On July 8, 2010, the Division of Ratepayer Advocates (DRA) protested the application. DRA stated that Pub. Util. Code § 454.9(b) requires that the Commission conduct a reasonableness review of all recorded CEMA costs prior to authorizing recovery in rates. DRA explained that the Commission is currently investigating the role of Edison's facilities in the Malibu Canyon fire, and that other fires are the subject of pending governmental investigations and lawsuits which include allegations regarding Edison's facilities having a role in the cause of the fires.3 DRA recommended that the costs associated with Malibu Canyon fire be disallowed or held in abeyance pending resolution of the Commission's investigation. DRA also stated that the outcome of the other investigations and lawsuits may bear on the reasonableness of costs for which Edison is seeking recovery. DRA also stated that it would audit the application and may raise additional issues from the audit.
3 DRA Protest at 2 - 3.