PG&E states that it will fully amortize the Pipeline Assets and Pump Station Assets by the end of 2005, in accordance with D.97-11-074 issued during the deregulation of California's electric industry. Because ratepayers bore the cost recovery burden resulting from the accelerated amortization of these assets, PG&E concludes there is no basis for allocating any of the gain on sale to shareholders. The Office of Ratepayer Advocates (ORA) agrees with PG&E's proposal to allocate to ratepayers the entire gain on sale through a credit to the depreciation reserve.14 Accordingly, we will allocate the entire gain on sale to ratepayers. However, today's decision is based on the specific facts of this case and should not be viewed as setting a precedent for the future treatment of gain on sale that is being considered in Order Instituting Rulemaking (R.) 04-09-003.
14 Reflects PG&E's July 11, 2005, comments on the draft decision, and ORA's Jul 18, 2005, reply comments .