5. Assignment of Proceeding
Susan P. Kennedy is the Assigned Commissioner and Burton W. Mattson is the assigned ALJ in this proceeding.
1. Energy customers in California and three western states will receive an estimated $1.5 billion (nominal value) as a result of settling litigation with El Paso.
2. A series of decisions and agreements now govern CDWR cost recovery from utilities and ratepayer under our jurisdiction (e.g., D.02-02-051 regarding the Rate Agreement).
3. Adjustment of future CDWR revenue requirement allocations to reflect allocations in effect during 2000 and 2001 would add complexity, and would conflict with updated CDWR allocations (if any), while using allocation percentages in effect at the time El Paso consideration is distributed to CDWR is simpler and consistent with the Commission's preference for a minimalist approach.
4. Settlement revenues credited to an electric utility's ERRA will expeditiously reflect Settlement payments as a reduction in procurement costs.
5. A reasonable and equitable approach to reducing SDG&E's AB 265 undercollection is to first apply 70% of SDG&E's share of Settlement revenues to the AB 265 subaccount in SDG&E's TCBA, with the remaining 30% of SDG&E's share allocated to the large customer subaccount of the ERRA (ABX1 43) and, upon payment in full of the undercollection in SDG&E's AB 265 subaccount, applying the balance of all Settlement revenues to SDG&E's ERRA.
6. The 70/30 approach to reducing SDG&E's AB 265 undercollection is consistent with our preferred minimalist approach, utilizes SDG&E's existing accounting mechanisms to the fullest extent possible, and provides an equitable accounting for Settlement consideration allocated to SDG&E's electric customers.
7. The amount of unrecovered costs payable by PG&E electric ratepayers will be determined in other proceedings (e.g., PG&E bankruptcy proceeding (I.02-04-026) or the rate stabilization proceeding (A.00-11-038 et al.)).
8. The use of an interest bearing memorandum account for PG&E will not unacceptably delay the return of Settlement money to PG&E ratepayers, but will ensure that PG&E rates are reduced below what they would otherwise be absent El Paso consideration, and will be accomplished in a coordinated process that properly treats many complex interrelated matters.
9. To the extent that utility DA customers must help pay for the utilities' previously unrecovered costs, DA customers are due a fair share of the consideration received by California electric utilities under the Settlement.
10. A reasonable and equitable allocation of El Paso consideration between full service and DA customers for SCE and SDG&E is to allocate the proceeds to the ERRA for full service customers (with the further 70/30 split adopted for SDG&E), and the DA CRS tracking or memorandum account for DA customers, based on the relative percentage of full-service and DA to total kWh system deliveries in the preceding 12 months prior to their first receipt of consideration under the MSA.
11. For PG&E, a reasonable and equitable treatment for DA customers is to place El Paso consideration into an interest bearing memorandum account for the future benefit of PG&E's ratepayers once the Commission determines the extent to which the full-service ratepayers and DA customers will pay PG&E's previously unrecovered costs.
12. An allocation between full service and DA customers based on deliveries in the preceding 12 months prior to the first receipt of consideration under the MSA avoids an adjustment based on current DA load, reasonably compensates those who were damaged, is a stable and simple method, and is consistent with the Commission's preference for a minimalist approach.
13. Crediting Settlement revenues attributable to core gas customers to the PGA will expeditiously reflect Settlement benefits as a reduction to core gas procurement costs.
14. For Southwest, crediting either the CFCAM or PGA will accomplish the purpose of expeditiously reflecting the value of the Settlement as a reduction to core gas procurement costs, while applying Settlement proceeds first to the CFCAM (until its balance is zero) will mitigate the rate impact of recovering Southwest's undercollected CFCAM balance.
15. Core-elect and core-subscription gas customers will receive the benefit of El Paso consideration by the credit to the gas utilities' PGA (or CFCAM for Southwest) to the extent they are still served by the gas utilities' core portfolios.
16. Requiring noncore customers who were core-elect or core-subscription customers for some or all of the March 1, 2000 through May 31, 2001 time frame to apply to their utility for a refund of their share of Settlement consideration entails administrative costs disproportionate to the amount of money to be allocated to this group.
17. A reasonable and equitable refund plan returns a pro rata share of Settlement consideration to current noncore customers who were core subscription customers for some or all of the period between March 1, 2000 and May 31, 2001, and, once the refund is complete, transfers the remaining balance, if any, to the PGA.
