5. Opposition to the Settlement

TURN and CCUE oppose adoption of the settlement, in particular the requested findings that $3.4 million in funding through March 2006 and $5.9 million in bridge funding are reasonable. TURN and CCUE identify five primary reasons for their opposition: 1) the application admits that the AMI project is not cost-effective without tariff changes, 2) the settlement fails to meet any of the findings required by the Commission, 3) the settlement fails to establish that the project meets the functionality criteria set forth in Commissioner Grueneich's ruling establishing the standards by which pre-deployment funding would be authorized, 4) the settlement's authorization of pre-deployment funds is contrary to historical Commission practice, and 5) the settlement provides insufficient justification to spend ratepayer dollars on an admittedly not cost-effective project. TURN and CCUE did not serve testimony but instead rely on other parties' testimony to support their arguments. TURN and CCUE recommend that the Commission defer approval of pre-deployment funding until the cost-effectiveness of SDG&E's proposed AMI project is determined.