8. The MRTU Memorandum Account (MRTUMA)

The revenue requirements that PG&E proposes to recover as a part of this proceeding flow through the MRTUMA, approved in Resolution E-4093.

Among its many findings within Resolution E-4093, we stated:¹¹

· Market participants, including PG&E, are required to comply with the FERC-approved MRTU tariff as part of the FERC regulations and agreements with CAISO.

· CAISO has targeted MRTU Release 1 to be implemented by February 2008, and MRTU Release 2 in 2009 to address subsequent directives provided by FERC in adopting MRTU.

· The Commission supports CAISO's MRTU initiative.

· The Commission expects the investor-owned utilities (IOUs) to be fully prepared for MRTU and to have the resources necessary to be able to participate in the new market design, LMP, and a day-ahead market.

· Currently, there is a large uncertainty about the MRTU-related costs that the IOUs will incur.

· This Resolution does not prejudge or determine what costs the Commission will allow PG&E to recover in rates associated with complying and participating in CAISO's MRTU initiative.

· Cost recovery associated with the amounts recorded in PG&E's MRTU MA is subject to a future Commission order in PG&E's ERRA reasonableness proceedings or some other formal proceeding where reasonableness of amounts recorded in this account are reviewed.

· PG&E's proposal to establish an MRTUMA is justified in order to meet the objectives of CAISO's MRTU initiative.

Resolution E-4093 further provided that "PG&E should reduce its actual recorded MRTU expenditures by any previous Commission-authorized MRTU expenditures reflected in PG&E's rate levels to ensure that PG&E does not double-recover its MRTU expenditures."

¹¹ See Resolution E-4093, at 11-13.