Comments on Draft Decision

The draft decision of the ALJ in this matter was mailed to the parties in accordance with Section 311(g) of the Public Utilities Code and Rule 77.7 of the Rules of Practice and Procedure.

Findings of Fact

1. ORA has recommended a rate base adjustment of $10.5 million based upon its conclusion that M&S inventory balances were overstated.

2. PG&E contests ORA's analysis and recommendations in the SAP Report, but PG&E cannot say that ORA's assertions regarding M&S inventory balances are totally without merit.

3. If it is later found that PG&E's currently authorized revenue requirements associated with M&S inventory balances are excessive, then ratepayers could be made responsible for such excessive revenue requirements for an extended period of time unless we act now to make such revenue requirements subject to reduction.

Conclusion of Law

PG&E's authorized revenue requirements associated with M&S inventory balances should be made subject to reduction, and related gas rates subject to refund, effective today.

ORDER

IT IS ORDERED that:

1. Pacific Gas and Electric Company's (PG&E's) authorized gas and electric revenue requirements associated with Materials and Supplies (M&S) inventory balances are hereby made subject to reduction, and related gas rates made subject to refund, effective today.

2. PG&E shall establish a memorandum account for the purpose of tracking the revenue requirements associated with the Office of Ratepayer Advocates' (ORA) recommended rate base adjustment for M&S inventory balances. The memorandum account shall remain in effect pending the outcome of the investigation by PG&E and ORA into M&S balances, and a final decision of the Commission on this issue. All revenue requirements included in such memorandum account shall receive the published commercial paper interest

rates applicable to PG&E's balancing accounts in the event of an ordered reduction in revenue requirements.

This order is effective today.

Dated , at San Francisco, California.

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