7. Burden of Proof Under Statute
and Rate Case Plan

Pursuant to § 454(a), before implementing a rate increase, an applicant must make a "showing before the Commission," and the Commission must find that the proposed increase is "justified." As a result, the applicant in this case, San Gabriel, bears the burden of proving that its proposed rate increases are justified.

In adopting the revised Rate Case Plan, the Commission further articulated the required showing for a water utility's General Rate Case: "The utility's application for a rate increase must identify, explain, and justify the proposed increase." Specifically, the application must include testimony, with supporting analysis and documentation, describing the components of the utility's proposed increase, for example, results of operations, and plant in service. All significant changes from the last adopted and recorded amounts must be explained, and all forecasted amounts must include an explanation of the forecasting method.

In considering each remaining disputed issue, we evaluate whether San Gabriel's showing meets our standards for justifying a rate increase or otherwise approving the San Gabriel request. As set out below, we resolve the three remaining issues in dispute.