Jeanne,

I think you are saying more and going into more detail than we need to.   It 
was my understanding from the call that you were not going to get into the 
statutory interpretation issues at all. 

I think modifying the first sentence of the carryover to the top of page 2 
(at least as printed on my machine) is fully sufficient if you just say:

"Moreover, EPMI submits that DWR has presented the Commission with a 
reasonable [STRIKEOUT interpretation of the STRIKEOUT]  approach for 
implementing the applicable statutory language." 

I do not understand the benefit of the balance of the paragraph.   It opens us 
up to getting drug into a interpretation argument we do not need to be in. 

Similarly, I do not understand why we would want to say "is consistent with 
the statutory language" and similar statements in the following paragraph. 

I am not sure I agree fully with those statements or that we need to be 
limiting our ability to respond to any further proposals which may come out 
by taking a firm position of the statutory foundation for CDWR's approach in 
this letter. 

Am I missing something?    Thanks

>>> JBennett <JBennett@GMSSR.com> 03/21 11:26 AM >>>
Attached, per our conference call of earlier this morning, are short and
sweet comments on the March 14, 2001 letter of DWR re CPA implementation. 
Please provide any comments/questions  to me as soon as possible. 

<<X22873.DOC>>

Jeanne Bennett