4. Position of the Office of Ratepayer Advocates (ORA) and SoCalGas

A. ORA

ORA agrees with CSD. It also requests additional penalties for SoCalGas' violation of the decision and its disregard of CSD and Energy Division's interpretation of it. (Apparently, SoCalGas conferred with CSD and the Commission's Energy Division prior to mailing its notice to landowners, but the parties were unable to reach agreement on the issue presented in this petition.)

B. SoCalGas

SoCalGas opposes the petition. First, it points out that CSD has technically not followed the Commission's rules for requesting modification of a decision because CSD did not propose specific language to carry out its proposed modifications.⁵ On the merits, SoCalGas argues that the settlement provides for rescission of the mineral interests upon the prior owner's execution of a general release of SoCalGas, and that CSD cannot now modify this portion of the settlement. SoCalGas argues that, if the Commission intended to modify the settlement on this point as CSD suggests, the Commission would have specifically said so, as it did on several other items. SoCalGas also cites several federal cases regarding the grounds for relief from a final judgment, and argues that CSD has not met those grounds here.