As filed, the petition to modify did not propose a detailed mechanism for recovery of any increased expenses for pension or other benefits. Pursuant to a request by the assigned ALJ, SDG&E and SoCalGas proposed to use the Annual Regulatory Account Advice Letter filing2 that each company makes to amortize the balances of various accounts. They indicated that using the mechanism to amortize the incremental costs preserves the relative allocation of the incremental expenses across all customer classes.
(van de Leeden declaration at § 4.)
Using the Annual Regulatory Account Advice Letter resolves a concern raised by the Division of Ratepayer Advocates that the petition was too vague. We find that the Annual Regulatory Account Advice Letter is a reasonable mechanism to recover any annual increase in expenses for pension or other benefits.
2 See for example, SDG&E's Advice Letter 2037-E, dated October 30, 2008, which addressed balances in eight separate balancing and memorandum accounts. Also see SoCalGas' Advice Letter 3910, dated October 15, 2008.