On October 2, I, Aaron Klem and our outside attorney, Jeanne Bennett, met with other ESPs, the utilities, and the Energy Division staff of the CPUC to hammer out an agreement on implementing the CPUC's order suspending direct access (DA) and handling continued submission of DASRs.
It was news to the utilities that ESPs have many contracts --  most several years old -- that allow for addition and subtraction of facilities throughout the contract term.
The utilities had thought that cutting off DASRs would be the best way to enforce the CPUC's order without having to review contracts (which they don't want to do).
After much discussion and debate, the participants agreed to make a joint filing at the CPUC seeking quick action.

ESP/UDC/CPUC Meeting on Implementation of DA Suspension
On October <NUMBER>, I, Aaron Klem and our outside attorney, Jeanne Bennett, met with other ESPs, the utilities, and the Energy Division staff of the CPUC to hammer out an agreement on implementing the CPUC's order suspending direct access (DA) and handling continued submission of DASRs.
It was news to the utilities that ESPs have many contracts -- most several years old -- that allow for addition and subtraction of facilities throughout the contract term.
The utilities had thought that cutting off DASRs would be the best way to enforce the CPUC's order without having to review contracts (which they don't want to do).
After much discussion and debate, the participants agreed to make a joint filing at the CPUC seeking quick action.
facilities contract term implementing cpuc allow addition subtraction years old news utilities esps access da make joint filing order suspending direct participants agreed cutting dasrs