7. Comments on Proposed Decision
The PD of the ALJ in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed on or before August 27, 2007. No reply comments were filed.
PG&E filed comments on behalf of the Settling Parties, and BOMA filed separate comments on the MM Settlement issue. The comments address MM Settlement conditions and request that the PD be adopted with certain minor modifications. Where appropriate, changes have been made to the PD.
Regarding implementation of rate changes, the PD specified an effective date on or after November 1, 2007. In comments, PG&E indicates that it will consolidate most Phase 2 changes with the Annual Electric True-Up (AET) for implementation on January 1, 2008.27 This approach both minimizes the number of electric rate changes and allows the Phase 2 rate change to take place in the context of more extensive changes to rates contemplated in the AET. Further, by timing its Phase 2 rate changes to coincide with the projected elimination of the Fixed Transition Amount on January 1, 2008, PG&E hopes to reduce the effect of the increased allocation of costs for residential and small commercial customers associated with the settlement agreements. PG&E's proposal is reasonable and consistent with the intent of the PD.
27 The Settling Parties recognize that certain initiatives require employee training and/or changes to PG&E systems beyond a normal change to a rate value; that such systems and program changes will be implemented by PG&E diligently as time permits and in a manner consistent with maintaining the secure, smooth operations of the systems involved; and that some initiatives could take several months to implement.
