XXVII. SoCalGas Administrative and General
Expenses

There are eight accounts, with sub-parts, where SoCalGas and ORA have differences of $49.956 million in Test Year 2004 estimates. We will decide those issues, and others as voiced by other intervenors, but otherwise we adopt as reasonable the end-of-litigation position of SoCalGas for Administrative and General accounts. Except as noted in the adoption of a different forecast, SoCalGas met its burden of proof by presenting sufficient detailed testimony in support of its estimated costs.

A. SoCalGas and SDG&E Account 920 - Administrative and General Salaries

For Administrative and General Salaries, we discuss the common issues together, and at the end of this account section several proposals that relate only to SDG&E.

B. SoCalGas and SDG&E - Sarbanes-Oxley Act Costs

The issues here are similar for both SoCalGas and SDG&E, and we will discuss them jointly. There was a significant request by both SoCalGas and SDG&E to add positions in the Controller Department due to the 2002 enactment of the Sarbanes-Oxley Act. This is one of the most important new federal legislative actions in the securities law area since the 1930's and it significantly modified and expanded the reporting and control requirements affecting corporate governance, financial disclosure and the practice of public accounting. SoCalGas proposed $381,000 in Account 920 for six positions and SDG&E proposed $298,000 in Account 920 for five positions for the expected increase in workload due to Sarbanes-Oxley Act requirements.³⁶⁴

ORA argued that prior to Sarbanes-Oxley, both utilities were required to establish and maintain adequate internal controls and procedures for tracking and reporting financial information, and in ORA's opinion, it would seem reasonable to conclude that SoCalGas and SDG&E were already analyzing and verifying their financial documents for accuracy and thoroughness before disclosure prior to the Sarbanes-Oxley Act. We disagree with this overly simple view; the Sarbanes-Oxley Act clearly added to the reporting obligations of companies like SoCalGas and SDG&E - and Sempra, its parent - which we cannot ignore. As they pointed out in testimony, and ORA acknowledged, reporting intervals have been shortened and the companies needed more staff to meet these deadlines and, for example, to provide the information required by the independent certified public accountant as a part of the audited financial statements. They argued this is all incremental work.³⁶⁵

One concern about the Proposed Settlements was how the parties specifically provided for any new or expanded obligations under the requirements of the Sarbanes-Oxley Act, and as another example of the inadequate "black-box" aspects of the settlements, we find the settling parties did not make any specific commitment of resources:

"The utility Joint Settlement Agreements do not propose a specific funding level for activities and costs associated with Sarbanes-Oxley. However, the Joint Settlement Agreement reductions in the utility end-of-hearings positions in the accounts ... represent the settling parties agreement to reflect the impact of reductions from other aspects of the settlement to a number of Administrative & General support services (including the activities associated with Sarbanes-Oxley)." (January 16, 2003 response to Administrative Law Judge Request for Information on Proposed Settlements dated January 16, 2003.)

We are not prepared at this time to leave corporate governance and financial reporting to chance; we will adopt the funding for the incremental positions intended to comply with the requirements of Sarbanes-Oxley, and we require an affirmative showing, in detail, in the next proceeding that illustrates the functions and workload for all financial reporting personnel after SoCalGas and SDG&E have had an opportunity to function in this new, faster, more thorough, disclosure environment. ORA may critique that experience in detail in the next rate proceeding. Better and more detailed financial review protections benefit not only shareholders but also ratepayers through reduced risk of financial irregularities and faster financial reporting.³⁶⁶

In Account 921, ORA proposed a reduction to related training; SoCalGas asked for $0.374 million and SDG&E asked for $0.577 million for training and outside consultants. We will allow the funding and expect an accounting of its utilization in the next proceeding.

1. SoCalGas and SDG&E Cost Accounting Positions for Capital Expenditures

SoCalGas asked for four new positions, senior accountants, based on the increased workload of capital expenditure increases, and by lowering the expected number of work orders handled per employee as a result of more review and control over reporting expenditures. ORA proposed to allow three not four positions. SDG&E also asked for new positions; one for construction accounting workload increases, another for more up-front review, another for the impact of Financial Accounting Standards Board Statement No. 143 that requires continuous monitoring of assets to identify Assets Retirement Obligations, and finally one more position for "translating the electric procurement dispatch models into a forecast of short and long-term cash flow, balancing accounts, revenue and fuel and purchased power forecasts" for a total of four positions.³⁶⁷ ORA proposed to eliminate these new positions.

