SDG&E's Evidence

SDG&E's Regulatory Policy Manager testified that the billing period in dispute is January 23, 2001 through July 2, 2005.

SDG&E has billed and Farm ACW has not paid amounts that were billed from January 23, 2001 through July 2, 2005. This period can be broken down as follows:

January 22, 2001	Date of last meter read that showed any consumption.
July 23, 2001	Date on which SDG&E determined that Farm ACW was operating generation on-site to meet its load and the date on which SDG&E calculated revised bills including standby fees and departing load back to January 23, 2001.
August 3, 2001	Date on which SDG&E service to Farm ACW was de-energized by SDG&E.
July 3, 2005	Date that SDG&E re-energized the customer's primary metering station and re-established electrical service to Farm ACW.

The amount in dispute is $118,474.38.

The Regulatory Policy Manager testified that from January 23, 2001 through August 3, 2001, SDG&E's service remained connected and available to Farm ACW. Farm ACW had opened its service on its side of the service entrance point. On August 3, 2001, SDG&E de-energized service to Farm ACW at the cable pole serving Farm ACW's primary metering station. From August 3, 2001 through July 3, 2005 SDG&E's service remained available to Farm ACW pending their receipt of approvals from a County of San Diego electrical inspector and payment of the amounts in arrears. At no time was service unavailable, provided that Farm ACW obtained clearance from the inspector and brought its payments current.

SDG&E's expert engineering witness testified that actual recorded values, i.e., the actual measured inputs of fuel, and outputs of electricity and heat, over the course of a calendar year, not assumptions, must be used to determine whether a generator is a legitimate cogenerator pursuant to Section 218.5. He stated that estimates based on assumptions were not adequate for SDG&E to give an applicant cogenerator status. He said that when Ms. Firooz worked at SDG&E she did not do heat or efficiency calculations to determine cogenerator status. He said that not only was Ms. Kirooz unqualified to render an opinion on whether a cogenerator meets the standards of Section 218.5, but also, it was improper to base an opinion on assumptions.