Need for Expedited Consideration

Rule 77.7(f)(9) of the Commission's Rules of Practice and Procedure provides in relevant part that:

"...the Commission may reduce or waive the period for public comment under this rule...for a decision where the Commission determines, on the motion of the party or on its own motion, that public necessity requires reduction or waiver of the 30-day period for public review and comment. For purposes of this subsection, "public necessity" refers to circumstances in which the public interest in the Commission adopting a decision before expiration of the 30-day review and comment period clearly outweighs the public interest in having the full 30-day period for review and comment. "Public necessity" includes, without limitation, circumstances where failure to adopt a decision before expiration of the 30-day review and comment period...would cause significant harm to public health or welfare. When acting pursuant to this subsection, the Commission will provide such reduced period for public review and comment as is consistent with the public necessity requiring reduction or waiver."

We balance the public interest in quickly addressing these low-income assistance matters against the public interest in having a full 30-day comment cycle on the decision draft. We conclude that the former outweighs the latter. A reduced period for review and comment balances the need for parties' input with the need for timely action. Comments were filed on August 19, 2002 by PG&E, SCE and jointly by SDG&E and SoCal. As discussed in this decision, we make certain modifications to the draft decision in response to SCE's, SDG&E's and SoCal's explanations concerning expenditure levels and budget requests for certain cost categories.

In its comments on the draft decision, PG&E urges us to adopt a very specific timeline and procedure for the reasonableness review of PY2002 CARE program expenditures. We clarify that the schedule and procedures for such review will be established by Assigned Commissioner's ruling when Energy Division's audit is completed.

Reply comments were due on August 26, 2002. The Commission did not receive any reply comments.

Findings of Fact

1. SBX2 2 requires that the utility's actual expenditures on CARE administrative costs be recovered through a balancing account, subject to the Commission's determination that those costs are reasonable.

2. SBX2 2 requires changes to the ratemaking treatment of CARE administrative costs for PG&E and SCE, since they currently recover these costs on a fixed forecasted basis.

3. Under the Commission's ratemaking treatment for CARE-related expenditures, as adopted in D.89-09-040, CARE subsidy costs are recovered as a direct pass-through, i.e., without a reasonableness review. Nothing in SBX2 2 requires that we modify this treatment.

4. A "before the fact" (ex ante) review of proposed CARE administrative activities and expenditures ensures that the amount of revenues collected into the balancing account is reasonable.

5. An "after the fact" (ex post) review of CARE administrative costs ensures that actual expenditures and administrative activities, which may differ from those authorized by the Commission in establishing the CARE rate, are reasonable.

6. PY2002 CARE budgets should reflect CARE administrative activities that are consistent with the types of outreach activities the Commission authorized in D.01-05-033. They should be reasonable in light of adopted penetration rate benchmarks, actual expenditure levels during 2001 and the first half of 2002, and other considerations. They should also be based on realistic expectations about the amounts that can be expended over the year.

7. An ex post reasonableness review of PY2002 CARE administrative expenditures that focuses on general consistency with program proposals, rather than a detailed review of whether particular activities are reasonable after-the-fact, is consistent with the degree of flexibility given utilities during rapid deployment to develop and explore various CARE outreach strategies. It is also a reasonable approach in light of the fact that the Commission has not yet completed its evaluation of rapid deployment to determine which strategies have been the most effective, or implemented automatic enrollment.

8. Based on the record in this proceeding, the manner in which the utilities record and report CARE administrative expenditures appears to be very inconsistent, particularly with respect to certain overhead cost categories. An audit of accounts and expenditures during PY2002 will enable us to improve the consistency of utility reporting for future program planning cycles.

9. An ex post audit will also enable us to determine whether the utilities are complying with the Commission's directive that administrative costs booked to CARE be incremental. Extending balancing account treatment to SCE and PG&E provides us a unique opportunity to standardize both the recovery and the reporting of CARE administrative costs between all of the utilities to ensure compliance with this policy.

10. Our ex post reasonableness review of PY2002 CARE administrative costs should include a review of the utilities May 1, 2003 annual reports on PY2002 CARE program expenditures and an Energy Division audit, as described in this decision.

