Protests and Need for Supplemental Information

The Utility Reform Network (TURN) and the Commission's Office of Ratepayer Advocates (ORA) protested Sierra's application. Neither protest offers much detail on the protestants' concerns. Therefore, this ruling directs both TURN and ORA to add additional detail about the nature of their concerns in their PHC statements.

TURN shall address the following issues (in addition to the other issues raised in this ruling) in its PHC statement:

1. TURN states that "Sierra's unbundling study requires review to assure that it is consistent with the much more detailed review of unbundling undertaken in Nevada and recently adopted in the Decisions in Nevada PUC docket 99-4001."

a. Who will perform this review?

b. Why are the Nevada decisions relevant here?

c. What inconsistencies exist between Sierra's unbundling study and the Nevada Decisions?

2. TURN states that "costs unbundled to marketing, determined to be competitive, and excluded from the distribution rate in Nevada should simply be removed from Sierra's distribution revenue requirement." Why?

3. TURN lists several instances in which Sierra's allocation of costs to customer classes is allegedly inconsistent with precedent of the larger California utilities in many respects.

a. Why should precedent of the larger utilities bind Sierra?

b. Give case citations to precedent with which Sierra's proposals are inconsistent.

c. What other inconsistencies exist?

4. TURN states that the Commission will need to review Sierra's residential rate design to assure that it comports with the baseline statutes.

a. How is Sierra's design inconsistent with statute?

b. What changes does TURN propose to remove this inconsistency?

5. TURN states that the applicability of baseline rates to second homes should be investigated in light of Commission precedent. TURN should give case citations.

6. TURN states that it opposes Sierra's proposal, adopted in Nevada, to charge for 100% of the cost of residential and small commercial distribution service through a customer charge. TURN should detail its concerns.

ORA's protest addresses only the scheduling of this proceeding. I agree that it will not be feasible to complete this proceeding in six months, and am inclined to adopt something similar to ORA's one-year schedule. ORA also states that it has "found problems with Sierra's Application." ORA shall detail those problems in its PHC statement.