We will allow these positions in Test Year 2004 forecasts, we accepted the majority of capital expenditure estimates and we acknowledge the greater accounting complexities and the workload associated with electric procurement in the current electricity markets. Ratepayers will be safeguarded by the TLCBA in the event the companies are unable to fill all positions or if their actual experience indicates that they can function effectively with fewer than forecast positions.

2. SoCalGas and SDG&E Results of Operations Models

SoCalGas and SDG&E proposed two new positions, located within SoCalGas, that are intended to work on the results of operations models for both companies. SoCalGas and SDG&E indicated to ORA in a data request response that:

"Although SoCalGas and SDG&E were not required to submit an RO model in this format,(³⁶⁸) in the spirit of that requirement, the utilities created a PC based spreadsheet model that is in full compliance with the six specific adjustments the model is expected to accomplish. Further, the utilities enhanced the model design beyond the requirements in the CPUC's PG&E decision to maximize efficiency in calculations and speed of use." (Response to ORA-DR-SCG-069, p. 14-11, Ex. 301 and p. 139, ORA opening litigation brief.)

SoCalGas and SDG&E argue that the work will continue to assist in the implementation of the decision in these proceedings, that the interim decision for refundable rate relief will require modeling, and ORA's recommendation to place SoCalGas and SDG&E on a traditional General Rate Case model, (which requires that the companies file a NOI 18 months before the start of the next test year) will require these positions in order for the companies to prepare spreadsheets that support a case filed as early as mid-2005 for a Test Year 2008.³⁶⁹

We have already determined in this decision that the companies must file a NOI for the next proceeding and that the next proceeding will be sooner than proposed in the applications, with a Test Year 2008. Therefore, we will adopt the estimate for these positions so that SoCalGas and SDG&E are able to proceed with their next cases and complete the implementation of this proceeding. We will also require, based on our current experience with the SoCalGas and SDG&E models,³⁷⁰ that the companies use these resources to continue refining and enhancing the models and in particular, that they eliminate all instances of manual data transfers within the models and for the tables and reports generated by the models to support the results of operations, rate base and other ratemaking tools. This requirement is consistent with §§ 1821 and 1822, to ensure the models and for ratemaking are accessible to the Commission and all parties.

C. SoCalGas Accounts 920 & 921 Administrative and General - Salaries and Expenses for Regional Public Affairs

SoCalGas asked for $5.738 million in Test Year 2004 for Regional Public Affairs that it described as "communications activities with local jurisdictions and governmental agencies on issues related to Region distribution and transmission construction, operations and maintenance activities."³⁷¹ ORA argued that these costs are primarily lobbying in nature. Most of this communication focuses on local elected officials.³⁷² ORA proposed $2.880 million. These are activities that ORA argued fall under existing FERC and Commission definitions of "lobbying."³⁷³ ORA provided no details in support of any review of SoCalGas workpapers, data request responses or its own analysis of specific activities by the Regional Public Affairs staff.

In rebuttal, SoCalGas lists a number of specific instances, where with local government, various fees and costs were reduced or avoided.³⁷⁴ SoCalGas also described a number of activities where it claims the benefit of such outreach accrues to the ratepayers by ensuring a better flow of information between the company and local entities and avoidance of a burden on less-well-equipped operational staff who would otherwise interact with these entities. We note that the proposed Settlement splits the difference, "based on a consideration of litigation risk"³⁷⁵ but we find it inappropriate to do so. To the maximum extent possible, the ratepayers are entitled to a clear answer on what the company is expected to do in exchange for the costs included in rates. When both parties are afraid they may lose, but do not quantify the work that is compromised (eliminated) when the money dispute is compromised, only the ratepayers suffer.

When we look at Ex. 3, SoCalGas identifies six areas that it claims to be responsible for the $1.995 million increase from 2001 to 2004; it lists working with local communities to avoid new fees and taxes with "new cities," (not named or identified in any fashion); working with cities imposing more stringent requirements on work performed in rights of way, (again, not specifically named or identified in any fashion); increased communication with air quality management districts; new water quality requirements, "navigating more stringent permitting requirements" for system upgrades (again, no new specific and more stringent requirements are cited), and the need to reach out to customers.³⁷⁶

We find nothing in the descriptions or in later rebuttal in Ex. 66 that assigns cost with specificity to any of the alleged new or changed activities. We see these as simply the current examples of the varying but ongoing activities already allowed for in the current workforce, especially given no substantial hard facts about current duties and how SoCalGas determined the cost increase for the test year.

