VI. Procedural Process and Schedule for Future Filings

A. Long-term Procurement Plan Filings

SCE proposes that its long-term plan be reviewed on a three-year cycle, in coordination with its general rate case. Specifically, SCE proposes that each utility develop and submit a long-term integrated resource plan within 90 days of the final decision in its respective GRC. This would allow its plan to incorporate those issues resolved in the GRC. Further, SCE states that the Rate Case Plan (D.89-01-040, as modified) already contemplates submission of long-term resource plans as part of the utility's GRC showing.

In comments on the proposed decisions issued by ALJ Walwyn and Commissioner Peevey, the CEC specifically opposes the adoption of SCE's proposed triennial long-term plan filing schedule. The CEC argues that a triennial cycle will needlessly disconnect utility planning from the CEC's biennial IEPR process:

"The triennial cycle virtually guarantees that most of the time an IOU will want to propose its own analyses as the base case, rather than use the IEPR results, and do so simply because their analyses are fresher than the IEPR results."¹¹⁶

The CEC also argues that if utility long-term plan filings are staggered to follow a GRC cycle "...there will be no consistent `lead or lag' between any IOU [plan filing] and the IEPR."¹¹⁷ The CEC further states that staggered long-term plan filings will undermine opportunities to achieve what should be common policy and practices among the three IOUs.

ORA and the ISO also oppose a staggered GRC cycle approach and articulate similar concerns voiced by the CEC.

We intend to review and adopt revised long-term procurement plans for the three utilities in our new Procurement OIR in 2004. With respect to the filing schedule for long-term plans submitted after 2004, we find the arguments made by the CEC, ORA and TURN against adopting SCE's proposed filing schedule to be compelling. A staggered GRC filing schedule will inappropriately disconnect the utilities planning efforts from the CEC IEPR process and is likely to result in duplicative and wasteful efforts on the part of PUC staff and interveners as result of having to review and litigate filings in three separate GRC proceedings. To achieve efficiencies in the commitment of staff and parties' resources, we will require the three IOU long-terms plans to be vetted in one proceeding sharing the same procedural track. We also find that taking this approach will better ensure appropriate coordination with the CEC's IEPR process as well ensure that our policies regarding utility resource planning are coordinated and consistent among the three utilities.

Following our decision adopting revised 2004 long-term procurement plans, the IOUs shall file long-term plans on a biennial cycle (on a date to be determined) that follows the CEC's adoption of a final IEPR report. In our decision on the revised 2004 plans, we shall revisit the specific timing of the IOUs' next round of long-term plan filings.

B. ERRA Filings

ORA and SCE recommend that the Commission annually update the short-term procurement plans 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.

Outlined in the tables below are the ERRA schedules for 2004 and 2005, as presented in the ALJ Walwyn PD, mailed on November 18, 2003. In its comments on the ALJ Walwyn PD, ORA stated that the ERRA schedules in the PD are inconsistent with AB 57 because the schedules do not incorporate a semi-annual review of the power procurement balancing accounts, as ordered by AB 57. ¹¹⁸ We clarify here that our intent is to have the IOUs use the ERRA Forecast and Reasonableness Review applications as semi-annual opportunities to make a showing that the Commission needs to review the power procurement balancing accounts and adjust rates or order refunds. Therefore, we adopt the 2004 and 2005 ERRA schedules as originally proposed and outlined below.

2004 ERRA Schedule
IOU	2004 ERRA Trigger AL /1	2004 ERRA Forecast	2003 Reasonableness Review	ERRA Over/Under Collection True-up /2
PG&E	April 1,2004	August 2003	August 2003	N/A
SCE	April 1, 2004	October 2003	October 2003	N/A
SDG&E	April 1, 2004	December 2003	December 2003	N/A

Footnotes:

1/ The trigger advice letter is used to calculate the ERRA trigger/threshold amount and is based on 12-months (calendar) of prior year recorded data. The IOU's will refile AL if Reasonableness Review Decision modifies recorded data. Note: By April 1, 2004 the IOUs will have closed their books for 2003 and filed their SEC reports.

2/ ERRA over/under collection true-up is independent of when IOUs file ERRA Forecast or Reasonableness Review applications-The IOUs will file an expedited application for Commission approval in 60 days when the ERRA balance reaches the trigger/threshold amount calculated in the Trigger AL.

2005 ERRA Schedule
IOU	2005 ERRA Trigger AL /1	2005 ERRA Forecast /2	2004 Reasonableness Review /3	ERRA Over/Under Collection True-up /4
PG&E	April 1, 2005	June 1, 2004	February 2005	N/A
SCE	April 1, 2005	August 1, 2004	April 2005	N/A
SDG&E	April 1, 2005	October 1, 2004	June 2005	N/A

Footnotes:

1/ The Trigger advice letter is used to calculate the ERRA trigger/threshold amount and is based on 12-months (calendar) of prior year recorded data. The IOU's will refile AL if Reasonableness Review Decision modifies recorded data. Note: By April 1, 2005 the IOUs will have closed their books for 2004 and filed their SEC reports.

2/ The dates have been changed so the IOUs file earlier in the year. This will allow IOU/PUC to have decisions out by the end of the year.

3/ 2004 Reasonableness Review period will incorporate 12 months of 2004 calendar year data.

4/ ERRA over/under collection true-up is independent of when IOUs file ERRA Forecast or Reasonableness Review applications. The IOUs will file an expedited application for Commission approval in 60 days when the ERRA balance reaches the trigger/threshold amount calculated in the Trigger AL.