4. ORA Recommendations

In its Report on Reasonableness Review, ORA stated:

"Because this is the first reasonableness review of a utility's procurement activities since the utilities returned to procurement activities on January 1, 2003, ORA is still engaging in the process of developing the most efficient and effective method for reviewing the utility contract administration and least cost dispatch. ORA anticipates this process will improve over time by, most importantly, requiring the utilities to provide procurement data in formats more accessible to ORA. Improved accessibility is critical because ORA has found this review process to be tedious and inefficient." (ORA Report, p.1-2)

Accordingly, ORA requested the Commission require SCE to provide certain specified information in future ERRA filings.

ORA identified and discussed differences with SCE related to the scope of least-cost dispatch review. As opposed to SCE's assertion that least cost dispatch is a compliance matter, ORA contends that least cost dispatch should be subject to reasonableness review. In its report, ORA identified three specific concerns related to least cost dispatch and contract administration and recommended that SCE provide further explanation during this proceeding. ORA also recommended that SCE be required to file advice letters regarding two exchange agreement amendments.

ORA recommended disallowances related to qualifying facility (QF) contract administration as well as certain audit adjustments, totaling approximately $36 million.