Exhibit 99.270 CALIFORNIA POWER EXCHANGE REQUESTERS: PAUL GRIBIK, RYAN DOCUMENT OF UNDERSTANDING - ZONAL PRICE CALCULATOR WESTLING, JOHN MAY ZONAL PRICE CALCULATOR OVERVIEW The Zonal Price Calculator (ZPC) is a key component to relieve congestion for market open. In response to its business importance and priority, we've created this document of understanding to: o Communicate the current status of the ZPC. o Document conditions [although not definitively] possibly encountered within the ZPC, that we believe provide gaming risk to the Market. o Request requirement specification from Product Management for the mitigation of those identified risks o Confirm the inclusion of the ZPC in OM Hand-El Stage 2. o Confirm settlement functionality pertaining to the ZPC CURRENT STATUS Gribik, Westling and May agree that the current version of the Zonal Price Calculator is working true to the way we believe it was originally specified. However, we also agree the calculator needs to be stressed tested with additional adjustment bids to ensure the final measure of market open quality. And we further agree that this Zonal Price Calculator is only a temporary solution, giving way to OM Hand-El Trade App. Additional activities: o Stress test with adjustments bids, Feb 9-10, 1998. o Development of automated interface to avoid re-keying of ZPC data GAMING RISK Gribik identified a number of conditions caused by potential participant gaming that present risk to the Market. These are, among others: 1) When an adjustment bid falls outside of the adjusted bid curve, currently, the anchor price is set no lower than zero. Solution discussed: allow the anchor price to go below zero to a maximum of the minus penalty value. ISO Requirement: publish the penalty prices and price transmission based on it. 2) Arbitrarily increase or decrease the starting reference price - not just set to zero at the beginning and move the curve up. 6/27/2002 Page 1 CALIFORNIA POWER EXCHANGE REQUESTERS: PAUL GRIBIK, RYAN DOCUMENT OF UNDERSTANDING - ZONAL PRICE CALCULATOR WESTLING, JOHN MAY Solution discussed: start the anchor price lower and let it flow up = - penalty PX is then required to bid inside the price range - bid price range needs to be inside the penalty range like $900 mwh. ISO and PX need to agree that: If gen(j) < = gen(j)min then dc(j) = - penalty If gen(j) > gen(j)max then dc(j) = penalty If dem(k) < dem(k)min then ic(k) = penalty If dem(k) > = dem(k)max then ic(k) = - penalty 3) If the PX receives no adjustment bids (and ISO does) and there is no way to set the anchor price on the PX. No solutions discussed. APPLICATION DEVELOPMENT SPECIFICATIONS We request that appropriate businsess requirements be gathered and technical specifications created to mitigate, as much as possible, the ability of market participants to game the market. In addition, we request that any appropriate tariff or business policies be adjusted as necessary to support these business requirements. OM HAND-EL STAGE 2 The PX must confirm the inclusion of the Zonal Price Calculator in OM Hand-El Stage 2 and its relative priority. The ZPC should be tightly integrated into the Trade Application including current functionality, automated interface and all known requirements to mitigate the impact of gaming and/or exceptional conditions in the market. SETTLEMENT FUNCTIONALITY Confirm if settlements have the capability to generate an invoice for a participant for energy if ZPC is negative. BUSINESS AREAS IMPACTED Trading, Compliance, Information Technology DATE COMPLETION PX - February 13, 1998 OM Hand-El - unknown OM Handel Stage 2 - unknown DEPENDENCIES OM Hand-El delivery of automated interface to avoid re- 6/27/2002 Page 2 CALIFORNIA POWER EXCHANGE REQUESTERS: PAUL GRIBIK, RYAN DOCUMENT OF UNDERSTANDING - ZONAL PRICE CALCULATOR WESTLING, JOHN MAY keying of ZPC data. Development of requirements for the Zonal Price Calculator for inclusion in OM Hand-El Stage 2. RECOMMENDATIONS / NEXT STEPS 1) Stress test with adjustments bids, Feb 9-10, 1998 - P. Gribik/Application Development. 2) Develop automated interface to avoid re-keying of ZPC data - OM Hand-El/Application Development 3) Confirm inclusion in OM Hand-El Stage 2. 4) Confirm settlements capability to invoice for energy if ZPC is negative - R. Johnson. 6/27/2002 Page 3