18. Use of a net present value to discount up-front payments to some customers is administratively feasible, efficient and equitable, while it minimizes administrative cost and complexity.
19. Gas consumers who were part of the core aggregation program during the March 1, 2000 through May 31, 2001 period, but who now purchase gas from utilities, will receive their share of the El Paso consideration through utility credits to the PGA (or CFCAM for Southwest).
20. Gas customers who were part of the core aggregation program during the March 1, 2000 through May 31, 2001 period, and who still purchase gas from core aggregators, will not receive El Paso consideration via the credit to the utilities' PGA (or CFCAM).
21. Core aggregation customers pay a core aggregation transportation charge that gas utilities charge for the transportation of gas provided by the core aggregators.
22. A reasonable and equitable treatment of El Paso consideration for customers of core aggregators transporting natural gas on the utility's facilities is as described in this order (i.e., book a proportional share of the Settlement consideration attributable to core aggregation customers in the EPSMA; set aside the total amount allocated to core aggregation customers from the upfront cash amount based on a net present value of the payment stream that would otherwise occur over time; use the EPSMA balance at the time of the next appropriate ratemaking proceeding to partially offset the utility's allocated core aggregation transportation revenue requirement; provide a proportional share of the Settlement consideration based upon the class's share of the utility's total system natural gas throughput, excluding noncore volumes, for the 12 months immediately prior to the time that the utility first receives the consideration; allocate the Settlement consideration to a fractional-cent per-therm for all deliveries, excluding noncore, to all customers served by respondents).
23. Transportation rates paid by core aggregation and core procurement customers will be equal in about 12 months using the approach described above.
24. Noncore customers are not required to obtain their portion of the refund from their competitive suppliers, and neither should core aggregation customers be required to obtain their portion from their core aggregators.
25. El Paso consideration is intended for end-customers not suppliers, marketers or core aggregators.
26. The end-use customers of six wholesale gas transportation customers of PG&E suffered the same harm from high natural gas prices at the California border as did other end-use gas customers.
27. A reasonable and equitable treatment for these six PG&E wholesale gas transportation customers is to treat them in a manner similar to the treatment for core aggregation customers (i.e., they receive a proportional share of PG&E's core settlement consideration based upon the wholesale customer class share of PG&E's total system natural gas throughput (excluding noncore volumes) for the 12 months immediately prior to the time that PG&E first receives the consideration; the allocation is taken from the upfront cash allocated to core procurement and core subscription customers based on a net present value of the future payment stream; their Settlement share is booked to a subaccount of the EPSMA until the appropriate ratemaking proceeding, where the memorandum account balance is used to partially offset PG&E's allocated wholesale transportation revenue requirement).
28. No party objects to treating El Paso consideration in a manner that is neutral with respect to utility incentive mechanisms.
29. The Commission's adopted treatment of El Paso consideration is intended to have no tax effect on utilities because the entire consideration received by utilities inures to the benefit of their ratepayers.
30. The disallowance of $2,691,675 in gas procurement cost recovery for Southwest was because of imprudent management, not for shareholders and ratepayers to share the pain of high prices.
1. No party requests evidentiary hearing, and none is required.
2. Allocation percentages for El Paso consideration distributed through CDWR's revenue requirement should not remain fixed based on allocation percentages in effect during the 2000-01 period, but should change over time as allocation percentages change.
3. Continuous DA customers should not receive any portion of the CDWR refunds
4. Settlement revenues should be credited to SCE's ERRA.
5. SDG&E should apply 70% of SDG&E's share of Settlement revenues to the AB 265 subaccount of SDG&E's TCBA, and 30% to the large customer subaccount of the ERRA (ABX1 43), until payment in full of the undercollection in SDG&E's AB 265 subaccount, at which time the balance of all Settlement revenues should then be applied to SDG&E's ERRA.
6. The Commission should require that PG&E establish an interest bearing memorandum account where it shall place the proceeds of the El Paso Settlement consideration to be held for PG&E's electric customers, and further require that PG&E credit these proceeds to benefit its electric ratepayers for unrecovered costs its ratepayers will have to pay once determined in either the PG&E bankruptcy proceeding (I.02-04-026) or the rate stabilization proceeding (A.00-11-038 et al.).