11. The CARE outreach activities proposed by the utilities are consistent with the types of rapid deployment outreach efforts the Commission authorized in D.01-05-033.

12. Authorizing the utilities to proceed with their proposed CARE outreach strategies is an appropriate "stay-the-course" approach to rapid deployment until we have completed our evaluation of rapid deployment efforts and have gained experience with automatic enrollment.

13. PG&E and SCE have requested amounts for outreach activities that far exceed what it appears they can realistically spend during PY2002, as discussed in this decision. The adopted budgets for this category better reflect the rate of expenditures during the first half of the year, while allowing for an acceleration of outreach activities during the second half of the year. They also allow for an increase over 2001 expenditures in consideration of the minimum penetration rate targets established for PY2002.

14. SoCal's requested budget for outreach activities reflects anticipated increases in expenditures booked to the account during the latter half of the year due to multi-lingual media outreach campaigns, additional capitation contractors and increases in costs for general outreach activities.

15. The upward trend in penetration rates and continued need for re-certification and verification activities during 2002 would appear to warrant budget increases to the processing/certification/verification category for all utilities. However, SCE and SoCal have spent only about one-fourth of their proposed PY2002 budgets for this category as of mid-year, and have not provided any explanation for this large difference. The adopted budgets for these utilities better reflect the rate of expenditures for these utilities during the first half of the year, while still allowing for an acceleration of processing, certification and verification activities during the second half of the year.

16. As discussed in this decision, the automatic enrollment program adopted in D.02-07-033 is expected to decrease the costs associated with processing, certification and verification in several ways. The utilities should anticipate these cost reductions beyond PY2002 by maintaining maximum flexibility to respond quickly to such changes as we proceed with this program.

17. This wide divergence in the utilities' cost estimates and rather erratic accounting practices for bill system programming raises the issue of whether reasonable, consistent conventions are being applied by the utilities in booking and recovering these types of expenditures.

18. The costs of studies and reports associated with our ongoing monitoring and evaluation of the low-income assistance program have increased since 2001, when rapid deployment was initiated. The utilities' proposed budgets provide a reasonable estimate of the increased costs, and actual expenditure levels to date reflect the fact that most of the expenditures for the year will occur during the second half as Phase 2 of the Needs Assessment gets underway. However, SCE's budget did not include the Phase 2 Needs Assessment costs allocated per Resolution E-3646, and should be adjusted accordingly. As discussed in this decision, in their May 1, 2003 report the utilities should break down the actual expenditures under this budget category by specific study in order to facilitate our ex post review.

19. For regulatory compliance and general administration, the proposed budgets and actual expenditures vary dramatically across utilities, as described in this decision. Differences in the types of costs booked to this account may account for some of these disparities, but there is not enough information on the record to make a determination.

20. For regulatory compliance, SoCal explained that it has only recorded $35 to date in this category due to internal posting and recording procedures issues that are currently being worked out. SoCal anticipates that these issues will be resolved in the next few months and that it will be booking to this cost category the full proposed amount. SoCal's proposed budget provides a reasonable estimate of the regulatory costs it will incur.

21. SDG&E and SoCal have not justified any increases to their general administration budgets, but have provided an explanation as to why booked expenditures currently diverge so noticeably from projected costs. Under these circumstances, it is reasonable to adopt PY2002 budgets for SDG&E's and SoCal's general administration costs at the level of the utility's actual PY2001 expenditures.

22. The utilities reporting and recording of indirect costs of the CARE program vary widely, as discussed in this decision. The record in this proceeding is insufficient to determine the extent to which these costs are also booked in base rates.

23. The utilities proposed budgets appropriately reflect the fact that there are no pilot programs authorized during PY2002.

24. The utilities proposed budgets for Energy Division staff requirements are reasonable, except that SCE's budget should be adjusted downwards to reflect the fact that SBX1 5 reimbursement funds for Energy Division staff requirements are "taken off the top."

25. The issue of funding for the LIOB is currently before the Commission in proposed Resolution No. L-301. For the purpose of establishing the CARE rate, it is reasonable to adopt the amounts that PG&E, SDG&E, and SoCal submitted in their applications, and budget $50,000 for SCE.

