumed Energy`dui certain "peak" periods was priced considerably
higher than at other periods.
In the s I , r of .00; th y
9 umm�e " ime rneeting requer=ements w hg rch l,ounstable., ABAG POWER was
electric t dselle It , 20 t P our schedulin coos nator and
g
E in writin of its difficulties sand quently, on 9ugust 2, 20Q0
y rs were im osrn on the market lace Cons
ABAG ROWER,notifed P G& g ,, actions bein taken to rectify
the situation. PG &E acknowled'ged that rt had .received ABAG POWER's, notice,, and although
it, believ ,
ed that ABAG POWER was in default of its ESP. g reenient; PG &E would allow ABAG
POWER
until August 7, 2000 to resolve the situation. Prior to this deadline, ABAG POWER
was able to secure scheduling coordination services, and contract for electricity at a
reasonable price, without he additional credit requirements imposed by other energy
providers and, °rernar,eters.
Legal Analysis
From a legal perspective, the matter is a simple collection issue. Since,ABAG- POWER did
•not ,enter into. a contract during the Gap Period, there is no "seller" to invoice ABAG 'POWER
for any energy that was consumed. There are only two sources of electricity flowing into
the California 'grid that could have serviced the Electric Program during the: Gap Period: the
ISO and PG &E.
The energy consumed by the Members could have'been ,s,u ed'throu.gh the ISO
"imbalance energy:" This is a reserve main..tai'ned 6y the ISO when contracted for,energ,y
supples' from PG &E arid 'other electric service providers fall below the amount = necessary to
keep the grid operational. Electricity Program electricity consumption during the Gap
Period co`uid have come from this source,
Alternatively, PG &E supplies such a large amount of electricity over any period. of `time ;that
it could have been supplying part of the power.for'the' Electric- Program during the. Gap
Period:
The risk, of: incurring the liability is wholly dependent on the ability either of 'the ISO
PG &E to prove that electricity consumed'by, Members ,during this period, was supplied by
the party making .the claim.
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ABAG POWER is without sufficient information to evaluate the likelihood of'this •risk.
occurring. ,.
ABAG POWER has `reviewed the "price of imbalance energy for the period in question:
Imbalance energy prices tend to be the highest of all prices paid for electricity. Based on the
price for imbalance energy an,'estimate of�the amount of electricity theit `Electric, Program
;would,,have consumed during the Gape Period, the maximum exposure is estimated' as •One
Million Four'Hundred Twenty Thousand Doll ars.($1,420,,000).
Finally, ABAG .POWER notes that as time goes on the ability of e ther'the, ISO or PG &E. to
collect •the data necessary to generate an invoice• and prove a claim diminishes.
B. UDC CHARGES,
Description of Risk
From information provided by the Program's billing agent (APS) we believe there may be
UDC charges for which neither,ABAG POWER nor its Mertibers have been invoiced by PG &E.
During: -they period. July 2000 to June 2001 the amount. of'UD,C charges billed to members
(and collected by ABAG POWER) is greater than the amount invoiced' from ;PG &E.
ABAG P OWER is also. aware of one ihstance in which UDC charges for,the affected period
were enerated b PG &E in connection with an :electric account fcr a Member S streetlight .,
streetlight system is not metered and is, PG &E billing system. Electricity,consumed by a
system: •These accounts are unique in,
the
Y
s' charged on an .estimated consumption basis In the
case of which ABAG POWER''is aware, the Member had, already paid PG &E for the asserted
UDC charges.
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2.
Wind Up Agreement= Attrnt D - 4 -28'_04 All
I{ I
Credos, owed b'IIPG &EfABAG,PpN/ d ' information fi°orri 'ABAG POWER s review of the DA
V
Y° ER has concluded that the'likely total exposure is
approximate'iy One. Million' Six Hundred Thousand Dollars ($1,600,00o).
LEGAL ANALYSIS II
PG&E applies U,DC_ charg to individual accounts based on the 'amount of electricity
consumed.
