DISCUSSION

Revenue Sharing

The SoCalGas PBR Mechanism includes a revenue sharing component which allocates recorded net operating income (NOI) between the utility's shareholders and ratepayers. Recorded NOI associated with the ROR above authorized levels is allocated according to a set of tiers. As the actual ROR increases, SoCalGas' shareholders are allocated increasing portions of the "excess" earnings. Shareholders are at risk for all recorded NOI associated with ROR below the authorized amount.

In D.96-11-060, the Commission authorized an ROR for SoCalGas of 9.49%. That ROR was still in effect in 1999. For 1999, SoCalGas recorded a 10.13% ROR adjusted to base rates which is 64 basis points above the authorized ROR of 9.49%.

The Energy Division has reviewed SoCalGas' revenue sharing calculations, and concurs that the calculations were made correctly.

In response to an Energy Division data request, SoCalGas indicated the main reasons it was able to exceed its authorized ROR were as follows: First, its net operating revenues increased relative to the amounts adopted in D.97-07-054.¹

This has largely occurred due to the annual PBR indexing of base margin and to higher than forecasted noncore revenues. Second, as anticipated in D.97-07-054, SoCalGas' rate base has declined. Third, taxes other than income taxes have declined due to a decline in payroll and property taxes. These three changes more than offset increases in depreciation, operation and maintenance, and income tax expenses.

1999 Customer Count Adjustment

In its annual advice letter, SoCalGas reports the actual number of customers served by the Company in the previous calendar year. SoCalGas' PBR indexing formula, the formula used to annually update SoCalGas' revenue requirements for inflation, productivity, and Z-factors, is applied to the revenue requirement per customer. That figure is then multiplied by an estimate of the number of customers in the upcoming calendar year to calculate the authorized revenue requirement for the upcoming year. An adjustment is later made to authorized revenue requirements to account for the actual number of customers served during the year. AL 2938-A reports that the actual number of customers served during 1999 were 4,937,811, an increase of 12,583 customers over the forecast of 4,925,228. An increase of $3.4 million to authorized revenue requirements will be made later to account for the difference.

The Energy Division concurs with the 1999 customer count adjustment amount. We believe that this amount should be adopted.

Allowance for Mobilehome Master Meter Conversions

Existing law allows master-meter customers to recover the costs of operating its submeter system at a cost to the users of the gas service that is no greater than if the service was furnished directly through individual meters. In 1996, AB 622 (stats. 1996, Ch. 424) was enacted and permitted the transfer of ownership and operational responsibility for gas service from an owner of a master-metered mobilehome park to gas corporations providing service in the area.

SoCalGas Preliminary Statement, Part XI.D4 states the following:

"In determining customer growth there will be a status quo on any reconfiguration of meter installations, e.g. where one meter is converted to three individual meters, the meter count will remain at one and correspondingly where three individual meters are combined into one meter, the meter count will remain at three."

"In addition, any conversion of mobilehome master meter units into individually metered units as a result of the utility taking over mobilehome park facilities as required by AB 622, will result in a base margin per customer allowance based on the authorized effective avoided cost for submetered credit and not based on the average base margin per customer."

In 1999, the SoCalGas takeover of mobilehome park metering facilities resulted in a net increase of 353 new individual meters. In compliance with SoCalGas' Preliminary Statement, this net increase in mobilehome park meters was excluded from 1999's actual meter growth for the annual PBR customer count true-up described above. However, this increase in mobilehome park meters results in an additional base margin customer allowance based on the authorized per month ($172.44 per year per meter) for which SoCalGas is requesting an increase in base margin of $60,871.

The Energy Division agrees with the calculation set forth by SoCalGas.

Service Quality and Customer Satisfaction

SoCalGas' customer satisfaction performance targets have been established for the following service attributes: 1) customer satisfaction with the customer Service Representative, 2) customer satisfaction with the scheduling of the appointment of a field service call, 3) satisfaction with the field Appliance Service Representative, and 4) the percentage of on-time arrivals for the service call. The annual targets are based on average performance for 1994 through 1996 for each of these attributes. Performance results are gathered from customer responses to customer satisfaction telephone surveys. A small deadband below the target

is allowed, but if SoCalGas performance falls below the deadband, a penalty is assessed. No reward is provided for performance which exceeds the target.

For 1999, SoCalGas reported that its performance exceeded the target in all four areas.

No penalty will be assessed for SoCalGas 1999 customer satisfaction performance.

Telephone Response Time

SoCalGas' telephone response time performance standard required 80 per cent of all telephone calls to be answered within 60 seconds for regular calls, and requires 90 per cent of all leak and emergency calls to be answered within twenty seconds. SoCalGas will be assessed a $20,000 penalty for each 0.1 percentage point decline in performance below each standard, with no deadband.