26. As described in this decision, SCE's ratemaking proposal for CARE expenditures is consistent both with the intent of SBX2 2 and with the rate recovery provisions of the Settlement Agreement. It is also identical to the Commission's recently adopted ratemaking treatment for increases in SCE's baseline subsidies and associated administrative expenses.

Conclusions of Law

1. The CARE administrative budgets adopted in today's decision are reasonable. As discussed in this decision, these budgets do not cap allowable expenditures in each budget category. They represent a level of CARE revenues to be collected in the CARE balancing account, subject to our ex post review of actual CARE expenditures.

2. Per D.02-07-033, the utilities should separately track the costs associated with the automatic enrollment program in the CARE balancing account. The utilities should work with Energy Division during program implementation to establish consistent accounting conventions for this purpose.

3. The CARE budgets adopted today should be effective until further Commission order. They should be reassessed during 2003 in light of the impact that automatic enrollment has on CARE enrollments and overall administrative costs.

4. As discussed in this decision, the utilities should use today's adopted budgets to establish the CARE surcharge rate in the appropriate rate setting proceedings.

5. PG&E and SCE should be authorized balancing account treatment for CARE administrative costs, consistent with SBX2 2.

6. PG&E's proposed balancing account and related tariff sheets for CARE administrative costs, as presented in Advice Letter 2352-G/2175-E are reasonable and should be adopted.

7. SCE's proposal to modify PROACCT, as described in this decision, is reasonable and should be adopted. SCE should file an Advice Letter to implement these changes within 20 days from the effective date of this decision.

8. Cost recovery of CARE administrative costs should be subject to the reasonableness review process described in this decision.

9. The utilities should track the actual costs of the Energy Division audit under the Energy Division cost category in their CARE balancing accounts, to be reimbursed along with other CARE-related Energy Division expenses.

10. In order to implement the balancing account provisions of SBX2 2 and address the CARE funding shortfall for PY2002 as expeditiously as possible, this order should be effective today.

11. There being no further issues to resolve in this proceeding, A.02-04-031, A.02-04-034, A.02-04-035 and A.02-04-036 should be closed.

ORDER

IT IS ORDERED that:

1. Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Southern California Edison Company (SCE) and Southern California Gas Company (SoCal), referred to collectively as "the utilities," are authorized the following CARE budgets for program year (PY) 2002:

Authorized PY2002 CARE Budgets
Cost Category	PPG&E	SSCE	SSDG&E	S SoCal
Outreach	$ 5,095,000	$ 840,840	$ 2,011,074	$ 3,087,794
Processing/Certification/Verification	$ 1,320,000	$ 520,798	$ 212,235	$ 766,030
Billing/Programming	$ 20,000	$ 500,000	$ 35,000	$ 596,898
Measurement/Evaluation	$ 266,600	$ 344,000	$ 301,366	$ 55,800
Regulatory Compliance	$ 100,000	$ 80,000	$ 86,286	$67,045
General Administration	$ 321,552	$ 464,500	$ 189,185	$ 24,794
Indirect Costs	$0	$82,700	$ 416,058	$0
Energy Division	$ 82,700	$ 195,500	$ 30,000	$ 68,950
LIAB/LIOB	$ 100,000	$50,000	$ 47,832	$ 35,000
Total Administration	$ 7,305,852	$ 3,078,338	$ 3,329,036	$ 4,702,311
CARE Subsidy	$ 125,000,000	$ 93,400,000	$ 25,568,477	$ 42,533,000
Total CARE Program	$ 132,305,852	$ 96,478,338	$ 28,897,513	$ 47,235,311

Within 10 days from the effective date of this decision, PG&E and SDG&E shall file Advice Letters that allocate the authorized budget between their electric and gas departments. These advice letters shall be effective on filing subject to Energy Division determining that they are in compliance with this decision.

2. The annual CARE budgets authorized today shall be in effect until further Commission order.

3. SDG&E shall propose adjustments to the electric component of its CARE rate in its next appropriate rate proceeding to reflect today's adopted CARE budget and to amortize under- or over-collections in its current CARE balancing account, as appropriate.

