III. Discussion

We agree with Roseville that it would be more efficient to address in one proceeding, rather than two, revisions to Roseville's rates to reflect its draws from the CHCF-B and the loss of its EAS revenues. One proceeding has the added advantage of producing only one change in rates, while two proceedings might result in two separate rate changes. Two rate changes should be avoided, if possible, because it would probably cost more for Roseville to implement two rate changes (since each change would require revisions to Roseville's tariffs, billing system, etc.), and because Roseville's customers might be confused or frustrated by one rate change after another.

For the preceding reasons, we will modify D.98-09-039 to require Roseville to submit in I.01-04-026 its proposal to reduce its rates and price ceilings (collectively, "rates") to offset its draws from the CHCF-B. As required by D.98-09-039, any such proposal must reduce Roseville's rates by an amount equal to its draws from the CHCF-B during the most recent 12-month period for which data is available at the time the proposal is submitted.² Since the record is unclear as to whether Roseville previously submitted a CHCF-B rate-reduction proposal in I.01-04-026,³ Roseville will have 30 days from the effective date of this decision to submit a proposal, if it has not done so already, that conforms to the requirements set forth on page 2 of the scoping memo issued in I.01-04-026 by the assigned Commissioner on November 30, 2001.

Except for the modification to D.98-09-039 authorized by this decision, D.98-09-039 remains in full force and effect. In particular, today's decision does not relieve Roseville of the requirement established by D.98-09-039 to maintain rate reductions to offset its draws from the CHCF-B for as long as the draws continue.⁴