7. ORA's Testimony

On July 21, 1999, ORA served its report on the application (Exhibit 4). ORA's report challenged PG&E's showing with regard to gas transmission costs, call center expenses, the Northridge earthquake, PG&E's allocations of insurance proceeds from the 1997 New Year's Flood, the level of PG&E's insurance deductibles, whether there should be a minimum threshold amount before the CEMA mechanism applies, forecasted costs, and whether there should be a limitation on the length of time interest accrues on the CEMA balance. ORA's revenue requirement calculation, not including correction of the PG&E revenue requirement modeling error, was $67 million. (Exhibit 4, p. 1-7.)