7. Comments on Draft Decision

On November 14, 2002, the draft decision of Presiding Officer and Assigned Commissioner Wood was served on parties in accordance with Pub. Util. Code § 311(g)(1), and Rule 77.7 of the Commission's Rules of Practice and Procedure. That draft decision denied the petition and closed the proceeding.

Comments were filed and served on December 3, 2002 by CIU. CIU urges the Commission to revise the Draft Decision and grant the CIU/CLECA petition. No reply comments were filed.

We carefully consider CIU's comments, and are persuaded to modify the draft decision. As CIU points out, CIU and CLECA represent a number of large industrial customers, including both interruptible and non-interruptible customers. Both groups joined in the petition. We may reasonably conclude that both groups made the decision to support continuation of the bill limiter in whole, and to collect any additional undercollections from other large industrial customers. No large non-interruptible customer opposed the petition. The California Manufacturers and Technology Association, which also includes large industrial members, did not oppose the petition.

Further, the petition does not propose indefinite continuation of the bill limiter. Rather, just as with the outcome in the Draft Decision, the bill limiter

component of Schedule I-6 will be re-evaluated in SCE's next GRC. This approach is consistent with prior Commission treatment to continue bill limiters here and elsewhere until further review.

Finally, SCE's proposed accounting treatment is not unreasonably complex, even if it adds another layer of complication to relatively complex accounting for ratemaking purposes. SCE would implement the additional accounting, and believes it is workable. It may be coordinated with the treatment required in Resolution E-3776 without being unduly burdensome.

Previous PageTop Of PageNext PageGo To First Page