VI. Procedural Process and Schedule for Future Filings

A. Long-Term Procurement Plan Filings

SCE proposes that its long-term plan be reviewed on a three year cycle, in coordination with its general rate case. Specifically, SCE proposes that each utility would develop and submit a long-term integrated resource plan within 90 days of the final decision in its respective GRC, such plan to incorporate those issues resolved in the GRC. Further, SCE states that the Rate Case Plan (D.89-01-040, as modified) already contemplates submission of long-term resource plans as part of the utility's GRC showing. The CEC would like this schedule to revolve around the two year cycle for the CEC's Integrated Energy Policy Report.

We intend to review and adopt revised 2004 long-term procurement plans for the three utilities in our new Procurement OIR, opening in the first quarter of 2004. Following that, a three year cycle of utility-specific long-term planning is reasonable, and, therefore, we adopt this utility proposal. Although we believe the CEC's request is reasonable, we are concerned about a schedule that results in an effective 50% workload increase for the Commission and a time of fiscal and staffing constraint. In our decision on the revised 2004 plans, we should revisit the specific timing of each utility's next GRC filing and revise any long-term plan filing dates as necessary.

B. ERRA Filings

ORA and SCE recommend that the Commission annually update the short-term procurement plans in each utility's ERRA filing. In addition, PG&E, SCE, and SDG&E have all indicated in their ERRA filings that efficiencies could be made in the procedural process we adopted in D.02-10-062, especially with forecasts established closer in time to the applicable year, a combining of the forecast, reasonableness review, and ERRA true-up in one application for each utility, and the possibility of the ERRA trigger amount being handled by Advice Letter rather than application.

2004 ERRA Schedule
IOU	2004 ERRA AL Trigger /1	2004 ERRA Forecast /2	2003 Reasonableness Review	ERRA Over/Under Collection True-up /3
PG&E	April 1,2004	August 2003	August 2003	N/A
SCE	April 1, 2004	October 2003	October 2003	N/A
SDG&E	April 1, 2004	December 2003	December 2003	N/A

Footnotes:

1/ AL Trigger is based on 12-months (calendar) of prior year recorded data. The IOU's will refile AL if Reasonableness Review Decision modifies recorded data. Note: By April 1, 2004 the IOUs will have closed their books for 2003 and filed their SEC reports.

2/ ERRA Forecast application will be combined with the Short-Term Procurement Plan application in 2005

3/ ERRA over/under collection true-up is independent of when IOUs file ERRA Forecast or Reasonableness Review applications - IOUs will file whenever there is an over/under collection.

2005 ERRA Schedule
IOU	2004 ERRA AL Trigger /1	2005 ERRA Forecast & Short-Term Procurement Plan /2	2004 Reasonableness Review /3	ERRA Over/Under Collection True-up /4
PG&E	April 1,2005	June 1, 2004	February 2005	N/A
SCE	April 1, 2005	August 1, 2004	April 2005	N/A
SDG&E	April 1, 2005	October 1, 2004	June 2005	N/A

Footnotes:

1/ AL Trigger is based on 12-months (calendar) of prior year recorded data. The IOU's will refile AL if Reasonableness Review Decision modifies recorded data. Note: By April 1, 2005 the IOUs will have closed their books for 2004 and filed their SEC reports.

2/ ERRA Forecast application will be combined with the Short-Term Procurement Plan application. Note: The dates have been changed so the IOUs file earlier in the year. This will allow IOU/PUC to have decisions out by the end of the year.

3/ 2004 Reasonableness Review period will incorporate 12 months of 2004 calendar year data.

4/ ERRA over/under collection true-up is independent of when IOUs file ERRA Forecast or Reasonableness Review applications - IOUs will file whenever there is an over/under collection.

For 2004, the utilities should only update the forecasts in their 2004 adopted short-term procurement plans. Each utility should file its revised 2004 long-term procurement plan in the new Procurement OIR which we intend to open in the first quarter of 2004.