11.   FERC can only order a refund once it has made the rates subject to refund, which it did for rates only back to October, Angle said.

12.   FERC has the authority to order refunds and take other actions to resolve the financial disputes, but up to now has been criticized for not doing so aggressively.

13.   House Democrats asked federal energy regulators Tuesday why they are not going more aggressively after alleged overcharges for wholesale electricity in California and ordering more refunds.

14.   Meralco indicated last week that it would take the case to court if the board ordered refunds.

15.   Sen. Barbara Boxer, D-Calif., introduced legislation that would require FERC to order refunds for past unreasonably high electricity purchases in the West.