TURN

TURN states there was clearly a potential for PG&E's shareholders to benefit at ratepayer expense, even though no such harm occurred. For example, if PG&E had actually acquired an ownership interest in the Ruby Pipeline, PG&E Corporation could have used its position as PG&E's parent company to drive a better deal for Ruby's owners at the expense of PG&E's ratepayers.

Even though PG&E Corporation did not invest in Ruby, TURN sees a continuing potential for harmful conflicts of interest under PG&E's corporate structure. Accordingly, TURN urges the Commission to consider, in a subsequent phase of this proceeding, changes to the Commission's affiliate rules, such as those proposed by Reid, to ensure that ratepayers are not adversely impacted in the future.