ELECTRIC INDUSTRY

I have, for many years, represented large industrial customers of regulated electric utilities in a variety of proceedings before the California Public Utilities Commission ("CPUC"). My principal client in this arena is the California Large Energy Consumers Association ("CLECA"), which is comprised of 11 heavy industrial electric customers with aggregate demand in excess of 320 MW. On behalf of CLECA, I have been an active participant in each of the general rate case and energy cost adjustment proceedings for Pacific Gas & Electric Company ("PG&E") and Southern California Edison Company ("Edison") over the past ten years. My work for CLECA normally involves cost of service, revenue allocation and rate design issues, but has also focused on preservation of certain interruptible service programs and the rate discounts associated with such programs.

Since 1993, I have been actively involved for CLECA in California's many-faceted debate over electric industry restructuring. CLECA was one of the principal proponents of direct access by customers to independent suppliers of electricity and I participated through rulemakings, investigations, negotiations with utilities and other user groups, and Legislative hearings. I negotiated with a few others the Memorandum of Understanding with Edison which led to the CPUC's decision to open the generation market in California. I participated in the negotiations surrounding the passage of AB 1890 by the California Legislature, which codified the restructuring arrangements. Since that time, I have been an active participant in numerous proceedings aimed at implementing the new market structure, including the calculation of and accounting for tr4ansition costs, metering and billing issues and restructuring implementation costs. I have also done a fair amount of work for individual CLECA members negotiating and documenting power purchase arrangements with alternative suppliers.

I currently represent the Sacramento Municipal Utility District ("SMUD") with respect to a number of restructuring implementation issues. SMUD is concerned about the new rules relating to competition within and outside its service territory, particularly issues or reciprocity with investor-owned utilities. SMUD is also concerned with the possible expansion of CPUC jurisdiction over safety and reliability issues. Our office has also represented SMUD in arbitration's regarding construction and operation of generation facilities.

I represent Scottish Power plc with respect to its acquisition of PacifiCorp. I have the task of obtaining CPUC approvals, as necessary, for the acquisition.

Our firm has represented ENRON with respect to siting and land use questions arising from its efforts to construct two new merchant power generation facilities in California. I have been called upon for advice on a variety of CPUC regulatory issues, including franchise fees, utility interconnection rules and standby charges.

I currently represent U.S. Generating Company in its effort to obtain CPUC approval of its settlement agreement with Edison resolving all claims arising form the 1993 auction of generation construction contracts in California which was later suspended by the CPUC.