4. PG&E's Advice Letter 2352-G/2175-E is approved. PG&E shall file for adjustments to the electric component of its CARE rate established by that Advice Letter in its next RAP to reflect today's adopted CARE budget. Any proposed adjustments to the CARE rate to also amortize balances in PG&E's electric CARE balancing accounts (for subsidies or administrative costs) must be consistent with electric rate freeze provisions of Assembly Bill (AB) 1890 and the directions of this Commission concerning rate recovery under those provisions.

5. Within 20 days from the effective date of this decision, SCE shall file an advice letter to implement the ratemaking treatment for CARE-related expenses described in this decision and illustrated in Attachment 5. This advice letter shall be effective on filing, subject to Energy Division determining that it is in compliance with this decision.

6. On the gas side, SDG&E, PG&E, and SoCal shall submit proposed gas surcharge rates, pursuant to Public Utilities Code Section 890(e), to become effective with other year-end consolidated gas rate updates on January 1, 2003. The proposed rates shall reflect today's adopted CARE budgets. SDG&E, PG&E, and SoCal shall file their Advice Letters by October 15, 2002.

7. Cost recovery of the utilities' CARE administrative costs for PY2002 and beyond is conditioned upon the Commission's final determination of reasonableness, not withstanding any decision by the Commission to authorize the amortization of balances in the utilities' CARE balancing accounts.

8. As described in this decision, the Commission's reasonableness review of CARE administrative costs consists of an ex ante (before the fact) review of proposed CARE administrative activities and budgets and an ex post (after the fact) review of actual CARE administrative expenditures. For PY2002, the ex post review will include an audit by Energy Division of all CARE administrative costs. The utilities shall close their books for PY2002 by March 2003 for this purpose. The audit shall be designed to examine the specific details of the various utility practices, with respect to recording and reporting CARE administrative costs. The audit shall include an evaluation of where CARE administrative costs are currently being recovered and present findings on whether or not the costs booked to the CARE account are incremental, i.e., not provided for in the utility's base rates.

Energy Division shall also provide recommendations on how the utilities should report and recover CARE administrative expenditures on a more consistent basis in the future, and on whether any recorded PY2002 expenditures should be disallowed for cost recovery. Energy Division's audit report is due by August 1, 2003, and shall be filed with the Commission's Docket Office in Rulemaking (R.) 01-08-027, with service on all parties to this proceeding and R.01-08-027. Comments are due within 30 days of Energy Division's filing of the report and replies are due 15 days thereafter. Energy Division may perform the audit itself or hire independent contractors for this purpose. We delegate the task of approving the budget and schedule for the audit to the Assigned Commissioner in R.01-08-027. In addition, the Assigned Commissioner shall establish a schedule for comments on Energy Division's audit and address other procedural matters related to the reasonableness review of PY2002 program expenditures.

9. As discussed in this decision, the utilities shall track the actual costs of Energy Division's audit in their CARE balancing accounts, under the Energy Division cost category, to be reimbursed along with other Energy Division CARE-related expenses.

10. The Assigned Commissioner in R.01-08-027, in consultation with Energy Division and the assigned Administrative Law Judge, may initiate additional audits of CARE expenditures after-the-fact, should the Energy Division audit and our ex post review of reasonableness for PY2002 indicate that further examination is needed.

11. The Assigned Commissioner may, for due cause, modify the due dates set forth in this decision.

12. All reports and other submittals required by this decision shall be filed at the Commission's Docket Office in R.01-08-027 and served electronically on all appearances and the state service list in this proceeding and R.01-08-027. Service by U.S. mail is optional, except that one hard copy shall be mailed to Judge Meg Gottstein at P.O. Box 210, Volcano, CA 95689. In addition, if there is no electronic mail address available, the electronic mail is returned to the sender, or the recipient informs the sender of an inability to open the document, the sender shall immediately arrange for alternate service (regular U.S. mail shall be the default, unless another means-such as overnight delivery-is mutually agreed upon). Parties that prefer a hard copy or electronic file in original format in order to prepare analysis and filings in this proceeding may request service in that form as well. The current service list for this proceeding is available on the Commission's web page, www.cpuc.ca.gov.

