Escalation Rates

SDG&E argues that D.04-12-015 under-stated the test year estimate by using an incorrect escalation so that the test year is understated by $0.779 million. SDG&E fails to tell us anywhere in Ex. 170 how it derived this shortfall. There is no comparison between the SDG&E calculation and the allowance included in D. 04-12-015. SDG&E does not compare and cite the "incorrect" rates and the "correct" rates.

In Ex. 170, (Appendix F-1) SDG&E presented its argument for $5.319 million in total escalation from 2000 dollars to 2004 dollars. But SDG&E provides no computations to show how it derived a $0.779 million error by the Commission, nor did it present a comparison to the escalation included in D.04-12-015. With no clear and convincing evidence to support or demonstrate its calculation, we cannot adopt SDG&E's request.