11. Master Data Request

In its testimony, ORA presented a list of additional information that SCE should provide in future filings, which would, in ORA's view, facilitate subsequent reviews. In rebuttal, SCE agreed to provide some of the requested information but objected to many of the items as being irrelevant, unclear, or overly broad. ORA then indicated its interest in working with SCE to refine the type of information requested and has proposed a master data request procedure.

ORA now requests that the Commission, first, direct SCE and ORA to develop a workable list of additional information for SCE to provide ORA in future ERRA review filings; second, require SCE and ORA to formally memorialize this additional information in a master data request; and third, require SCE to include responses to this master data request in the next ERRA review application. In its reply brief, SCE indicates that it is willing to work with ORA to define the information that it should provide in these proceedings, and is also willing to explore ORA's suggestion of a master data request.

We agree that, rather than specifying, in this decision, the information that SCE should include in its next ERRA filing, it would be more appropriate for ORA to request the needed information in a data request process that is more in time with the application itself. As the ERRA process is being refined, data request questions can consider the most recent experience and decisions that might impact the scope of investigation.

The master data request has been used successfully in the past18 and is an efficient tool that allows ORA to more quickly focus on issues and frame the scope of its review and analysis. Discovery disputes can be resolved in a timelier manner, which could prevent discovery related delays in the procedural schedule.

ORA and SCE should work together to establish a master data request process for SCE's ERRA reasonableness proceeding to be filed in 2005, including an agreement on the questions to be asked and the information to be provided. ORA should then provide the master data request no later than two months prior to SCE's anticipated application filing date. SCE should respond to the master data request by either including the information in its testimony/workpapers or providing a separate data request response, at the time of the application filing. The decision in the 2005 proceeding can then establish master data request procedures for future SCE ERRA filings, based on experience in that, as well as other, utility ERRA proceedings.

18 For instance, in the energy utility rate case plan and offset plans adopted by D.89-01-040, a master data request process was included for Energy Clause Adjustment Cost (ECAC) filings, which were similar in nature to ERRA filings.

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