We therefore hold the expense level constant at the 2001 base year expense of a total $3.765 million for Test Year 2004 in both accounts. We make this adjustment not based on re-characterizing the costs as "lobbying" but because SoCalGas did not meet its burden of proof and failed to quantify and justify any increase.

D. SDG&E Accounts 920 & 921 Administrative and General - Salaries and Expenses for Regional Public Affairs

ORA proposed an identical adjustment for SDG&E for Salaries and Expenses for Regional Public Affairs as was made for SoCalGas, arguing the costs are lobbying. We will make the same adjustment, holding SDG&E at the 2001 level of $0.605 million in total for both accounts for Test Year 2004. In the next rate proceeding, both applicants and ORA are invited to make a more task-specific and detailed recommendation. UCAN argued for no increase over the SDG&E base amount.³⁷⁷ This is a reduction of $0.052 million in Account 920 and $0.512 million in Account 921 "O" for SDG&E's Test Year 2004.

1. SoCalGas - Human Resources Account 920.2

SoCalGas explained that a "key driver" for training program success is to continually redesign or up-date programs to be current with policy and procedures and regulatory changes.³⁷⁸ This activity is Instructional Design. ORA proposed an adjustment of 1.2 positions for $0.115 million for one instructional design manager and 0.1 each for two other positions and $0.047 million in other costs because in its opinion SoCalGas did not justify the costs.³⁷⁹ ORA did not explain what was lacking in SoCalGas' justification, and so we cannot tell if ORA's objection itself is reasonable. A persistent failing in ORA's showing is the use of conclusions without the benefit of attendant analysis and explanation on how and why that conclusion should be viewed as reasonable. We will not make adjustments that represent a small fraction an employee position. We will not make ORA's adjustment; SoCalGas justified in its testimony need for the instructional design program.

2. SDG&E - Human Resources

ORA recommended a $0.255 million adjustment for four of the 12 new positions requested by SDG&E. ORA argued that SDG&E had carried several vacant positions for some time before filling seven in 2002, and therefore feels another eight are sufficient.³⁸⁰ We have already noted that the "maturing workforce" argument is not compelling, and we therefore conclude the level of hiring and other personnel transactions may not be as high as projected by SDG&E. We will adopt ORA's $0.255 million reduction to the 2004 estimate. We note this is an area where, if we are wrong, SDG&E can shift unspent funding from other areas where we expect savings may accrue to the TLCBA.

3. SoCalGas and SDG&E Severance Payments

ORA proposed that the forecast of severance payments, based on historical payments, should be excluded from the test year, citing D.00-02-048³⁸¹ for PG&E, because a position that is already funded (in the forecast) provides salary savings while vacant. This would assume that a position is then vacant for a sufficient time for the savings to offset the severance payment. ORA has not shown any analysis of actual (historical) severance payments compared to salary savings that would show this is applicable to either SoCalGas or SDG&E. We agree that SoCalGas and SDG&E should not get an allowance for severance if savings are likely to equal or exceed the severance costs. But, we do not know the facts here. In any case, the TLCBA will capture the savings of a vacant position and we need not adopt this adjustment.

4. Other Proposed SDG&E Adjustments

Two other items are an agreement to accept a $113,000 reduction reflected in both SDG&E's and ORA's end-of-litigation position to resolve an unidentified issue related to ORA's audit of 2001 recorded information and an un-reconciled difference between the SDG&E and ORA results of operations spreadsheets. We will rely on SDG&E's spreadsheets that included these items.

5. Conclusion - Account 920 - A&G Salaries

We adopt the following SoCalGas labor costs:

Account 920.0 $29.915 million

Account 920.2 2.015 million

Total 902.0 + 920.2 $31.930 million

We adopt the following SDG&E labor costs for Account 920 "A" and "O":

Account 920 "A" $1.080 million³⁸²

Account 920 "O" (gross) $9.801 million³⁸³

E. SDG&E Account 920 "B" A&G Salaries - Incentive Compensation Plan and Spot Cash Awards

For SDG&E, this account includes the costs of both incentive compensation and spot cash awards. As previously discussed, we decline to make any adjustments to disallow 50% of incentive compensation. We adopt the forecast salaries including at-target incentives as discussed in this decision and the revenue requirement component for all compensation is subject to the TLCBA.

