Background

SCE filed its application for a test year 2009 GRC on November 19, 2007. The Commission's Rate Case Plan, Decision (D.) 89-01-040, as modified by D.07-07-004, imposes various substantive and procedural requirements for energy utility general rate cases, including a timeline for processing the filing. Based on SCE's application filing date and the Rate Case Plan schedule, a final decision on this matter would be issued by January 1, 2008. The Assigned Commissioner's Ruling and Scoping Memo, dated February 7, 2008, provided a schedule that anticipated a final decision before the end of December 2008. While various modifications to the schedule occurred, the anticipated end of year decision date did not change.

Recognizing that unforeseen events might delay the procedural schedule and preclude the Commission from issuing a final decision before December 31, 2008, SCE filed a motion on September 9, 2008, for authority to establish a GRC RRMA to track the change in the revenue requirement adopted in this GRC for the period of January 1, 2008 to the effective date of the final decision (the SCE Motion).

According to SCE, a memorandum account would protect both ratepayers and shareholders from adverse consequences resulting from procedural delays and allow sufficient time for the parties and decision makers to make any necessary corrections of errors or omissions in the calculation of the Results of Operations in any proposed decision. By its motion, SCE is not asking the Commission to prejudge the reasonableness of any balance recorded in the memorandum account.

Also, the Commission has consistently used the GRC applications of SCE to determine the authorized revenue requirement that SDG&E may charge its customers related to its share of SONGS costs billed by SCE (exclusive of fuel costs). SDG&E intervened in this proceeding and has actively participated because of that interest. Because of the potential that a delay in issuance of a decision in this proceeding could cause SDG&E to under-collect what the Commission eventually finds in this application is SDG&E's reasonable 2009 SONGS-related revenue requirement, SDG&E filed a motion on September 12, 2008, for authority to establish a memorandum account to track the change in the revenue requirement related to its interest in SONGS adopted in this GRC for the period of January 1, 2009, to the effective date of the final decision (the SDG&E Motion).

The Utility Reform Network (TURN) filed a response to the SCE Motion on September 24, 2008. TURN indicated it did not anticipate filing a separate response to the SDG&E Motion. TURN supports the granting of the Motion to establish a memorandum account, requesting that the removal of pressure for an end of year decision be utilized for developing the record in the proceeding further on the subject of the impacts of the recent disruptions in the domestic economy on the revenue requirement to be established. TURN's response included a request to take official notice of included data. SCE filed a Reply to TURN's Response on October 3, 2008 objecting to the request for official notice. TURN's request for record augmentation was separately addressed by Administrative Law Judge (ALJ) Ruling on October 6, 2008.

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