3. DRA's Requested Adjustment for SONGS Outages

DRA reviewed SDG&E's Utility Retained Generation (URG) operations and fuel procurement activities from January 1, 2009 to December 31, 2009. DRA also reviewed generation outage information, including the underlying factors for certain outages, and SDG&E's internal audit program for its URG facilities. DRA found that, except for two outages at the SONGS, SDG&E's fuel procurement activities as well as its audit program for its URG facilities were not unreasonable. Based on its review, DRA recommended that the Commission disallow $950,000, which it estimates is the total replacement energy cost of what it considers two unreasonable outages at the SONGS. As discussed in her ruling dated December 23, 2010, the assigned ALJ bifurcated the current proceeding in order to address this one issue regarding outages at SONGS in Phase 2 of the current proceeding.