California Community Choice Association ("CalCCA") recommends: (1) the investor-owned utilities' ("IOUs") proposed bid floors should be rejected; (2) the proposed IOU Codes of Conduct ("CoC") should be modified and enhanced; (3) any requirement that bidders waive or limit their rights for redress for any violation of the terms of the solicitation should be removed; and (4) San Diego Gas and Electric ("SDG&E") should be required to revise its Market Offer process.