Finally, we note that Southwest's rebuttal testimony alludes to the gas cost incentive mechanisms (GCIM) adopted for PG&E (D.97-08-055), SDG&E (D.98-08-038) and SoCalGas (D.94-03-076).81 A similar GCIM for Southwest was discussed in Investigation 01-06-047, however D.02-08-064 in that proceeding did not adopt any incentive mechanism for Southwest. As this is the second time we have been asked to evaluate and address Southwest's gas procurement practices, we encourage Southwest to consider the filing of an application that might establish a GCIM as a means to reduce costs for ratepayers, and as an incentive to shareholders to benefit from improved gas purchase procedures.
81 Exhibit 5, Tab L, p. 14.