2. Moving Issue to BCAP

The motion is granted for the following reasons. First, the Commission has recently determined that the submetering discount for mobile home parks "shall be determined in a general rate case, biennial cost allocation proceeding, or similar proceeding (revenue requirement proceeding) where the utility's revenue requirement is determined and rates are set." (Decision 04-11-033, Ordering Paragraph 2.) As part of the BCAP, the Commission will allocate gas revenue requirements and set gas rates. Any changes in the amount of the gas discount may affect the revenues needed to be recovered from other customers, and thereby potentially affect allocations and rates. Thus, while the gas discount might be determined in the rate design phase of PG&E's GRC, the discount is better determined in the gas-related BCAP because of the implications for cost allocation.

Second, the adopted BCAP schedule anticipates a decision by early summer 2005, while the decision in the rate design phase of the GRC is not now anticipated until about six months later. PG&E proposes an increase in the discount of about $0.95 per unit per month for master meter customers who submeter at mobile home parks. PG&E proposes an increase in the discount of about $2.61 per unit per month for master meter customers who submeter at multifamily facilities. If the Commission adopts an increase in the discount, addressing the issue in the GRC rather than the BCAP would deprive customers of lower bills for a period that might exceed six months.

Third, the rate design phase of PG&E's GRC involves electric, not gas, allocations and rates. ORA asserts that there is no "bright line rule" that forecloses the consideration of gas rates here. This is true. Nonetheless, there is a current BCAP proceeding that can accommodate this issue. No other gas-related matters are identified by opponents as now included in this rate design phase of the GRC. Moving this one gas-related issue to the BCAP keeps the focus in the BCAP on gas rates, and keeps the focus in the GRC on electric rates.

Fourth, opponents support keeping the issue in the GRC by contending that data adopted in the revenue requirement phase (Phase I) of PG&E's GRC is necessary for setting the discount. Even if true, the same data may be used in either the rate design phase (Phase II) of the GRC or the BCAP. Moreover, WMA asserts that a major component of the gas submeter discount relies on the costs developed in the BCAP (e.g., operations, maintenance, billing, metering), not the GRC. Further, WMA says that none of the components of the gas submeter discount is developed from any other parts of PG&E's current Phase II GRC application. Under the circumstances, it is reasonable to determine the discount in the BCAP proceeding.

Finally, all other things equal, opponents to the motion are generally indifferent to whether the discount is resolved in the GRC or BCAP. Opponents are seriously concerned, however, that the timing of the WMA motion will, if granted, unreasonably disturb the BCAP schedule. In this case, however, the BCAP schedule can be reasonably modified to include this issue, as explained below.

PG&E asserts that the electric and gas master meter discounts should be considered in the same proceeding to ensure consistency in consideration of the discount. To the extent true, we expect parties to seek reasonable relief in the GRC (e.g., opportunity to submit updated testimony) if the events or results in the BCAP necessitate any modification in their recommendations in the GRC.