4. DRA Protest

DRA expressed general concern over Suburban's relationship to its parent, Southwest, with respect to the allocation of costs between the two companies, and with the expenses and costs of the Utility Group. Specific issues identified in DRA's protest included: sales, customer service, rate design, revenue calculations, operations and maintenance expenses, administrative and general expenses, payroll expenses, plant costs, rate-base determination, water consumption, conservation, and numbers of customers.

DRA also identified other areas of concern, including: general objection to a Tier 3 Advice Letter process for Project Cornerstone being included in the scope of this proceeding; a recommendation that Suburban use a Domestic Production Activities Deduction (DPAD) for income tax reporting purposes (also a matter related to Southwest); and, opposition to the allocation of costs and revenues of Suburban's RHP.