F. SDG&E Account 920 - "C" Environmental Services

ORA proposed an adjustment based on SDG&E's 2002 actual cost being lower than 2002 forecast. As we have discussed before on forecast method issues, we will not readjust for minor recorded effects when we are forecasting from a 2001 base outward to 2004. The Joint SDG&E Comparison Exhibit shows a difference of $39,000 in labor costs. We will rely on the TLCBA to capture any savings and we will adopt the 2004 estimate of $1.133 million for Account 920 "C" (Gross).³⁸⁴

G. SoCalGas Account 921 - Administrative and General Non-Labor Expense

ORA proposed an adjustment for "non recurring, unusual and/or one-time expenditures" for $0.656 million in the 2001 base-year to derive Test Year 2004 non-labor costs. $0.110 million was identified by ORA from SoCalGas-prepared workpapers as membership dues, donations and contributions, which SoCalGas argues are reasonable expenses, and ORA relied on D.96-01-011 to recommend disallowance of these types of expenses. With no further discussion necessary, we will adopt the continued disallowance of these costs as they are unlikely to be relevant and necessary to provide safe and reliable service.

ORA proposed to disallow a further $0.298 million for temporary labor help, and in rebuttal, SoCalGas argues ORA was wrong to do so, misidentifying the costs as outside consultants.³⁸⁵ While it is true that Ex. 301 is extremely short on details and justification, the temporary help needs should have been addressed in funding the company's justifiable vacant and new positions in the functional accounts, including Account 920, and we will make this adjustment.

There are two other minor adjustments that SoCalGas disputes; $0.058 million in catering expenses, essentially lunch or dinner at meetings, mediation, arbitration, (again explained in rebuttal Ex. 77 and not explained in Ex. 301), and $0.047 million for employee recognition activities. We will not adopt either of the minor adjustments; if $58,000 can enhance productivity and $47,000 can enhance morale and productivity, we will allow these costs. This leaves $0.253 million that SoCalGas does not address in (rebuttal) Ex. 77 and ORA does not clearly identify as the "legal settlement" component in Ex. 301's description of the adjustment. We will adopt this residual adjustment not because of ORA's adjustment but because SoCalGas fails to carry its burden of proof to explain and justify its request. Thus, we adopt $5.122 million for Account 921 in Test Year 2004 ($5.485 million, less $0.110 million and $0.253 million).

H. SoCalGas Account 921.6 Administrative and General - Real Estate & Facilities

There is a $0.635 million difference between ORA's end-of-litigation position that is higher than SoCalGas' end-of-litigation position, because of a reduction in rebuttal Ex. 129. We will use the lower SoCalGas position in its results of operations spreadsheets. SoCalGas has also accepted a recommendation by TURN that the forecast for electricity costs from Edison should be reduced by $0.635 million based upon Edison's August 2003 rate reduction. We will not make a further reduction for $20,000 to reflect reduced energy costs at microwave towers.³⁸⁶ SoCalGas argued there is no assurance leasors would flow through any savings, and further, for this minor amount we will decline the adjustment as too granular. We adopt the end-of-litigation position, including TURN's one adjustment, of $12.454 million for the real estate portion of Account 921.6.

I. SDG&E Account 921 "A" and "F" - A & G Office Supplies & Expenses

After adjustments in its forecast to reflect a $2.178 million reduction related to ORA's review of recorded 2001 Base Year information, SDG&E requested $14.229 million. We accept the 2001 adjustment to the base without a need for further consideration. The following table reconciles the outstanding adjustments to show ORA's recommendation of $9.347 million. We will discuss the other adjustments below.

	Issue Area
	SDG&E Test Year 2004 Estimate	$14.229 million
	ORA Proposed Adjustments
1.	Audit Adjustment (Included by SDG&E)	2.178 million
2.	Controller's Dept.	0.577 million
3.	Human Resources	1.475 million
4.	Labor Relations	0.107 million
5.	Strategic Planning	0.610 million
6.	One-time, Unusual and/or non-recurring	0.563 million
7.	Long-Term Incentives	1.457 million
8.	Shared Assets Billings387	0.099 million
9.	Un-reconciled differences	0.006 million
	Adopted Changes
	Human Resources	$0.887 million

1. SDG&E Controller's Department (2)

ORA proposed that outside consulting costs should be expected to decrease based upon approving a staffing increase - which were due to the new provisions of the Sarbanes-Oxley Act - and ORA concluded that more staff would reduce SDG&E's reliance on outside services and consultants. ORA also argued that SDG&E did not provide documentation to justify training needs.³⁸⁸ ORA reduced the account by $0.577 million for 2004. In rebuttal, SDG&E argued that this would not allow for training to comply with the Sarbanes-Oxley Act. ORA's proposal is so brief that we cannot assess the basis of its recommendation; much of ORA's testimony is far too vague and fails to include an adequate description of the work performed or the logic of the conclusion and so we decline to make this adjustment.

