Comments of Draft Decision

The draft decision of the Administrative Law Judge in this matter was mailed to the parties in accordance with Pub. Util. Code § 311(g)(1) and Rule 77.7 of the Rules of Practice and Procedure. Comments were filed on ______ and reply comments were filed on ________.

Findings of Fact

1. CACD found the utilities advice letter filings in compliance with Ordering Paragraph 7 and in compliance with the intent of the PBOP Decision.

2. The PBOP Decision authorized the use of the benefits/years-of-service approach if the utilities demonstrate to the CACD prior to January 1, 1993 that this approach results in a minimal increase in PBOP cost.

3. DRA was notified by CACD that GTEC was authorized to use the benefits/year-of-service attrition approach to recover its PBOP costs.

4. Pacific Bell used a 20-year amortization period for its prior PBOP accruals.

5. PBOP trusts and funding issues are applicable to the recovery of future year PBOP cost in each subsequent year's price cap filing.

6. The PBOP Decision found that the use of surplus pension assets was not a viable alternative source of funding PBOP cost.

7. GTEC's independent actuary found that GTEC's valuations and calculations were in conformance with generally accepted actuarial principles, appropriate for use in implementing PBOP cost recovery, and appropriate for determining the proper funding level for PBOP contributions.

8. GTEC's actuary certified that GTEC's methods and assumptions used in determining its PBOP costs were reasonable and in conformance to the requirements of the PBOP Decision.

Conclusion of Law

DRA's petitions for modification of Resolutions T-15160 and T-15161 should be summarily denied on the ground that the Commission is not persuaded to modify the resolutions.

ORDER

IT IS ORDERED that:

1. The petitions to modify Resolutions T-15160 and T-15161 filed by the Division of Ratepayer Advocates on January 4, 1993 are denied.

2. Application (A.) 93-01-003 and A.93-01-004 are closed.

This order is effective today.

Dated , at San Francisco, California.

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