VII. The Office of Ratepayer Advocates Comments

On November 5, 2004, the Office of Ratepayer Advocates (ORA) submitted comments on SCWC's Application. ORA states it has been reviewing SCWC's progress in developing the Application, and agrees that a rate increase, at the level requested, is necessary to recover the costs of the BVES generating facility. ORA also supports SCWC's request for the two one-way memorandum accounts, the use of caps on costs, and a future review to determine the reasonableness of all generator facility costs.

ORA states that it participated in discussions with BVES during the formulation of the cost allocation process, and had input to SCWC's proposed rate design. ORA agrees with the three principles used by SCWC in rate design, and with the priority SCWC used in applying these principles to its proposed rate design. ORA states it finds SCWC's proposed allocation of costs and rate design rational, and that the resulting rates are fair, just and reasonable for all customer classes.

In ORA's opinion there are no unresolved factual disputes associated with the Application, and therefore no need for a hearing.