V. Comments on Proposed Decision

The proposed decision of the ALJ in this matter was mailed to the parties in accordance with Pub. Util. Code § 311(d) and Rule 77.1 of the Rules of Practice and Procedure.

ORA filed comments in support of the proposed decision. PG&E filed comments requesting that the proposed decision be modified regarding notice requirements and that balancing account treatment be granted for administrative costs triggered by new requirements in the proposed decision that were not contained in the common area settlement.

ECHO and Aglet filed reply comments. ECHO did not object to PG&E's proposed modifications. Aglet opposed PG&E's request for balancing account treatment of administrative costs and asked that Ordering Paragraph 6 state clearly that balancing account treatment is granted for only common area revenue, not cost, under-collections or over-collections.

The proposed decision did not specify how the right-of-transfer provision for new common area accounts should be implemented. We agree with PG&E that individual customer notification at the time of service initiation, with additional notice as part of the routine bill inserts that inform customers of their rate options, would provide adequate notice to new common area customers regarding the right-of-return provision.

We reject PG&E's proposal that it provide notice only through the routine bill inserts to those existing residential customers who are not known common area customers. All existing common area customers should be notified promptly and clearly of their rights under the settlement. Dissemination of this information as one item of many in a twice-yearly bill insert of all rate options would not provide adequate notice of the common area settlement. PG&E should send the common area bill insert specified in the settlement to all residential customers who do not receive the separate historical bill analyses sent to known large common area accounts.

We are not persuaded by PG&E's arguments regarding balancing account treatment of administrative costs. The adopted treatment of new common area accounts minimizes administrative costs. Further, our requirement that a common area bill insert be sent to all residential customers who do not receive the separate historical bill analyses mirrors the assumption of PG&E's witness and, thus, creates no new administrative costs. We clarify Ordering Paragraph 6 as Aglet requested.