10. Next General Rate Case

Alco is a Class B company and typically Class B general rate cases are filed by advice letter. The Commission directed Alco to file this general rate case as an application and DRA actively and fully litigated the proceeding. The litigated issues were significant in this proceeding, but were based on genuine differences of opinion and we have no reason to doubt Alco's good faith in its filing. Nevertheless, we believe that Alco should file its next rate case as a full application and not as an advice letter. This is a discretionary choice on our part: Alco is a very large Class B company and is a sophisticated water operation. We therefore find it prudent to examine Alco's next general rate case for a test year no earlier than 2013 under the full scrutiny applied to an application. Therefore, there will be no increase in base rates beyond the 2012 attrition allowance until Alco files subsequent general rate case. This requirement should be revisited in the next proceeding and should not automatically result in the continued use of the application process over the advice letter process beyond the next proceeding (unless Alco were to become a Class A company through continued growth). The Commission should make an appropriate finding in the next proceeding.