As
ome to A AG POWER -a tentionnwe bel eve thatbti�ed b &E. In the case that has
g. Y PG
e Member ha 's been billed twice for the
same UDC charges. Other Members with streetlight accounts may encounter the same
.situation.
C.- ISO ESCROW DEPOSIT AND OX ESCROW DEPOSIT
Description of Risk
The PX Escrow Deposit and ISO Escrow Deposit, heid' by "NCPA on. behalf of ABAG POWER are
be consumed in the purse f und. In the case of'PX Escrow Deposit, all of the funds may
settling the" PXfs bankruptcy claims. "The: ISO Escrow Deposit
is subject to adjustments based on FERC ordered ener..gy price rollbacks (see detailed
P Dpw). The FERC ordered rollbacks can.both increase and
description m Section" D b ) I
decrease the ISO Escrow'
ABAG POWER bought electricity for use by the Electric Program.and° sold excess capacity
p times.. At those ins"
into the market lace at vanous, tances m which ABAG POWER was .
purchasing electricity, the FERC ordered price red uctions`wilI generate a refund and an
increase in the ISO Escrow Deposit . In those instances in.which'ABAG POWER sold energy
into the ma the FERC ordered rollbacks can reduce the amount available from the
ISO Escrow
eposit. Based on ABAG POWEWs review of the total amount,of'power sold
likel reduct o do of exceed the amount for price
n the IS 0', Delude that the
g p Y
y posit.
Under these circumstances, we believe the risk is nominal.
D. DIRECT'ACCESS'CREDITS
Description of 'Risk
ABAG POWER is distributing �to 'each. of its Electric Program Members a proportionate share
of the funds received from PG &E as settlement cf ABAG PQWEWs' claim, against PG &E for
Direct Access Credits incurred durin'g� 2000 under the deregulated energy market in
California." The "Direct Access Credit i's a result of then application ^of a rate formula adopted
by the CPUC. 'The formula includes contemporaneous energy
pr and the Direct Access.
Credit is a by- product of'high electricity prices in 2000,1
The FE,RC has (been engaged in a proceeding to determine whether wholesale prices charged
y generators and marketers during 2000 in Californiavere "just and
by electricit
reasonable." FER'C,has °already found that at certain tiinnes such prices were not. The FERC
{ For a detailed d'escrip'iion of Direci-Access Credits, see Appendix A, "Direct Access`Cfedit."
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Wind U'p Agreement- AttmtD- 4 -28 -04 All
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proceeding is now:trying to determine what "just and reasonable" rate's should have been
during specific times,' The outcome will bean order requiring generators and marketers
who overcharged' to refund money to purchasers.
In principle the CPUC has the, power to recalculate the, Direct Access Credit : based on th'e
FERC ordered reduction in electricity prices. However, FERC has(no jurisdiction over the
CPUC and':cannot compel such a recalculation. The result of such a recalculation would be "a
reduction: in the amount of Di'cect:Access Credit owed , ABAAG POW P_.3 The CPUC can
undertake a regulatory , process referred to as ratemaking in Which the,ultimate result.cou-Id
i pos imposition o over a specified i, Electric, Program Memberaccounts to recoup overpaid
Direct P g
time, period or immediately.
