11. Conclusions

Like ORA, this Commission supports a streamlined process that can improve regulatory efficiency as well as reduce the burden on interested parties and on our staff. Nevertheless, improving regulatory efficiency should not undermine the Commission's regulatory authority or become an obstacle for the Commission in fulfilling its regulatory responsibilities. Thus, using as a framework the Commission's analysis of the Lease Agreement and the five proposed product order leases pursuant to § 851, we will follow ORA's recommendation and extend our approval to future product order leases via advice letter, but only in conjunction with certain substantive and procedural conditions that SCE and ORA have agreed will be followed. Those conditions are set forth in our order.

In addition to conditions that SCE should meet, ORA recommends that the Commission require that future audits of SCE pursuant to § 314.5 review SCE's actual cost allocation of its fiber network. Such an investigation is the appropriate regulatory mechanism by which the Commission can ensure that there is no cross-subsidization between ratepayers and shareholders, and that co-mingling of assets does not otherwise harm the public interest.

The conditions specified in our order reflect the concerns discussed by ORA and SCE. The conditions also identify information that SCE should submit for future product order leases to enable the Commission and its staff to assess the proposed product orders quickly in the context of how SCE's fiber is being used. The conditions fall into the following categories:

· Limitations on use of the advice letter process;

· Continuing obligations of SCE;

· Notifications to Commission staff;

· Information to be filed with advice letter; and

· Information to be submitted to Commission staff concurrently with advice letter.