We allowed SoCalGas and SDG&E the labor costs with the expectation of a significant workload under the Sarbanes-Oxley Act. We instructed both the applicants and ORA to look at the issue in greater detail and more explicit testimony in the next proceeding, so we find it necessary to allow the funding for training and consultants to use those employees well.

2. SDG&E Human Resources (3)

We decline to make ORA's $1.475 million adjustment for non-labor costs related to human resources. Again, ORA complained that they did not receive adequate justification, but ORA never raised a single discovery issue in the proceeding prior to serving testimony. It is not at all clear what ORA expected from SDG&E and ORA never provides an analysis of specific items and whether or not the costs should be recovered in rates. ORA did not, for example, appear to analyze the need for $1.196 million for "relocation and search fees" in 2001 but this cost appears to increase by $0.745 million for relocation and $0.055 million for search fees.³⁸⁹ ORA did not prepare an alternative estimate. We cannot arbitrarily delete portions of the request simply because they represent an increase. However, we find a combined $1.996 million for search and relocation costs in 2004 to be far too high in light of our rejection of the maturing workforce argument, and our concern that SDG&E (and SoCalGas) are unlikely to fill all vacant and new positions. We will reduce SDG&E's Test Year 2004 expense allowance by $0.800 million and we will also decline to nearly double the cost for pre-employment physicals and background checks ($98,000 in 2001 and an increase of $87,169 for 2004), again because we doubt the level of hiring proposed by the applicants will really occur.³⁹⁰

3. SDG&E Labor Relations (4)

Again, ORA made a proposal to reject $107,000 of "retained" expenses - which is never explained - and again, it complained about a lack of documentation. In rebuttal, SDG&E asserted that $85,000 is "driven" by: $30,000 needed for a Taft-Hartley Trust; $14,000 needed for training of new supervisors working in a union environment; $34,650 for arbitration fees; and $6,350 in other costs.³⁹¹ We find the discussion and justification for a disallowance unpersuasive. There is no evidence that SDG&E's request is excessive.

4. Strategic Planning (5)

SDG&E requested an increase of $0.650 million in non-labor costs, most of it, $0.575 million for outside labor (consultants) for research and modeling. In Ex. 72, SDG&E demonstrated that there were five new activities: gas resource planning, studying the distribution markets, studying the need for gas transmission and storage, renewable electric generation modeling, and studying rate stability with consumer focus groups, that total $0.575 million. The remaining $0.075 million is for equipment.³⁹² ORA argued increasing the size of the strategic planning departments should diminish the need for outside consultants. With no indication how it derived the amount, ORA would propose the account be decreased by $0.610 million; the difference appears to be allowing the costs of computers and other expenses for two new employees.

SDG&E pointed out that the costs in this account are allocated between SoCalGas and SDG&E and any adjustment should be split between both companies. SDG&E argues that the new positions cannot perform the analysis necessary as SDG&E resumes electric procurement following the failure of electric industry restructuring and the gas markets are facing fundamental strategic questions.³⁹³ We find that SDG&E has met its burden of proof for this expense estimate and we adopt SDG&E's forecast for 2004.

5. Long-Term Incentives (7)

We have rejected all adjustments to incentive compensation including the portion forecast in this account.

J. SDG&E Account 921 "C" Office Supplies & Expenses - Supplies Management

ORA proposed a $0.245 million adjustment by applying an adjustment for 2002 actual costs compared to 2002 forecast. We rejected all similar adjustments to rely on 2002 costs and we will not make an adjustment that does not demonstrate a linkage to the likely activity level in 2004.

³⁶⁴ "(F)or example, under Sarbanes-Oxley, there are analyses that are required that we simply didn't have to do previously as part of responding to requests from external auditors as they ask more questions about our calculations and our numbers before signing off on the corporate financials. So there are a lot more analyses of earnings and questions both to reply to questions from the external auditors and also to prepare others internally to respond to other requirements under Sarbanes-Oxley." (Tr., p. 373, lines 3-11.)

