VI. Verification and Reporting

Greenlining/LIF propose that the Commission conduct an audit to ensure that each utility's WMDVBE verification and reporting process is accurate and reliable. Petitioners also propose that the Commission require the utilities to standardize their WMDVBE reporting and verification.⁶ Greenlining/LIF do not make these proposals in the form of a rule change, but rather, request that they occur in the Commission's administration of the WMDVBE program.

Sections 9 and 10 of GO 156 address the necessary elements of a utility's annual WMDVBE report and plan. Over the course of the administration of the WMDVBE program, Commission staff has sought to refine its data gathering methodology in order to standardize utility reporting. As a result, the format of the annual reports has continued to evolve. For example, in D.91-02-015, 39 CPUC2d 271, 276, and Exhibit A to that decision, the Commission adopted a WMDVBE program expenses cost itemization format. In D.95-12-045, 63 CPUC2d 203, 214 and Attachment A to that decision, the Commission required a common reporting requirement. However, utilities still present other information in a nonstandardized fashion. For example, utilities have their own breakdown of major categories of products and services which makes it difficult to compare utility data or to fully standardize reports.

Therefore, in order to facilitate greater standardization in the reports, this rulemaking proposes amending GO 156 to require that the utilities report their WMDVBE product and services expenditures according to the uniform system of accounts (USOA) applicable for each utility. (For example, electric utilities would report their information according to the Federal Energy Regulatory Commission's USOA applicable to electric utilities; similarly, gas utilities would use FERC's USOA for gas utilities and telephone utilities would report its information consistent with the Federal Communication Commission's USOA.)

We also propose to require the utilities to retain their workpapers associated with their WMDVBE annual reports and to provide these workpapers to the Commission upon request.

Finally, we require the respondent utilities subject to GO 156 to include the following information in their report filed and served in this rulemaking.

· Identify by verification order number each vendor that received payment for contract service for the reporting year 2002.

· Identify the company name, a brief description of service provided, and the dollar amount paid to the vendor for the reporting year 2002.

· Utilities which report fuel purchases separately under GO 156, §9.1.10 must also report this information by verification order number, company name, description and dollar amount.

· Explain the basis for any discrepancies in the total dollar amounts reported in the utility's annual report vs. this request.

The utilities may meet and confer with Commission staff regarding the appropriate reporting format for the above information.