8. Transparency of Major
Decommissioning Expenditures

To date, the Commission has only its experience with the decommissioning of SONGS 1 as a basis to develop its methods for exercising oversight of the utilities' decommissioning activities. PG&E, as its own contractor, has recently begun to decommission Humboldt Bay Power Plant and has used Advice Letters to communicate with the Commission about its activities. The procedures followed by PG&E and SCE for SONGS are different due to a lack of direction from the Commission. Further, PG&E's Advice Letters have not contained all of the information necessary for the Commission to adequately or promptly review how closely actual costs are following estimated costs during the major decommissioning phase where the vast majority of activities and expenses occur. We think this is an essential part of our oversight and waiting for triennial review after hundreds of millions of dollars may be spent, perhaps well in excess of what has been previously estimated, is unreasonable.

Therefore, at the March 14, 2011 evidentiary hearing in Phase 2 of this proceeding, representatives of the utilities agreed to meet with Energy Division to discuss the Advice Letter process for notice and authorization to withdraw funds from the nuclear decommissioning trust funds. PG&E agreed to a periodic Advice Letter process under Tier 2 to request approval for anticipated trust fund disbursements and which will include, inter alia, specific information about the activities, prior cost estimates, actual costs, and whether trust fund reimbursement has been obtained. A description of the process and contents of the Advice Letters is attached hereto as Attachment B.

SCE and SDG&E expressed their preference to not have this process apply to SONGS 1 until Phase 3 and commencement of SONGS 2 and 3 decommissioning. We agree at this time because the ongoing decommissioning expenses at SONGS 1 are minor, giving the Commission time to evaluate the Advice Letter process for HBPP to determine whether it is appropriate and sufficient review before extending it to other decommissioning activities.