This risk exposure is punctuated by §4 of theStipulation and Release under PG &E and
ABAG POWER are settling the Direct Access Credit claim (Stipulation and Release). §4
states:
"[ABAG POWER] and PG &E expressly agree that this, Stipulation and Release is :a
cornpromise and settlement of all clarrisand matters that are disputed.as between
be parties involving the 1998 RAP'forthe period through and including, June 30,,
2001, •all issues. that were raised or could have been raised, in the CPUC Complaint,
and :all issues that . were,raised,,orcould -have been'rais-ed, in the Claim. .In the event
that the CPUC issues.any.future ruling relating to the direct access. credits at issue in
the Clam, the. CPUC Cornp'laint or the 19.98 RAP, the parties wily use:their best
efforts to preserve the intent'of - this Stipulation and Release,.consistent with
applicable ow;" (emphasis added)'
This' provision was negotiated when PG&E , declined to give ABAG POWER a full indemnity
:against the possi6 "ility that the CPUC will, take an action to impose :a surcharge. to recover
Direct Access Credits paid to ABAG POWER (or •its electricity members). PG &E agreed that
the exposure ;exists but "asserts that it cannot, as ari entity regulatecl'b "the CPUC, agree to
make ABAG, POWER whole in the event of an adverse CPUC action. PG &E asserts that an
y p on would be characterized as ;illegal circumvention (by'PG &E) - of the
CP nABAG POWER acceded to PG &E's argument an §418 the negotiated corn promi.se-
Backe round
On December22, 2003, the U Bankruptcy Court for Northern California, ';San Francisco -
Division confirmed,a Plan of Reorganization for PG &E ('Confirmed Plan): The Direct Access
Credit Was paid to ABAG' POWER and'er fhe Stipulation- and 'Rele. ase: The Stipulation and
Release was approved by the court and. is included in the Confirmed Plan,as a Class 7 Claim.
eorga izat on PG &E: r Simu d lta 'neously, &E was pursuing claims chapleng o plans o
gce tanf the
9 P. y P 9 d the• CPUC.submitted tom etin
actions by the CPUC durin. g deregulation (CPUC Proceedings). .Further, PG &E filed suit'in
Federal District Court for Northern California. against;the CPUC, various aspects
of ~the deregu)ated energy market created under :CPUC regulations and guidance. The'CPUG
- Pricing, occurred on�an hourlybasist
' On&estimate,of the impact of known (in Spring 200 ,,) FERC;ordered reductions. on ABAG POWER's'Diiect
Access Credit resulted'in a,reducti'omof $4 =5 million in Direct Access Creditsowed. ABAG POWER'belieyes the
estimate':to be reasonable_
"The''1998 RAP" is the.ratesetting proceeding described below under'the same name. The "'CPUC Complaint" is
ABAG POWER's initial complaint filed with the CPUC for- payment Direct Access Credit:
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Wiiid Up Agreement -Attn t D- 428-04 All!
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and .PG &E reached; a Master. Settlement Agreement on all pending disputes, including those
before the Bankruptcy Court TheeMaster-Settlement Agreement dismissed the lawsuits and
the CPUC Proceedings with prejudice, and.,committed: both parties to supporting and
implementing what ultimately became the Confirmed' Plan. 'The dismissed CPUC
proceedings do not include the 1998` RAP,or ABAG POWER's CPUC Complaint. The CPUC
action to approve the Confirmed Plan and the Master Settlement Agreement is documented
in the opinion issued for Investigation 02 -04 -026, (Settlement Opinion)'
The Master Settle mentAgreement between' the CPUC and PG&E:' has the following relevant
features:
1. The CPUC a reed to include ,certain cost co
and r 9 g p g y Pone s future re Such c components included components In the CPUC
sum of $2.2 billion g g ry lisped by t uded the
atema i_n roceedm s as the affect PG &E cost com
l
must be sufficient fo a su o t. Rates estab
he CPUC
esi � Hated the re ulato asse
O pp rt all of the. cost components necessary to PG &E's
continued vlability'as an no public utility and, °(b) amortize the' regulatory asset
over a period o- f ten (16), years.
2. Within , the constraints of`the Confirmed Plan and ;the "Master Settlement Agreement,
the tans its .re bl authorit over PG&
g _ ato rY .
3. The curl • retains
and future"C UCs are bound by he M
P , aster Settlement Agreement:
4. The CPUC acknowledges the. continuing jurisdiction of"the _Bankruptcy Court to enforce
the Confirmed Plan.