13. Application (A.) 02-04-031, A.02-04-034, A.02-04-035 and A.02-04-036 are closed.

This order is effective today.

Dated September 5, 2002, at San Francisco, California.

LORETTA M. LYNCH

President

CARL W. WOOD

GEOFFREY F. BROWN

MICHAEL R. PEEVEY

Commissioners

Commissioner Henry M. Duque, being necessarily absent, did not participate.

ATTACHMENT 1

ACRONYMS/ABBREVIATIONS

PY - Program Year

CARE - California Alternate Rates For Energy

PG&E - Pacific Gas and Electric Company

SDG&E - San Diego Gas & Electric Company

SCE - Southern California Edison Company

SoCal - Southern California gas Company

SBX2 2 - Senate Bill No. 2 from the Second Extraordinary Session

LIEE - Low-Income Energy Efficiency

PGC - Public Goods Charge

ORA - Office of Ratepayer Advocates

PHC - Prehearing Conference

Working Group - Reporting Requirements Manual Working Group

LIAB - Low Income Advisory Board

LIOB - Low-Income Oversight Board

LIRA - Low Income Ratepayer Assistance

RAP - Rate Adjustment Proceeding

BCAP - Biennial Cost Adjustment Proceeding

AL - Advice Letter

PROACT - Procurement Related Obligations account

SRBA - Settlement Ratemaking Balancing Account

(END OF ATTACHMENT 1)

ATTACHMENT 2

Calculation of PY2002 Minimum Targets-Net Enrollment

(END OF ATTACHMENT 2)

ATTACHMENT 3

CARE Proposed and Authorized PY2002 Budgets,
with Expenditure Information

CARE Program Costs:	Pacific Gas and Electric
	Actual 2001	Proposed 2002	1/1/02 thru 6/30/02 Actual	Adopted
Total Outreach	$3,247,915	$7,641,534	$2,038,000	$5,095,000
Processing/ Certification/Verification	$948,103	$1,320,000	$514,406	$1,320,000
Billing System /Programming	$16,938	$20,000	$210	$20,000
Measurement & Evaluation	$1,693	$266,600	$0	$266,600
Regulatory Compliance	$68,458	$100,000	$128,468	$100,000
General Administration	$272,879	$321,552	$305,672	$321,552
Indirect Costs	$0	$0	$0	$0
CPUC Energy Division	$65,535	$82,700	$53,980	$82,700
LIAB/LIOB	$0	$0	$0	$100,000
TOTAL ADMIN COSTS	$4,621,521	$9,752,386	$3,040,736	$7,305,852
CARE Rate Discount	$70,023,000	$125,000,000	$43,753,590	$125,000,000
TOTAL PROGRAM COSTS	$74,644,521	$134,752,386	$46,794,326	$132,305,852
Source:
All Admin Costs from July 22 Joint Utility Report
2001 Subsidy from CARE Annual Report
2002 Proposed Subsidy from Application
2002 Y-T-D Subsidy From July 22, 2002 RD Report

CARE Program Costs:	Southern California Edison
	Actual 2001	Proposed 2002	1/1/02 thru 6/30/02 Actual	Adopted
Total Outreach	$601,743	$1,700,000	$224,224	$840,840
Processing/ Certification/Verification	$329,190	$780,000	$208,319	$520,798
Billing System /Programming	$0	$500,000	$76,253	$500,000
Measurement & Evaluation	$5,004	$80,000	$2,502	$344,000
Regulatory Compliance	$60,000	$80,000	$30,000	$80,000
General Administration	$862,854	$464,500	$232,951	$464,500
Indirect Costs	$257,495	$0	$82,185	$87,700
CPUC Energy Division	$53,253	$195,500	$11,666	$195,500
LIAB/LIOB	$0	$0	$0	$50,000
TOTAL ADMIN COSTS	$2,169,539	$3,800,000	$868,100	$3,078,338
CARE Rate Discount	$68,837,345	$93,400,000	$42,784,496	$93,400,000
TOTAL PROGRAM COSTS	$71,006,884	$97,200,000	$43,652,596	$96,478,338
Source:
All Admin Costs from July 22 Joint Utility Report
2001 Subsidy from CARE Annual Report
2002 Proposed Subsidy from Application
2002 Y-T-D Subsidy From July 22, 2002 RD Report

