V. Use of California Jurisdictional Operations

PacifiCorp bases its request on California jurisdictional operations. ORA, Roseburg, and Siskiyou say that company-wide operations should be used in determining whether an interim rate increase is necessary. Historically, we have set rates based on California jurisdictional operations. If we were to do as ORA and the other parties suggest, we would base a determination of whether an interim increase is needed on total company operations. In other words, if the total company is financially healthy, California rates need not be increased regardless of whether the results of operations for California demonstrate that California ratepayers are paying the full costs of the service they receive, including a reasonable return.

Typically, California rates should be set based on California operations. California ratepayers should not subsidize other states, nor should they be subsidized by them. However, the issue at hand is whether a financial emergency exists which warrants the unusual actions of an interim rate increase. To determine the nature of the financial status of PacifiCorp, it is appropriate to look at the results of the company as a whole. This does not mean that the more normal task of setting rates in a general rate case should deviate from the use of California specific results.