We resolved the term of post-test year ratemaking in Phase 1, when we directed SoCalGas and SDG&E to file a Notice of Intent for an application with a Test Year 2008. SoCalGas and SDG&E propose that the term should be through 2008 with a Test Year 2009.58 ORA agrees with a possible extension beyond 2008.59 TURN proposes a Test Year 2006 with no adjustment in 2005.60 Aglet proposes a 2008 Test Year with the adopted post-year ratemaking running through 2007.61

Nothing in this phase of the proceeding has assuaged our concerns that the underlying base margin in Phase 1 for Test Year 2004 is not sufficiently robust to be an appropriate base for five years' of rates (2004 through 2008). Nothing in the post-test year ratemaking process can improve on the 2004 foundation to make it a reasonable component of rates for five years. The adjustments we make in the post-test years are at best broad-stroke approximations designed to prevent a major disconnect to the actual cost of service and the operating conditions faced by SoCalGas and SDG&E between major rate cases.

58 Ex. 151, JVL-2.

59 Ex. 333, p. 1-6.

60 Ex. 561, p.2.

61 Ex. 800, p.2.

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