III. Creation of Interim Balancing Account

Edison has requested modification of the PBR and proposes a balancing account and immediate implementation of revenue adjustments. ³ As justification for its request Edison cites newly enacted Public Utilities Code Section 739.10 and the MOU.

The NRDC supports Edison's proposed modification and states that the current PBR virtually ensures over or undercollections.

However, both TURN and ORA believe that any attempt to modify the existing PBR be done in a separate application in a more careful and comprehensive manner than that proposed by Edison. In particular, TURN urges the Commission to reject Edison's proposal to unilaterally modify the PBR mechanism and instead initiate an expedited process for the presentation, discussion and consideration of alternative interim ratemaking. By doing so, TURN argues, the Commission would be in a better position to determine the best method for compliance with Public Utilities Code Section 739.10. ORA also believes that an adjustment to the current PBR may be required, but because the current PBR contains a number of conditions and procedures that balance the interests of ratepayers and shareholders, any changes require careful consideration to ensure that the balance of interests is maintained.

ORA and TURN do not agree that the MOU is sufficient justification for modification or the PBR.