Legal Analysis
The potential CPUC, regulatory action on the Direct .Access Credit can only triggered by.a
FERC ordered reduction in wholesale electricity energy prices' for 2000. Only PG &E and a
Direct Access Credit recipient: have standing to Initiate an to recalculate the Direct
Access Credit: PG &E and ABAG POWER,are•estopped from so doing 6y §4 of the Stipulation
and Release (see below), A recalculation �of the Direct Access Credit can in theory be
initiated by the;CPUC. The impetus fora CPUC action is'bureaucratic and triggered by FERC
ordered price, reductions..,
The central question i's whether the CPUC can legally do so in the face of,, ABAG POWER's
objections, The issue of recalculating Direct Access Credits based on FERC ordered refunds
was raised by •PG &E m a raternaking action before the CPUC (Application 98 -07 -003, the
11 1998 RAP" filed in 1998.): The Administrative Law)udge (AL]) issued a draft decision on
April 3, 2003 but the CPUC has .not taken any action on it and,; it'is not currently on the
CPUC agenda for consideration 'public hearing or further action,
The 1998 RAP, - D:raft' on states in pertinent'part::,
it 'ou
"In od. FERC order refs u
ds.We are confronted init [
sd y, t Acce
houl ss] credit
reasonable toi i
recompuae th witDth ee ,unknown factors:
whetherTERC will or refunds: when FERC will order refunds (and when the order
become[s]; final), and the 'amount of those refunds As of ;this writing, FERC'h'as the
matter under consideration. Any order of refu_ rids, if substantial is expected to be
appealed It as impossible °to predict the date of Y final order. The period in question,
December 28 00
20;to Januar 18 2001 , is two ears ol sand „counting. It is unfair for
r ce action f re the CPUC Some have adopted as p resented B others have been sub�ec h 1.
be taken without pp ,deregulation matters have had a mixed
reception befo � � p p t to substantial
raft d pmionAdopting aPost Power Exchange Direct Access Credit for Pacific Gas and
revision Th Pd ecision'is,0
Electric Com an'yi(1'§9,8 RAP; Draft Decision).
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%Viid Up , Aarcement -Aitmt D- 4 -28 -04 All
ratepayers who paid 'their utility ,bills two years ago to be subjectao an, unknown .
liability to be. paid at an unknown future date. We need not elaborate on the ;intensive
effort required by PG &E to recomputed individual brills nor the intensive> efforts and
spent resources of end use to verify those recomputed :bills. Because we deny'
PG &E's proposal we do not reach the question of whether approval of the, proposal
would constitute retroactive ratema king.
When we speak of refunds in this context, we..refer not.to money going '.back °to' DA
[direct access] customers
but to a recommendafi'on of their'credit. If'a refund'is
ordered, th:e credit would have been less and,the customer `would -have `be_ en
overpaid by PG &E.thereby causing 'a'repayment to PG &E.
, The same, logistical objections raised by the,AU toy retroactive reductions in Direct Access
Credits still stand and , are amplified by the; passag:eof yet another °year since]ssuance ^of „the
199,8 RAP = Draft. Decision and without further action by FERC. Further,'the legal barriers
to "retroactive ratemaking,” which the draft decision avoids, become a live.`i'ssue.
Independent of the: arguments.; made in the 1998 RAP' - Draft Decision; a strong .legal .
argument can be made that the,CPUC is''estopped by the Settlement Opinion and Master
Y .
