VIII. Procedural Process and Schedule for Future Filings

A. Quarterly Compliance Filings

On September 10, 2003, PG&E and SDG&E filed a joint petition to modify D.02-10-062, specifically to extend the due date of the Quarterly Procurement Plan Compliance Reports from within 15 days of the end of the quarter to within 30 days of the end of the quarter. Both utilities state that they need this additional time to prepare sufficiently detailed and comprehensive reports. Parties testified to the thousands of transactions that are included in the quarterly compliance filings. Therefore, we find PG&E's and SDG&E's joint petition reasonable and grant the relief sought, on a going forward basis, in this decision.

We also take this opportunity to address the procedural process under which we review these compliance filings. In D.02-12-074, in Section VI, we set a procedural process under which the Energy Division would review the quarterly compliance filings on an expedited basis, with a 30 day review period as a guideline, and then prepare a resolution with their findings and place it on the Commission's agenda. With the Commission's current staff resources, a full review of the filings cannot be done in these expedited timeframes. Rather, the Commission should look to streamlining its review by having the utilities provide an independent auditor's certification that procurement transactions were reviewed and verified to be in compliance with their adopted procurement plans. This procedure was discussed with SCE's witness Cini, who agreed that Energy Division, in consultation with the PRG, could select an outside auditor for this function. ³² Therefore, we find that the Energy Division should, in consultation with each utility and its PRG, select an outside auditor to review and verify that the quarterly compliance filings are in compliance with the adopted procurement plans, and the audit expenses should be paid by the utilities and recorded in a memorandum account. Given the large volume of transactions conducted each quarter, we recognize that sampling may be appropriate method for verification. A resolution for the Commission's agenda should only be prepared if Energy Division or the outside auditor find transactions or procurement practices that are not in compliance with the adopted plans.

B. ERRA Filings

ORA and SCE recommend that the Commission annually update the STPPs in each utility's ERRA filing. In addition, PG&E, SCE, and SDG&E have all indicated in their ERRA filings that efficiencies could be made in the procedural process we adopted in D.02-10-062, especially with forecasts established closer in time to the applicable year, a combining of the forecast, reasonableness review, and ERRA true-up in one application for each utility, and the possibility of the ERRA trigger amount being handled by Advice Letter rather than application.

In today's decision we make no change to existing ERRA filing schedules, preferring to assess the merits of the ORA and SCE recommendations as part of the comprehensive policy decision forthcoming after January 1, 2004.