7. For SCE and SDG&E, Settlement proceeds for electric customers should be allocated to the ERRA for full service customers, and the DA CRS tracking or memorandum account for DA customers, based on the relative percentage of full-service and DA to total kWh system deliveries in the preceding 12 months prior to their first receipt of consideration under the MSA.
8. For PG&E, El Paso consideration should be placed in an interest bearing memorandum account for the future benefit of PG&E's ratepayers once the Commission determines the extent to which the full-service ratepayers and DA customers will pay PG&E's previously unrecovered costs.
9. Settlement proceeds allocated to core gas customers of PG&E, SDG&E and SoCalGas should be credited by each utility's PGA, with the first Settlement payment net of the discounted amounts allocated up-front to some customers.
10. Settlement proceeds allocated to core gas customers of Southwest should first be credited to Southwest's CFCAM (net of the discounted amounts allocated up-front to some customers) until the CFCAM balance is zero, with the remainder then be applied to the PGA balance.
11. Each gas utility should propose a refund plan for its customers who were core-elect or core-subscription customers for some or all of the March 1, 2001 through May 31, 2001 period following the principles stated in this order (i.e., the refund plan should be based on the customer's purchases from the utilities' core portfolios (in therms) during the period at issue, as shown on their bills; the refund should be allocated to a fractional-cent per-therm for all throughput, with rate treatment as discussed regarding core aggregation; the refund should be paid up-front based upon a net present value of a reasonable forecast of potential payments; the refund should be accounted for by initially recording the revenues in the PGA with utility refunds or credits to these noncore customers booked to the PGA as an expense; and, once the refund is complete, the remaining balance, if any, should be transferred to the PGA).
12. Each gas utility with core aggregators transporting natural gas on the utility's facilities should follow the refund approach described in this order (i.e., book a proportional share of the Settlement consideration attributable to core aggregation customers in a new account called the EPSMA; the amount for core aggregation customers should be set aside from the upfront cash payment based on a net present value calculation; the EPSMA balance should be used, at the time of the next appropriate ratemaking proceeding, to partially offset the utility's allocated core aggregation transportation revenue requirement; the proportional share of for these customers should be based upon their class's share of the utility's total system natural gas throughput, excluding noncore volumes, for the 12 months immediately prior to the time that the utility first receives the consideration; the Settlement consideration should be allocated to a fractional-cent per-therm for all deliveries, excluding noncore, to all customers served by respondents, with the core aggregators' share recorded in the EPSMA until it is credited against the core aggregation transportation charge).
13. Six wholesale gas transportation customers of PG&E should be treated in the same manner as core aggregation customers (i.e., they receive a proportional share of PG&E's core settlement consideration based upon the wholesale customer class share of PG&E's total system natural gas throughput, excluding noncore volumes, for the 12 months immediately prior to the time that PG&E first receives the consideration; the allocation should be taken from the upfront cash allocated to core procurement and core subscription customers; the wholesale share of the settlement should be booked to a subaccount of the EPSMA until the appropriate ratemaking proceeding where the memorandum account balance should be used to partially offset PG&E's allocated wholesale transportation revenue requirement; and the amount allocated for these customers should be calculated based on a net present value).
14. Utilities should not receive any unintended or unearned benefit or detriment through application of an incentive mechanism as a result of the Settlement, but the determination of any incentive should be calculated as if the Settlement payments had not occurred.
15. The adopted accounting and ratemaking treatment of Settlement consideration should have no tax effect on utilities, and no ratemaking adjustment should be adopted for a tax effect that is not expected to occur.
16. Should an adverse tax effect occur a utility may propose the most efficient treatment at that time.
17. Southwest's proposal should not be adopted that the first $2,691,675 of the amount ultimately allocated for Southwest's core customers be retained by Southwest for the benefit of Southwest's shareholders.
18. Southwest's proposal should not be adopted that among all beneficiaries of the El Paso Settlement Southwest be paid first.
19. The proposal of Bower & French should not be adopted that Settlement consideration be immediately provided to ratepayers when the times for all appeals of the Superior Court's final approval order have expired whether or not appeals are pending of the Commission's order.
20. To prevent unnecessary or unreasonable delay, this order should be effective immediately so that (a) those reviewing the Settlement can now take the Commission's accounting and ratemaking treatment into consideration in making their decisions, and (b) benefits are expeditiously provided to California utility ratepayers.