, Settlement, reement from reducing the amount: of the Direct;Access Credit paid to ABAG
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The: Settlement Opinion snakes the following policy, finding: "It is ,in the public interest that
PG &E emerge from hankruptcypromptly ..To emerge from bankruptcy 'PG &Eshoul'd; pay its
creditors. All allovi%ed claims should be paid in full: (emphasis added) " On the date of the
Settlement Decision,;.ABAG POWER "s Stlpulation and Release was an "allowed' claim" and
part of the record before the CPUC. -It wilt be difficult for the CPUC to defeat `the, argument'
that it is'estopped from takin g y an
(otherwise permitted) action that effectively rhodlfies` ;the
Stipulation and Release: or reduces the payment required' .'by the Stipulation .and Release. In
addition, the Master Settlement;Agreeriient ;states,: "[PG &E and. the CPUC] agree. not to
contest the. validity and enforceability of [the 'Master Settlement Agreement], the
[Confirmed Plan] or'any order entered bythe [Bank.rupt -y Court] contemplated by or
required to ;supplement [the Master Settlement.Agreement and the Confirmed Plan], "$
, Ancillary-Ana lVSjS
In addition to the`" iogi:c _of a bureaucratic recalculation of the Direct: Access .Credits in
res p onse to the an ticipated FERG-ordered price red'uction's, there might be pressure on the
CRUC:to recover Direct Access Credits to reduce.general utility rates. In response, one -can
raise the objection ; stated in the 1998 RAP- - Draft Decision that the costs to recalculate ,and'
recover "ove.rpaid" credits may Well ekceed the.recouery. Finally, please note that the post -
bankruptcy CPUC ratemaking structure for PG &E includes the "regulatory asset." Under the
terms of the: Confirmed .Plan and'tbe ;,Master`Settlement Agreement, the-amount of Chet
regulatory asset which must be ;amortized' by ongoing electric rates wild be red'uced•by any
monies actually recovered by PG &Eas a result'of the FERG price rollback.9 The direct
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6 Although, the.contested time`,period misses ;most&the' times 'during wFiieh ABAG P.OWER's Direct. Access Credit
was generated. The same legal;,arguments apply, and the FERC proceeding liar expanded the timeframe for
potential price rollbacks to ineludemore okhe period `in which ABAG POWER's'credits were• "generated."
' Settlement Decision, `p. 78.
' Master Settlement Agreement; p. 18, §21-
9 ' Master 'Settlement Agreement, pp. 8 -9, §2'.d.
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Wind Up Aercement- AttmtD- 4 -28 -04 All
effect of the FERC ordered rollback brings °significant rate relief under'the Confirmed Plan.'
In the context of.generalized rate relief, 'it appears doubtful that.the CPUC� would be willing
to undertake the ironic step of imposing a surcharge on certain , classes of customers
(including local ,government entities 'such as ABAG POWER's electricity members) in. order to
wring out the last bitter drop of'savings ;generated by the FERC.ordered refunds. Another
impediment to such action, by the CPUC is the specter of resurrecting the public debate
about California's failed energy deregulation program.
Conclusion
The CPUC- h.as.the`thedretical ability to reduce the Direct Access Credits paid to ABAG
POWER. However,, POWER can pose the foilowing legal, argument in position: (a) the
CPUC is estopped from so; doing by the CPUC's findings and actions in reaching the Master
Settlement Agreement with PG &E, an "d the CPOC's support for the: Confirmed Plan under
which the credits were paid, and (b) the logistical' and equity issues raised in the 1998 RAP
- Draft Decision. In :the, :absence of any motivation to undertake'.such'a step other than
bureaucratic purity of process, AB'AG POW €R's opinion is that the risk is nominal.
s
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10 Mas g estimates a 'potential - recovery by PG &E of
fer Settlement A reement
price reductions:
($ ) in FERC ordered
Wind Up Aurcement- .Atom D- 4 -28 - All
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EXHIBIT A.
TO ATTACHMENT" D:
Allocation of Estimated Contingent Liabilities.
This table illustrates 'the allocation of ABAG, P,OWER's estimate of the Electric Program liability for the
denoted charges among Electric Program members... Allocated:amounts have been rounded to the
nearest 10 dollars. Please see Attachment D for an explanation of'the methodology and basis for this
Member's
City of Albany
Town of Los Altos Hills
City of Antioch
City of Arcata
Town of Atherton
City of Benicia
City of Berkeley
County of Butte
City of Cloverdale
County of Monterey
County of Contra Costa
City of Cotati
City of Cupertino
City of Daly City
City of Davis
City of El Cerrito
City of Foster City,
Golden Gate Bridge District
City of Gonzales
City of Half Moon Bay
H.A.R.D.
City of Hercules
Town of Hillsborough
Housing Auth. Co. of Alameda
City of Los Altos
Los Trancos Co. Water District
City of Menlo Park
City °of Millbrae
City of Mill Valley
City:of Milpitas
Town of Moraga
County'of Napa
City,of Newark
City of Orinda
Cityof Pacifica . .