³⁶⁵ Ex. 73, pp. PJF-6 through PJF-8. Also, Sempra opening litigation brief, pp. 187-188 and 192, 194.

³⁶⁶ By making this finding, we neither express nor imply an opinion on whether shareholders and ratepayers were previously at significant risk for financial deception by Sempra, SoCalGas, or SDG&E management, only that, consistent with the requirements of the Sarbanes-Oxley Act, we intend to provide adequate resources to ensure compliance.

³⁶⁷ Sempra opening litigation brief, p. 194.

³⁶⁸ The Commission imposed a requirement on PG&E to simplify the spreadsheets before its next GRC, see D.00-07-050 dated July 20, 2000. "To maintain the integrity of the deliberative process, we believe that it is essential that Commission staff be able to understand and run PG&E's model without PG&E running the models for them. In addition, a user-friendly model will facilitate the Commission's ability to quickly calculate the revenue requirement for various decision scenarios... It is also important for a user-friendly model to minimize (or eliminate) the need to manually transfer data from one portion of the model to another. Said another way, the model should be as interactive as possible, with intermediate calculations being automatically forwarded to the next portion of the modeling process... " (Mimeo., p. 10-11.) (Footnote from the original quote.)

³⁶⁹ Sempra opening litigation brief, p. 186.

³⁷⁰ There are still differences in how the SoCalGas and SDG&E spreadsheets calculate several items, such as escalation on capital expenditures that should be eliminated.

³⁷¹ Ex. 149, SoCalGas Joint Comparison Exhibit, p. 84.

³⁷² Ex. 301, footnote 46, p. 8-36.

³⁷³ "This account shall include expenditures for the purpose of influencing public opinion with respect to the election or appointment of public officials, referenda, legislation, or ordinances (either with respect to the possible adoption of new referenda, legislation, or ordinances or repeal or modification of existing referenda, legislation or ordinances) or approval, modification, or revocation of franchises; or for the purpose of influencing the decisions of public officials, but shall not include such expenditures which are directly related to appearances before regulatory or other governmental bodies in connection with reporting utility's existing or proposed operations." Source: FERC Uniform System of Accounts, Account 426.4, a below-the-line account for lobbying expenses.

³⁷⁴ Ex. 66, beginning at p. FA-113; examples include (1) the Boston "Big Dig," $1.5 million of $6.0 million relocation costs were recovered, (2) Angora Hills off-ramp modifications, saved $0.015 million, (3) avoided $0.080 million of city required improvements in Compton, (4) recovered $2.5 million in Port of Long Beach Pier "S" relocation costs, and other un-quantified savings. SoCalGas did not provide the dates of the activities.

³⁷⁵ Attachment D - Joint Settlement Comparison Exhibit, p. 83. (An exact split of positions would have been $4.309 million.)

³⁷⁶ Ex. 3, beginning at p. FA-53.

³⁷⁷ UCAN opening litigation brief, p. 68.

³⁷⁸ Ex. 14, p. PJF-14.

³⁷⁹ Ex. 301, p. 14-16.

³⁸⁰ Ex. 302, p. 14-13.

³⁸¹ Pages 261 and 262.

³⁸² Account total request $1.105 million (Ex. 150, p. 94) less the $52,000 requested increase for Regional Public Affairs Labor (Ex. 27, p. DLG-123).

³⁸³ Account total request $10.056 million less the ORA $255,000 adjustment for Human Resources. (Ex. 150, p. 94.)

³⁸⁴ Ex. 150, p. 97.

³⁸⁵ Ex. 77, p. PJF-15.

³⁸⁶ See Sempra opening litigation brief, p. 182, and TURN Ex. 501, p. 29.

³⁸⁷ Ex. 150, p. 100, Issue 7: SDG&E states that its proposal is for $2,829,000 and ORA used $2,730,000 in its Results of Operations spreadsheets that equals a difference $99,000. Ex. 302, p. 10-21 used $2,860,000, which would be an increase of $130,000.

³⁸⁸ Ex. 302, p. 14-10.

³⁸⁹ Ex. 302, p. 14-13.

³⁹⁰ These costs are itemized, but not analyzed, by ORA in Ex. 302, p. 14-13.

³⁹¹ Ex. 72, p. PJF-16.

³⁹² Ex. 72, Attachment F, the response to ORA Data Request 61, Q. 7.

³⁹³ Ex. 72, pp. PJF 17 and PJF-18.