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. SDG&E, ORA, Duke Energy North America, and West Coast Power filed comments supporting adoption of the proposed decision without modification.

California Farm Bureau Federation filed comments supporting the decision, but also pointing out that the settling parties had included a rate floor to promote a gradual movement toward cost-based distribution rates, and not because cost-justified rate decreases are unreasonable. That was our understanding as well. We have retained our discussion and our finding that uncapped EPMC allocations would in this instance lead to unreasonable decreases for some customer classes because the wording is clear that it is the circumstances of this proceeding, rather than any belief that EPMC-based rate decreases are in general unreasonable, that lead us to that conclusion.

FEA filed comments rearguing its position and continuing to urge the Commission to reject the settlement's proposed capping.

There were no replies to comments.

After consideration of the parties' comments, we have made only minor, non-substantive changes to the proposed decision.