IT IS ORDERED that:
1. The accounting and ratemaking treatment discussed in this order, and summarized in Attachment A, is adopted.
2. Within ten days of the date this order is mailed, respondent utilities Pacific Gas and Electric Company, Southern California Edison Company, San Diego Gas & Electric Company, Southern California Gas Company, and Southwest Gas Corporation shall file and serve an Advice letter or Advice letters, to propose refund plans and amendments to their tariffs as needed to implement the accounting and ratemaking treatment adopted herein. The Advice letter(s) shall be in compliance with General Order 96-A.
3. This proceeding is closed.
This order is effective today.
Dated ______________________, at San Francisco, California.
1. OVERVIEW
El Paso Settlement (Settlement) proceeds may be distributed through numerous transactions over a period of up to 20 years rather than in a single payment. As a result, we adopt a simple, direct, uniform and minimalist approach, and use existing accounting mechanisms, to the fullest extent possible. We decline to use complicated, indirect and controversial methods that will require the continued use of limited resources of parties, Commission staff and the Commission, and which may promote disputed outcomes for up to 2 decades.
We do this because the refund may be protracted, making it infeasible to track the exact customers and prior consumption during the 15-month period that led to the Settlement for the purpose of refunds that may last up to 20 years. Moreover, several customers who were directly harmed during the time in question (e.g., noncore, municipalities) will have the opportunity in the court's Settlement claims process to establish that harm and receive a fair share of the consideration. Also, the provisions of California Public Utilities (PU) Code § 453.5 are satisfied given the impracticability of tracking the customers harmed during the energy crisis over the next 15 to 20 years, the court's claims process, and the explicit authorization for the Commission under § 453.5 to authorize refunds based on current usage.19
Therefore, we adopt an accounting and ratemaking approach that is simple, direct and uniform; conserves limited resources; is consistent with the PU Code; and promotes an equitable and reasonable outcome.
2. CDWR REVENUE REQUIREMENT
The Commission has adopted a process for the recovery of the revenue requirement of the California Department of Water Resources (CDWR) for long-term energy contracts and other related costs.20 This process will continue to be used for distribution of El Paso Settlement consideration.
That is, to the extent CDWR receives consideration under the Settlement, CDWR will pass the benefit through to retail customers as an adjustment to CDWR's revenue requirement. This will automatically adjust retail rates, when presented by CDWR to the Commission for processing under established procedures, compared to what rates would otherwise have been. Allocation percentages between utilities are not fixed, but the percentages applicable to CDWR's revenue requirement at the time the consideration is passed through to retail customers by the Commission shall be applied. CDWR has already committed that all consideration received by CDWR "shall be used solely to reduce amounts which contribute to CDWR's revenue requirements." (Allocation Agreement, paragraph 4(c)(ii).)
3. ELECTRIC UTILITIES
3.1. ERRA for SCE and SDG&E
SCE: Southern California Edison Company (SCE) shall credit Settlement revenues to its Energy Resource Recovery Account (ERRA).
SDG&E: San Diego Gas and Electric Company (SDG&E) shall credit 70% of SDG&E's share of Settlement revenues attributed to SDG&E's electric customers to the Assembly Bill (AB) 265 subaccount of SDG&E's Transition Cost Balancing Account (TCBA), and 30% to the large customer subaccount of the ERRA (ABX1 43). Upon payment in full of the undercollection in SDG&E's AB 265 subaccount, the balance of all Settlement revenues shall be applied to SDG&E's ERRA.
3.2. PG&E
Pacific Gas and Electric Company (PG&E) shall place the Settlement consideration attributed to PG&E's electric customers into an interest bearing memorandum account. The balance in the memorandum account shall be used to pay previously unrecovered costs to the extent ultimately borne by ratepayers as determined by the Commission in either the Commission's bankruptcy proceeding (I.02-04-026) or the rate stabilization proceeding (A.00-11-038 et al.) The remaining balance, if any, in the memorandum account (e.g., if Settlement consideration is paid over 20 years) shall be returned to ratepayers through a credit to an authorized balancing account, or other account, in effect at the time. As a result, PG&E ratepayers shall ultimately be responsible for less costs than they otherwise would have been, and ratepayer rates shall be less than they otherwise would have been, absent the full amount of the Settlement consideration payable to PG&E.