CARE Program Costs:	San Diego Gas & Electric
	Actual 2001	Proposed 2002	1/1/02 thru 6/30/02 Actual	Adopted
Total Outreach	$1,120,289	$2,011,074	$883,883	$2,011,074
Processing/ Certification/Verification	$193,318	$212,235	$77,606	$212,235
Billing System /Programming	$315	$35,000	$0	$35,000
Measurement & Evaluation	$5,842	$301,366	$7,246	$301,366
Regulatory Compliance	$45,205	$86,286	$30,324	$86,286
General Administration	$189,185	$190,174	$47,135	$189,185
Indirect Costs	$81,926	$416,058	$150,336	$416,058
CPUC Energy Division	$38,610	$30,000	$27,200	$30,000
LIAB/LIOB	$48,210	$47,832	$19,930	$47,832
TOTAL ADMIN COSTS	$1,722,900	$3,330,025	$1,243,660	$3,329,036
CARE Rate Discount	$15,422,789	$25,568,477	$9,301,153	$25,568,477
TOTAL PROGRAM COSTS	$17,145,689	$28,898,502	$10,544,813	$28,897,513
Source:
All Admin Costs from July 22 Joint Utility Report
2001 Subsidy from CARE Annual Report
2002 Proposed Subsidy from Application
2002 Y-T-D Subsidy From July 22, 2002 RD Report

CARE Program Costs:	Southern California Gas Company
	Actual 2001	Proposed 2002	1/1/02 thru 6/30/02 Actual	Adopted
Total Outreach	$1,782,821	$3,087,794	$1,008,210	$3,087,794
Processing/ Certification/Verification	$845,048	$1,128,472	$306,413	$766,030
Billing System /Programming	$181,444	$596,898	$235,304	$596,898
Measurement & Evaluation	$0	$55,800	$0	$55,800
Regulatory Compliance	$107,062	$67,045	$35	$67,045
General Administration	$24,794	$51,440	$1,021	$24,794
Indirect Costs	$0	$0	$0	$0
CPUC Energy Division	$68,929	$68,950	$40,802	$68,950
LIAB/LIOB	$0	$35,000	$0	$35,000
TOTAL ADMIN COSTS	$3,010,098	$5,091,399	$1,591,785	$4,702,311
CARE Rate Discount	$39,782,791	$42,533,000	$21,322,523	$42,533,000
TOTAL PROGRAM COSTS	$42,792,889	$47,624,399	$22,914,308	$47,235,311
Source:
All Admin Costs from July 22 Joint Utility Report
2001 Subsidy from CARE Annual Report
2002 Proposed Subsidy from Application
2002 Y-T-D Subsidy From July 22, 2002 RD Report

Authorized PY2002 CARE Budgets
Cost Category	PG&E	SCE	SDG&E	SoCal
Outreach	$ 5,095,000	$ 840,840	$ 2,011,074	$ 3,087,794
Processing/Certification/Verification	$ 1,320,000	$ 520,798	$ 212,235	$ 766,030
Billing/Programming	$ 20,000	$ 500,000	$ 35,000	$ 596,898
Measurement/Evaluation	$ 266,600	$ 344,000	$ 301,366	$ 55,800
Regulatory Compliance	$ 100,000	$ 80,000	$ 86,286	$67,045
General Administration	$ 321,552	$ 464,500	$ 189,185	$ 24,794
Indirect Costs	$0	$82,700	$ 416,058	$0
Energy Division	$ 82,700	$ 195,500	$ 30,000	$ 68,950
LIAB/LIOB	$ 100,000	$50,000	$ 47,832	$ 35,000
Total Administration	$ 7,305,852	$ 3,078,338	$ 3,329,036	$ 4,702,311
CARE Subsidy	$ 125,000,000	$ 93,400,000	$ 25,568,477	$ 42,533,000
Total CARE Program	$ 132,305,852	$ 96,478,338	$ 28,897,513	$ 47,235,311