In 1999, SoCalGas reported an 84.7 telephone response rate within 60 seconds for regular calls and a 92.5 per cent response rate within 20 seconds for emergency calls.

No penalty will be assessed for SoCalGas' 1999 telephone response rate performance.

Employee Safety

The employee safety performance component is based upon the utility's performance in the frequency of certain injuries and illnesses reported to the Federal Occupational Safety and Health Administration (OSHA). The employee safety benchmark is set at a frequency of 9.3 incidents per 200,000 hours worked, with a deadband of 1.0 points in each direction. Penalties will be paid by SoCalGas if its incident rate exceeds 10.3, and rewards will be paid if the rate falls below 8.3. Penalties and rewards are assessed at $20,000 per 0.1 points outside the deadband.

For 1999, SoCalGas reports that it experienced an incident frequency rate of 6.9 which results in a reward of $280,000.

The Energy Division has reviewed SoCalGas' employee safety performance reward calculations and concurs that they were made correctly.

We believe that SoCalGas' calculated reward of $280,000 should be adopted.

Core Pricing Flexibility Adjustment

D. 97-07-054 and D.98-01-040 authorized a core pricing flexibility program for SoCalGas. Under this program, SoCalGas may offer optional tariff rates or negotiate discounted rates with new or existing core customers for the purpose of load growth or load retention. In order to ensure that ratepayers are isolated from any risk of revenue shortfall associated with discounted core rates or optional tariff offerings, SoCalGas established an adjustment mechanism to the CFCA, as required by the Commission. The CFCA adjustment mechanism is basically designed to protect core customers by calculating those revenues which represent base revenues that would have been credited to the CFCA absent any optional tariffs or negotiated rates. In AL 2938-A, SoCalGas calculated that the net revenues and CFCA adjustment for 1999 is $305,690.

Ratepayers and shareholders will share the net revenues from this program, since the net revenue gain increases net operating income.

Employee Stock Options Adjustment

D.97-07-054 authorized recovery of expenses associated with stock options (including dividend equivalents associated with stock options) for certain SoCalGas and parent company (currently Sempra Energy) employees who provide services to SoCalGas. Sempra Energy makes an accounting entry each quarter to recognize the net credit or net debit associated with stock options for these employees, and allocates that amount to SoCalGas. For this entry, Sempra Energy calculates three items: (1) a dividend equivalent expense (if applicable) accruing to the outstanding stock options; (2) a credit resulting from the forfeiture of options from option holders who have left the company without exercising their options; and (3) an adjustment to reflect the market value of the outstanding options "in the money" (ie with exercise prices less than the closing stock price at the end of each quarter). The accounting treatment of stock options can generate either a net credit or a net debit to operating income. This calculation produced a net debit in 1998, a net credit in 1999 and is expected to produce a net debit in 2000.

After filing AL 2938-A, SoCalGas discovered that the portion of the net expense associated with employee stock options held by parent company employees providing services for SoCalGas was not being allocated to SoCalGas. This would result in a net debit in 1998 and a net credit in 1999 resulting from including the allocable parent company portion of employee stock options expense to SoCalGas. While SoCalGas was in the process of calculating the final amounts, two additional errors were discovered. First, SoCalGas' reported 1998 net operating income did not include the portion of employee stock option expenses for SoCalGas employees for 4^th quarter 1998. Second, a calculation error overstated the portion of the net 1999 stock option credit attributable to SoCalGas employees. The changes would have resulted in a reduction in net operating income in 1998 and 1999. Since there were no shareable earnings in 1998 (per Resolution G-3270), a reduction in 1998 net operating income would not impact 1998 earnings sharing. However, in 1999 SoCalGas did have shareable earnings. The after-tax (and after franchise fees and uncollectibles gross-up) impact of incorporating the reduction to 1999 net operating income would be a $475,000 reduction in 1999 ratepayer earnings sharing to $7.714 million.

Utilities operating under a PBR mechanism typically include ratepayer revenue sharing amounts in rates on January 1^st. Due to the discovery of these accounting errors, the Commission action on AL 2938-A was delayed beyond January 1, 2000. However, by Commission approval of AL 2982, SoCalGas' end of year rate consolidation filing, the utility is currently amortizing in 2001 rates a 1999 ratepayer earnings sharing amount of $8.189 million as filed in AL2938-A. Therefore, SoCalGas is authorized to incorporate the necessary changes to the earnings sharing component of AL 2938-A into rates with the modification that the 1999 ratepayer earnings sharing reduction of $475,000 is to be recorded into a memorandum account for subtraction from any calculated ratepayer earnings sharing in 2000 or thereafter.

Effective Date

SoCalGas requests an effective date of October 25, 2000. This resolution and approval of AL 2938-A will be effective today.

1 1. In D97-07-054, the Commission adopted the SoCalGas PBR and authorized revenue requirements.