City -of Patterson.
City of Petaluma
Cityof Pinole
City-6f Pleasanton
R;A.F.C.
City of Salinas;
(A)
(B)
(D)
Uninvoiced
Direct Access
,Energy Charges -(1)
UDC Charges (2)
Credits (3)
$1,420,000'
:$1,600
$4
Total
$ 4;920
$ 1 5 1 550
$ 9,350 $
19,820
470
530
1,220
2,220 -
74,030
83
164,090
321,540
5,360
6
15,470
26,870
-2,860
3,220
8,000
14,080
18,1 6,0
20
50,600
89,230
4,060
4;570,
55,190
63,820
28,680
32,310
107,610
168,600
7,70.0
8;670
29,570
45,940,
78,860
88',860 .
151,450
319,170
207,960
2a4,320
778,930
1,221,210
3
4,460 ''
1.0;690
19,110
20,620'
23;230
49
92,890
6 2,020
69',880
357,930
489,830
3,320
3,740
3,720
10,780
5,130
5,780
16
27,440
19,770
22',280
54,620
96,670
19,880
22;400
101,650
143,930
5 ; 630
6;350
15,130
27,11.0
2,840
3,200
7,180
13,220
12,630
14,230;
38,750
65,610
7,890
8',890 ,
22,280
39,060.
11,460
12,91 ;0 ,,
30,760
55,130
1,880
2;120
": 6,690
1,0,690
7,760
8;740
20,970
37,470
1,010
1,,140•
1,330
3,480
17;380
19.;590'
56,130
93,100
7,890
8;890
12,770
29,550
15,860
1 7,870
50,970
84
16,580
18;'680
79,120
114;380
2,660'
3;000
3,660
9,320
21,800
24;560
109,150
1.55,510
1.3,140
14;81:0
25,400
53,350
2
2
5; "150
10,280
12,260
13
28,160
54,240
9,570
10,780
.62,570
82,920
54,380.
61 ;270
96,470
212,120
14,220
16;020
72,080
102,320
43,290
48,780
107,930
200,000
i 17,870
20,130
64,580
102,580
40,070
45,1'50
58,300
143,520
EXHIBIT'A
TO ATTACHMENT,D
Allocation of Estimated Contingent. Liabilities.
'This table' illustrates the.allocation of ABA, G.PO.WER's estimateof °the Electric. Program liability for'the
denotedcharges among Electric. Program members:, Allocated amounts have been rounded to the
nearest 10 dollars. Plbase,see Attachment - D for an explanation of the methodology and basis;for.,this
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(A)
(B)
(D)
Unihvoiced,
Direct Access.
Energy Charges (1)
UDC Charges(2)
Credits,
Members
$1
$1
$4576,000
Total
City of San Carlos
10;380
11,700:
27
49,250
City of San,Leandro
49,380
55,640.
139
244
City of San,Ma'teo
44,790
50,460
117,720,
212,970
County -of San Mateo
148;120
166,900
582,550
: 897,570
City of San, Pablo
9,370
10,550
.23
43,500
City of. Santa',Rosa
82,740
93
1:88480,
364
City-of Saratoga
4,360
4,920
10,060
'19,340.
County of Sonoma
7;230
8,150
15
30,770
South Co. Fire Authority
910
1,020'
3,800
5,730
City, of Union'City o
2;880
3,240
1.7,130
'23,250
Cityof Vacaville
7;770
8,760
26;690
43,220
City of Vallejo
9:1
103,450
346
541,760
West'County Wastewater Dist.
20,620
23,240
131
175;280
Town of W ridso.r
24
27,950
93
.11
146,150
City of Winters
6;570
7,410
11,540
25,520
Total•
$ 1419;980.
$' 1,600,000
$ 4,676,010 $
705,990;
Notes:
(1) Allocated' by kWh usage
(2):Allocated by kWh usage,
(3') Allocated on CTC Credit
Reversals. Represents PG &E's
estimate of the possible reduction
in the CTC credits due to the
FERC „price mitigation hearings.
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