II. Procedural Background

Our order instituting rulemaking (OIR) describes the evolution of our hourly ratesetting process; we will not repeat that description here. Before the OIR, we held two informal meetings, open to all interested persons and well attended by intervenors and utilities. We also solicited and received letters from Union of Concerned Scientists (UCS) and The Utility Reform Network (TURN) fleshing out some of the ideas they brought up at the meetings. This preliminary work greatly helped to focus the OIR, and we express appreciation for the participants continuing efforts.

The record of our hourly rate updates consists of utility compensation data sets and party comments. The due date for the data sets is annually on April 30, when the annual compensation reports under General Order 77-M must be filed.¹ The OIR provided for two rounds of comments (opening and reply) to be filed concurrently, with certain additional compensation data to be supplied by the utilities with their opening comments.

Two intervenors, The Greenlining Institute (Greenlining) and Public Advocates, submitted "preliminary" comments (seeking to broaden the rulemaking) before the due date for opening comments. Greenlining also participated fully in the scheduled comment cycle.

The following parties (besides Greenlining) filed opening comments: Aglet Consumer Alliance (Aglet); AT&T California; Pacific Gas and Electric Company (PG&E); San Diego Gas & Electric Company and Southern California Gas Company (SDG&E/SoCalGas, filing jointly); Southern California Edison Company (SCE); Verizon California Inc.; and the Joint Intervenors (consisting of TURN, UCS, Disability Rights Advocates, Green Power Institute, Utility Consumers' Action Network, and Consumer Federation of California). Although Aglet did not formally participate in the Joint Intervenors' opening comments, Aglet joined in the latter's reply comments. With the exception of Aglet and SDG&E/SoCalGas, the parties filing opening comments also filed replies.

¹ In other words, the utilities generate and distribute the basic compensation data without having to wait for the OIR to issue.