VII. Procedural Process and Schedule for Future Filings

A. Quarterly Compliance Filings

On September 10, 2003, PG&E and SDG&E filed a joint petition to modify D.02-10-062, specifically to extend the due date of the Quarterly Procurement Plan Compliance Reports from within 15 days of the end of the quarter to within 30 days of the end of the quarter. Both utilities state they need this additional time to prepare sufficiently detailed and comprehensive reports. Parties testified to the thousands of transactions that are included in the quarterly compliance filings. Therefore, we find PG&E's and SDG&E's joint petition reasonable and grant the relief sought, on a going forward basis, in this decision.

We also take this opportunity to address the procedural process under which we review these compliance filings. In D.02-12-074, in Section VI, we set a procedural process under which the Energy Division would review the quarterly compliance filings on an expedited basis, with a 30 day review period as a guideline, and then prepare a resolution with their findings and place it on the Commission's agenda. With the Commission's current staff resources, a full review of the filings cannot be done in these expedited timeframes. Rather, the Commission should look to streamlining its review by having the utilities provide an independent auditor's certification that all transactions were reviewed and verified to be in compliance with their adopted procurement plans. This procedure was discussed with SCE's witness Cini, who agreed that Energy Division, in consultation with the PRG, could select an outside auditor for this function. ¹¹⁸ Therefore, we find that the Energy Division should, in consultation with each utility and its PRG, select an outside auditor to review and verify the quarterly compliance filings, and the audit expenses should be paid by the utilities and recorded in a memorandum account. A resolution for the Commission's agenda should only be prepared if Energy Division or the outside auditor find transactions or procurement practices that are not in compliance with the adopted plans.

B. Long-term Procurement Plan Filings

SCE proposes that its long-term plan be reviewed on a three year cycle, in coordination with its general rate case. Specifically, SCE proposes that each utility would develop and submit a long-term integrated resource plan within 90 days of the final decision in its respective GRC, such plan to incorporate those issues resolved in the GRC. Further, SCE states that the Rate Case Plan (D.89-01-040, as modified) already contemplates submission of long-term resurce plans as part of the utility's GRC showing. No party objects to SCE's proposal.

We intend to review and adopt revised 2004 long-term procurement plans for the three utilities in our new Procurement OIR. Following that, a three year cycle of utility-specific long-term planning is reasonable, and, therefore, we adopt this proposal. In our decision on the revised 2004 plans, we should revisit the specific timing of each utility's next GRC filing and revise any long-term plan filing dates as necessary.

C. ERRA Filings

ORA and SCE recommend that the Commission annually update the short-term procurement plans in each utility's ERRA filing. In addition, PG&E, SCE, and SDG&E have all indicated in their ERRA filings that efficiencies could be made in the procedural process we adopted in D.02-10-062, especially with forecasts established closer in time to the applicable year, a combining of the forecast, reasonableness review, and ERRA true-up in one application for each utility, and the possibility of the ERRA trigger amount being handled by Advice Letter rather than application.

2004 ERRA Schedule
IOU	2004 ERRA AL Trigger /1	2004 ERRA Forecast /2	2003 Reasonableness Review	ERRA Over/Under Collection True-up /3
PG&E	April 1,2004	August 2003	August 2003	N/A
SCE	April 1, 2004	October 2003	October 2003	N/A
SDG&E	April 1, 2004	December 2003	December 2003	N/A

Footnotes:

1/ AL Trigger is based on 12-months (calendar) of prior year recorded data. The IOU's will refile AL if Reasonableness Review Decision modifies recorded data. Note: By April 1, 2004 the IOUs will have closed their books for 2003 and filed their SEC reports.

2/ ERRA Forecast application will be combined with the Short Term Procurement Plan application in 2005

3/ ERRA over/under collection true-up is independent of when IOUs file ERRA Forecast or Reasonableness Review applications - IOUs will file whenever there is an over/under collection.

2005 ERRA Schedule
IOU	2004 ERRA AL Trigger /1	2005 ERRA Forecast & Short Term Procurement Plan /2	2004 Reasonableness Review /3	ERRA Over/Under Collection True-up /4
PG&E	April 1,2005	June 1, 2004	February 2005	N/A
SCE	April 1, 2005	August 1, 2004	April 2005	N/A
SDG&E	April 1, 2005	October 1, 2004	June 2005	N/A

Footnotes:

1/ AL Trigger is based on 12-months (calendar) of prior year recorded data. The IOU's will refile AL if Reasonableness Review Decision modifies recorded data. Note: By April 1, 2005 the IOUs will have closed their books for 2004 and filed their SEC reports.

2/ ERRA Forecast application will be combined with the Short Term Procurement Plan application. Note: The dates have been changed so the IOUs file earlier in the year. This will allow IOU/PUC to have decisions out by the end of the year.

3/ 2004 Reasonableness Review period will incorporate 12 months of 2004 calendar year data.

4/ ERRA over/under collection true-up is independent of when IOUs file ERRA Forecast or Reasonableness Review applications - IOUs will file whenever there is an over/under collection.

For 2004, the utilities should only update the forecasts in their 2004 adopted short-term procurement plans, all other parts of their short-term procurement plans will be operational for 2005, unless modifications are ordered based on our review of revised 2004 long-term plans. Each utility should file its revised 2004 long-term procurement plan in the new Procurement OIR which we intend to open in the second quarter of 2004.