3.3. DA Customers
SCE and SDG&E: El Paso Settlement proceeds shall be allocated, when paid pursuant to the Settlement, to full service and Direct Access (DA) customers based on the relative percentage of full-service and DA usage to total kWh system deliveries in the preceding 12 months prior to the first receipt of consideration under the Master Settlement Agreement (MSA). The allocated amount shall be entered into the Direct Access Cost Responsibility Surcharge (DA CRS) Tracking Account for SCE, and the DA CRS Memorandum Account for SDG&E.
PG&E: El Paso Settlement proceeds shall be placed in an interest bearing memorandum account for the future benefit of PG&E's ratepayers. The benefits shall be distributed in connection with the Commission's determination of the extent to which the full-service and DA customers shall pay PG&E's previously unrecovered costs pursuant to the two matters discussed above (i.e., bankruptcy and rate stabilization proceedings), and consistent with the method there adopted for present and future reduction of costs or rates compared to what they otherwise would have been.
4. NATURAL GAS UTILITIES
4.1. PGA
PG&E, SDG&E, Southern California Gas Company (SoCalGas): El Paso Settlement consideration attributable to core gas customers shall be credited to each utility's purchased gas account (PGA). The first payment under the MSA recorded to the PGA shall be net of up-front payments for some few customers (e.g., core-elect, core-subscription, core aggregation, PG&E limited wholesale transportation).
Southwest Gas Corporation (Southwest): El Paso Settlement consideration allocated to core gas customers shall first be credited to the core fixed cost adjustment mechanism (CFCAM). Once the CFCAM balance is zero, the consideration shall be applied to the PGA. The first payment under the MSA recorded to the CFCAM (or PGA if the CFCAM balance is zero) shall be net of up-front payments for some few customers (e.g., core-elect, core-subscription, core aggregation).
4.2. Core-Elect and Core-Subscription Customers
To the extent that core-elect and core-subscription customers are eligible to submit claims in the Superior Court's claims process for noncore customers, they are entitled to submit such claims pursuant to the Court's process. As such, they shall not receive a duplicative share of the California natural gas utilities' consideration under the Settlement for the March 1, 2000 through May 31, 2001 period for which they were not purchasing gas from the core portfolio. To the extent core-elect and core-subscription customers were purchasing gas from utilities' core portfolio, they are eligible for a portion of the El Paso consideration through their gas utility using the Commission-adopted process.
The process is that each gas utility shall submit an Advice Letter with a proposed refund plan for the affected core-elect and core-subscription customers. The refund plan shall be a pro rata share of El Paso Settlement consideration to noncore customers who are currently not core-subscription customers but who were core-elect or core-subscription for some part or all of the 15-month period from March 1, 2000 through May 31,2001. The refund (or credit) shall be based on the customer's purchases from the utility's core portfolios (in therms) during the period at issue, as reflected on their bills. The refund (or credit) shall be allocated to a fractional cent per therm for all throughput, using the same refund rate treatment adopted below for core aggregation customers. The refund plan shall be based on paying the net present value of the refund (or credit) over a period of no more than 12 months.21 Utility refunds (or credits) shall be booked to the PGA (or CFCAM for Southwest) as an expense. Once the refund is complete, any remaining balance shall be transferred to the PGA (or CFCAM for Southwest).
4.3. Core Aggregation
Each gas utility which has core aggregators transporting natural gas on the utilities' facilities shall book the proportional share of the Settlement consideration attributable to core aggregation customers in a new memorandum account called the El Paso Settlement Memorandum Account (EPSMA). At the next appropriate ratemaking proceeding, the memorandum account balance shall be used to partially offset the utility's allocated revenue requirement recoverable in the authorized tariff rate for the core aggregation transportation charge.
Core aggregation customers shall receive a proportional share of the California natural gas utility's Settlement consideration based upon their class' share of the utility's total system natural gas throughput, excluding noncore volumes, for the 12 months immediately prior to the time that the utility first receives the consideration. The Settlement consideration shall be allocated to a fractional-cent per therm for all deliveries, excluding noncore, to all customers served by respondents with the core aggregators' share recorded in the EPSMA until it can be credited against the core aggregation transportation charge.