Statewide--PG&E, SCE, SDG&E and SoCal
Cost Category	PY 2001	PY 2002 Requested	Authorized
Outreach	$ 6,752,768	$ 14,440,402	$ 11,034,708
Processing/Certification/Verification	$ 2,315,659	$ 3,440,707	$ 2,819,063
Billing/Programming	$ 198,697	$ 1,151,898	$ 1,151,898
Measurement/Evaluation	$ 12,539	$ 703,766	$ 967,766
Regulatory Compliance	$ 280,725	$ 333,331	$ 333,331
General Administration	$ 1,349,712	$ 1,027,666	$ 1,000,031
Indirect Costs	$ 339,421	$ 416,058	$ 498,758
Energy Division	$ 226,327	$ 377,150	$ 377,150
LIAB/LIOB	$ 48,210	$ 82,832	$ 232,832
Total Administration	$ 11,524,058	$ 21,973,810	$ 18,415,537
CARE Subsidy	$ 194,065,925	$ 286,501,477	$ 286,501,477
Total CARE Program	$ 205,589,983	$ 308,475,287	$ 304,917,014

(END OF ATTACHMENT 3)

ATTACHMENT 4

PY2002 PLANS FOR MULTI-LINGUAL RECERTIFICATION LETTERS

* Asian letters provided upon request

(END OF ATTACHMENT 4)

ATTACHMENT 5

SCE's Proposed Modifications to CARE Ratemaking

Southern California Edison Company CARE Ratemaking
I. How "PROACT" Ratemaking Works:
In the Settlement Rate Balancing Account (SRBA):
			Total Revenue
		Less:	Recoverable Costs
		Equals	Surplus		Used to amortize PROACT
					Balance
II. An Example:						($000)
						Prior to	After
						Increased	Increased	Impact
						Eligibility	Eligibility	(Undercollection)
			CARE-Discount			(2,000)	(5,000)	(3,000)
			CARE-Surcharge			2,000	2,000	-
			All Other Revenue			800,000	800,000	-
			Total Revenue			800,000	797,000	(3,000)
		Less:	Authorized CARE Administrative Rev. Rqmt.			1,400	1,400
			All Other Recoverable Costs			648,600	648,600	-
			Total Recoverable Costs			650,000	650,000	-
		Equals	SURPLUS			150,000	147,000	(3,000)
III. Proposed Ratemaking Entries:
	Part A (Difference between Discount and Surcharge):
				Remove Undercollection from SRBA			3,000
				Record Undercollection in CBA				(3,000)
				Where:	SURPLUS Equals		150,000
					Undercollection Recorded in CBA			(3,000)
	Part B (CARE Administrative Revenue Requirement):
				Authorized CARE Admin. Revenue Requirement				1,400
				Actual CARE Admin. Expenses				(1,600)
					Undercollection Recorded in CBA			(200)
	CARE Balancing Account:			Difference between Discount and Surcharge			A	(3,000)
				Difference between Authorized and Actual Admin.			B	(200)
							Total	(3,200)
		/1 The undercollected balance recorded in the CBA will be recovered after the PROACT
		Rate Repayment Period.
IV. Summary:
	In order for SCE to maintain revenue neutrality while increasing the CARE eligibility with no overall corresponding change in rates, SCE proposes to establish a new CARE Balancing Account (CBA). The CBA will record the undercollection in revenues by comparing the amount of the CARE Discount with the CARE Surcharge. Under the current Commission-approved ratemaking structure, the undercollection in revenues will automatically be recorded to the PROACT. In order to ensure that the undercollection is appropriately recorded only in the CBA (and not the SRBA), SCE will remove the CARE-related undercollection from the SRBA. On a monthly basis, SCE will credit the SRBA by an amount equal to the debit recorded in the CBA associated with the difference between the CARE Discount and CARE Surcharge amounts.
	In addition, the authorized CARE administrative revenue requirement will be a Recoverable Cost, as is the current Commission adopted practice. The difference between the authorized CARE revenue requirement and the actually incurred CARE administrative expenses will also be recorded in the CBA. The disposition of the amounts recorded in the CBA will be recovered after the PROACT Rate Repayment Period.

(END ATTACHMENT 5)