3. Rate Case Plan
SCWC's general rate case (GRC) application for its Region III is made pursuant to the new three-year GRC cycle requirements for Class A water utilities set forth in § 455.23 and implemented by the Commission under its new rate case plan in D.04-06-018.4 The plan provides for each utility to file a GRC application every three years, complete with specified documentation and supporting material, and for the Commission to process each application under a 12-month schedule. For the 2005 transitional first year filings under the plan, D.04-06-018 adopted an expedited schedule, allowing a February 1 rather than January 1 filing date while retaining a projected completion date by the end of the calendar year; SCWC's Region III is included in the February 2005 filing schedule. Thus, this GRC application was scheduled to be processed in 11 months, rather than 12, so Commission staff could start work punctually on the next GRCs in the cycle. At the prehearing conference, the Assigned Commissioner indicated that completing this case in a "timely fashion" would be a high priority.
Adhering to the 11-month schedule for processing this GRC has been challenging primarily due to SCWC's failure to present issues and evidence early in the process. The critical first step in the GRC process is the utility presenting a complete application with all significant issues clearly identified and supporting evidence included. However, this GRC is SCWC's first experience with the new rate case plan, which places new and exacting obligations on the utility, ORA, and principal hearing officer. To the extent this GRC was a learning experience, we hope it was a successful one.
As well, we note that under the plan, ORA is responsible for reviewing the proposed application of each utility and identifying all deficiencies, which the utility must remedy prior to the application being accepted for filing. In the case of SCWC's proposed application, ORA did not take the opportunity to point out obvious deficiencies, e.g., SCWC's list of most significant cost increases not corresponding to the total requested increase, the lack of justification for the unprecedented amount of construction work in progress to be added to rate base, and the absence of any testimony on the prudency of the Calipatria Niland Upgrade project.
3 All citations are to the Public Utilities Code unless otherwise indicated.
4 Class A utilities are investor owned water utilities with greater than 10,000 service connections. All Section (§) references are to the Public Utilities Code.