The amount allocated to core aggregation customers shall be set aside from the initial (up front cash) payments by El Paso of Settlement consideration, so that future deferred payments can be allocated 100% to core procurement customers. The refund (or credit) to core aggregation customers shall be paid within 12 months so that in approximately 12 months the transportation rates paid by core aggregation and core procurement customers is equal, or nearly equal. The amount allocated to core aggregation customers shall be calculated based on a net present value of the otherwise forecast future payment stream. 22
4.4. PG&E Wholesale Transportation Customers
The six customers served on PG&E Schedule G-WSL shall be treated in the same manner as adopted for core aggregation customers. They shall receive a proportional share of PG&E's core settlement consideration based upon the wholesale customer class share of PG&E's total system natural gas throughput, excluding noncore volumes, for the 12 months immediately prior to the time that PG&E first receives the consideration. The allocation to wholesale customers shall be taken from the initial (up front cash) payments allocated to core procurement and core subscription customers (so that future deferred payments will be allocated 100% to core customers). The wholesale share of the settlement shall be booked to a subaccount of the EPSMA until the appropriate ratemaking proceeding (i.e., BCAP or annual true-up) where the memorandum account balance shall be used to partially offset PG&E's allocated revenue requirement for the wholesale transportation charge. Consistent with the adopted treatment of the core aggregation consideration, the amount allocated to these six wholesale customers shall be calculated based on a net present value.23
5. INCENTIVE MECHANISMS
The determination of an incentive, if any, under a Commission-adopted utility incentive mechanism shall be calculated as if Settlement payments had not occurred. That is, all El Paso consideration shall be treated in a manner to be neutral with respect to utility incentive mechanisms.24
6. INCOME TAXES
El Paso Settlement consideration shall be treated through balancing and other accounts described herein in a manner to have no tax effect on any respondent utility. Rather, El Paso Settlement consideration will offset and pay for costs already otherwise incurred (or in PG&E's case, will offset previously unrecovered costs). Revenues shall equal expenses, and there shall be no resulting tax liability.
Nevertheless, if a utility is taxed for El Paso Settlement consideration and actual tax payments are required by the Internal Revenue Service or other governmental taxing authority, a utility may at that time propose (a) adjustment of the consideration such that only the net revenues are credited to ratepayers, (b) allowing cost recovery of any tax liability in the next appropriate ratemaking proceeding, or (c) authority to create a memorandum account to track adverse tax implications until addressed in a ratemaking proceeding.
7. ADVICE LETTERS
Each respondent electric and gas utility shall file an advice letter, or advice letters. The advice letter(s) shall amend the utility's tariffs as necessary to add specific provisions for treatment of the El Paso Settlement consideration as directed herein.
(END OF ATTACHMENT A)
ATTACHMENT B
PARTIES AND ACRONYMS
LINE NO |
ACRONYM |
PARTY OR ENTITY |
1 |
A. |
Application |
2 |
AG |
Attorney General |
3 |
AL |
Advice Letter |
4 |
Bower & French |
William P. Bower and Thomas L. French |
5 |
CDWR |
California Department of Water Resources |
6 |
CEOB |
California Electricity Oversight Board |
7 |
CFCAM |
Core Fixed Cost Adjustment Mechanism |
7 |
D. |
Decision |
8 |
DA |
Direct Access |
9 |
DA CRS |
Direct Access Cost Responsibility Surcharge |
10 |
El Paso |
El Paso Natural Gas Company, its parent corporation and its affiliates |
11 |
Electric Classes |
Representatives of certain classes of electric utility ratepayers |
12 |
EPSMA |
El Paso Settlement Memorandum Account |
12 |
ERRA |
Energy Resource Recovery Account |
13 |
FERC |
Federal Energy Regulatory Commission |
14 |
MSA |
Master Settlement Agreement |
15 |
PG&E |
Pacific Gas and Electric Company |
16 |
PGA |
Purchased Gas Account |
17 |
SCE |
Southern California Edison Company |
18 |
SDG&E |
San Diego Gas and Electric Company |
19 |
SoCalGas |
Southern California Gas Company |
20 |
Southwest |
Southwest Gas Corporation |
21 |
SPURR/ABAG POWER |
School Project for Utility Rate Reduction and the Association of Bay Area Governments Publicly Owned Energy Resources |
22 |
TCBA |
Transition Cost Balancing Account |
23 |
TURN |
The Utility Reform Network |
