Comments on Proposed Decision

The proposed decision of the Administrative Law Judge in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed on September 10, 2007 by CalWEA, GPI, and CSPA jointly (CalWEA) and by SCE. Reply comments were filed on September 14, 2007 by DRA.

CalWEA supports the PD but expresses concern that the calculation of the 2007 MPR may not be coordinated with our order on the petition for modification. We believe that Ordering Paragraph 1, below, provides adequate assurance on this point.

SCE reiterates its position that it is premature to include a GHG adder in the 2007 MPR, both because GHG control costs are not sufficiently definite and because the point of GHG regulation has not yet been decided. DRA, in reply, asserts that under any GHG regulatory regime, a generator emitting GHGs will ultimately incur costs to continue to emit at the same level; those costs will be passed on to the users of the electricity. We agree with DRA, and will employ a GHG adder in the 2007 MPR. We have expanded the discussion in the text to make our reasoning more accessible.