8. Comments on Draft Decision
The draft decision of the ALJ in this matter was mailed to the parties in accordance with Section 311(g)(1) and Rule 77.7 of the Rules of Practice and Procedure. Comments on the draft decision were filed by PG&E, SCE, jointly by SDG&E/SoCal and by ORA. In addition, the utilities jointly filed corrections to the earnings, FF&U and interest amounts that were previously submitted.32 No reply comments were filed.
We have reviewed the comments, and make minor corrections and edits in response. In particular, we update the tables and estimates of earnings, FF&U and interest in response to the utilities' corrections to those numbers. We also append the E-tables to Attachment 2, which were inadvertently omitted. In addition, we clarify the discussion on ratemaking and the cost allocation of Energy Division verification activities, in response to comments, but do not make any substantive changes to our determinations on these issues.
In its comments, SCE urges us to forego an Energy Division audit of the PY2001 administrative costs booked in the ILPMA, arguing that its filed workpapers and testimony "should be more than sufficient for the Energy Division to meet the Commission's articulated review standard [footnote omitted], without the added time and expense of an audit. If upon further review, however, the Commission still wants more detail, SCE can make available to the Energy Division additional information on each of the relevant cost components that sets forth even greater detail than that already provided by SCE in its 2003 AEAP application." 33
We leave to Energy Division the responsibility of determining the scope of its audit, including the type of additional information it may require from the utilities to assess the reasonableness of amounts booked to the ILPMA account. However, we reject the notion that we should make a determination on this issue without an Energy Division audit. We note that the amounts in question are significant, particularly for SCE. Collectively, the utilities are requesting
recovery of approximately $10 million in administrative costs booked to ILPMA during PY2001 and PY2002. SCE's share of this amount is approximately $6.7 million--$2.7 million in this proceeding for PY2001, and $4 million in the 2003 AEAP for PY2002. 34 By D.01-07-029, the Commission specifically directed that a reasonableness review be conducted for the amounts booked to this account, and today's decision ensures that such a review will be undertaken. Accordingly, we affirm the draft decision's direction on this issue.
Except as noted above, we make no modifications to the draft decision.
32 See: Joint Filing of SDG&E, SoCal, PG&E and SCE Providing Revised Franchise Fee, Uncollectible and Interest and Amending Utility Earnings Claims, August 5, 2003 and ERRATA to that filing, also jointly filed on August 5, 2003. Also see: Comments of ORA on the Draft Interim Opinion, August 5, 2003; Comments of SCE on Judge Gottstein's Draft Interim Opinion, August 7, 2003 (SCE Comments); Comments of PG&E on Draft Decision of ALJ Meg Gottstein, August 6, 2003 and SDG&E and SoCal Comments on the Draft Decision, August 7, 2003. 33 SCE Comments, p. 4. 34 See March 19, 2003 ALJ Ruling in this proceeding and SCE's July 18, 2003 Prehearing Conference Statement in the 2003 AEAP (A.03-05-002 et al). Amounts that SCE and other utilities may request for PY2003 (if any) are not known at this time.
