4. TURN's Response

TURN supports the Petition. However, in order to allow for a more orderly and efficient processing of A.09-02-022, TURN suggests that it would be most effective to change the timetable for rate implementation and to bifurcate the issues in A.09-02-022 via the Scoping Memo to be issued in that proceeding.

Also, TURN states that it is pointless to spend time reviewing the reasonableness of costs if PG&E spends the money and can claim that such expenditures are necessary to meet the compliance schedule. If this were to be the basis for approval, TURN requests that the May 1, 2010 CPP implementation date for large customers be moved far enough ahead (perhaps one year) so that a decision on implementation costs can be issued in advance of PG&E's spending the money.

As an alternative to such a delay, TURN states that the Commission could adopt DRA's proposal, made at the April 22, 2009 prehearing conference in A.09-02-022, to allocate the implementation costs between Phases 1 and 2. TURN reasons that such a procedural change would allow parties to evaluate at least a portion of the information technology (IT) costs, if the Commission accepts the recommendation to delay only the February 2011 implementation date.