4. Issues Before the Commission

The parties to the proceeding consist of Heather Epps (Applicant) and PG&E. The Applicant requests that the Commission modify D.06-07-027 and D.09-03-027 so as to shift the costs for the AMI program to PG&E and its investors. PG&E requests that the Commission dismiss the application, and thereby keep the program unchanged.

The central issue before the Commission is whether the Applicant has alleged new facts that, if supported by the Applicant, would warrant granting the application.