III. DUE PROCESS

PG&E contends that the process we used to issue the D.01-10-067 violated its due process rights. Again, PG&E fails to specify any legal basis for its contention. Rather, PG&E claims generally that its due process rights were violated because: (1) PG&E's proposals were singled out for early resolution; (2) the schedule for resolving these issues was altered; and (3) the Commission failed to base its decision on the evidentiary record in the proceeding. None of these allegations demonstrate a violation of PG&E's due process rights.

PG&E's proposal on market valuation was a unique proposal in the URG proceeding, and presented threshold issues that we found convenient to address in advance of resolving the remaining issues concerning prospective URG revenue requirements. (See Assigned Commissioner Ruling (ACR), August 10, 2001.) PG&E itself had motioned for early resolution of issues related to market valuation and undercollections. (See ALJ Ruling, July 18, 2001.) Clearly, it was reasonable to resolve these issues on an expedited basis, and it was within our discretion to do so. PG&E fails to demonstrate any due process violation in the early resolution of certain PG&E proposals.

Similarly, due process does not require us to keep to an inalterable schedule, or to refer to the evidentiary record for legal conclusions. Indeed, PG&E cites no such legal requirements. All significant holdings in D.01-10-067 are legal conclusions, and, in fact, the August 10, 2001 ACR specifically asked for briefs on the "legal question of market valuation." Since the Decision resolves legal issues there was no need for reference to the evidentiary record. In addition, PG&E cannot point to any due process requirement that prohibits us from changing procedural schedules.