6. Issues Raised by the NBC Agreement

The Application raises issues related to the billing of NBCs addressed in R.02-01-011, and issues related to the billing of DWR-related CRS addressed in R.06-07-010. As a result, the February 26 Ruling directed Applicants to file and serve comments on the issues discussed below, and invited parties to A.09-06-023, R.02-01-011 and R.06-07-010 to submit comments on the same.

The February 26 Ruling sought comments on, among other things:
(1) whether agreements that reduce the amount of NBCs payable to reflect uncollectibles and avoided costs are permissible under Commission decisions or statutes prohibiting cost shifting; and (2) if the Commission may approve an agreement that relieves PG&E of its obligations to bill and/or collect NBCs and that releases NMDL Customers that receive electric distribution service from the Districts from liability for NBCs otherwise due or that may accrue pursuant to current Commission decisions and PG&E Schedule E-NMDL.