ACCOUNTING AND REPORTING REQUIREMENTS
Pursuant to D.03-03-007, Ordering Paragraph 13, the SMJU were ordered to attend a workshop to discuss accounting and reporting issues related to CARE and LIEE. Energy Division facilitated the workshop at the Commission's Headquarters on June 23, 2003 and submitted its workshop report on October 27, 2003. After reviewing the workshop report, the Commission, in an Assigned Commissioner's Ruling (ACR), dated December 3, 2003, under Rulemaking 01-08-027, deemed that further discussions on accounting and reporting standards with the SMJU were necessary and ordered that a second workshop be conducted.
The subsequent workshop was split into two meetings, held on February 23 and March 5, 2004. On April 5, 2004, Energy Division submitted its second workshop.29 This second report includes Energy Division's recommendations on accounting and reporting requirements for the SMJU's CARE and LIEE programs. The recommendations set forth in the second report supercede those expressed in the Energy Division's October 27, 2003rd workshop report, and were based on additional information provided by the SMJU at the workshop meetings. Comments on Energy Division's second report were due April 19, 2004, with replies due on April 26, 2004.
In the December 3, 2003rd ACR, Assigned Commissioner Wood clarified that the SMJU are to proceed under then current reporting and accounting requirements adopted by the Commission, until the Commission could consider Energy Division's recommendations in its second workshop report.
In the Scoping Memo of Assigned Commissioner and Administrative Law Judge (Scoping Memo), issued on June 24, 2004, in R.04-01-066, the Assigned Commissioner and Administrative Law Judge indicated that Energy Division's recommendations contained in Energy Division's August 5th report were approved and the SMJU shall begin providing the information required by that report beginning on August 1, 2004.30
In its 2004 Annual CARE Report, submitted on July 30, 2004, Southwest Gas indicated that the Scoping Memo did not contain any express language to change the ordering paragraphs of D.09-07-062, D.94-12-049 and D.95-10-047. Those decisions require the SMJU to submit an Annual CARE Progress Report, with a prescribed format, on August 1 of each year.
Energy Division does note in Energy Division's April 5th report, on page 4, that in lieu of the August 1st reports required pursuant to D.09-07-062, D.94-12-049 and D.95-10-047, the SMJU should provide an annual CARE/LIEE report on May 1 of each year on the previous calendar year, using the exact format described in Energy Division's report.31 In addition, Energy Division recommended that the SMJU also submit a mid-year status report every August 1st, that shows program accomplishments achieved from January through June of the current year and would be pursuant to the format specified in Energy Division's April 5th report.32
Finally, to implement the new reports without a gap in reporting, Energy Division requested that the SMJU file a report on August 1, 2004 covering the period May 1 through December 31, 2003, with the next report providing information for the program period January 1 through December 31, 2004.
Energy Division recommends that the Commission clarify that, in lieu providing the CARE Annual Reports submitted pursuant to D.09-07-062, D.94-12-049 and D.95-10-047, that the SMJU submit all the reports recommended in Energy Division's April 5th report and for those reports the SMJU shall use the format and tables attached to Energy Division' April 5th report.
Energy Division notes that many of the SMJU are delinquent in submitting currently required reports. Energy Division notes that on July 30, 2004, Southwest Gas submitted a CARE Annual Report with the reporting periods May 1, 2003 through April 30.
On July 30, 2004, the following utilities submitted the Annual Report on CARE and LIEE Program Status for the report period May 1, 2003 through December 31, 2003. Energy Division notes whether the reports were complete or incomplete: Avista (incomplete); PacifiCorp (complete): Sierra (incomplete); Southwest Gas (complete) and West Coast Gas (incomplete). On October 29, 2004, Bear Valley submitted a report on CARE only (Bear Valley did not have a LIEE program in 2003) (incomplete).
Energy Division believes there may have been some confusion regarding the reporting requirements. Energy Division recommends that the utilities who submitted incomplete reports or didn't submit a report be required to refile with the missing components so the Commission will have a complete record on 2003. In addition, Energy Division recommends that the Commission not tolerate any inconsistencies or incomplete reports this year.
Energy Division notes that the Annual Report on CARE and LIEE Program Status Report on PY 2004 is due May 1, 2004 and will be submitted shortly. Information in those reports should supercede the estimated information contained in this report.
29 Energy Division's second report was entitled "Final Energy Division Workshop Report On The Review Of Accounting And Reporting Requirements For The California Alternate Rate For Energy (CARE) And Low-Income Energy Efficiency (LIEE) Programs Of The Small And Multi-Jurisdictional Utilities (SMJU)."
30 See page 6 of the Scoping Memo.
31 See page 4, item number 5, of Energy Division's April 5,2005 report.
32 See page 5, item number 6of Energy Division's April 5, 2005 report.
