Comments on Proposed Decision

The principal hearing officer's proposed decision was filed with the Commission and served on all parties in accordance with Section 311(d) of the Public Utilities Code and Rule 77.1 of the Rules of Practice and Procedure. ORA filed comments. CalAm filed only a reply opposing ORA's suggested changes and supporting the proposed decision as written. No other party filed comments or replies.

ORA's comments reargue its positions on regulatory commission expense, legal service expense, CWIP, ESA expenditures, cost of capital, and service quality. Rule 77.1 provides, "Comments shall focus on factual, legal or technical errors in the proposed decision.... Comments which merely reargue positions taken in briefs will be accorded no weight and are not to be filed." No changes have been made in those areas.

We have accepted ORA's suggestion to reiterate that "working cash" in the Depreciation Expense and Reserve, and Rate Base section refers to "operational working cash."

ORA alleges that there are errors on three pages of the Appendix B adopted tariff sheets. On page 1 of 18 ORA has misquoted the figures; they are correct as shown. On page 5 of 18, ORA believes it has detected a rate error of $0.0001 per 100 cubic feet in CalAm's favor, and on page 7 of 18 an error of $0.0002 per 100 cubic feet in the ratepayers' favor. CalAm disagrees with ORA's corrections. We have not changed the figures because ORA provides no explanation of why it believes these rates are in error, because the differences at issue are minuscule, and because even if the figures were wrong they would tend to offset one another.