FYI--Greg Klatt will participate in the Meet and Confer meeting on Tuesday in regard to the procedural schedule.  gh

 -----Original Message-----
From: 	"Dan Douglass" <douglass@energyattorney.com>@ENRON  
Sent:	Thursday, January 17, 2002 7:15 PM
To:	Rapp, Bill; Hass, Glen; Harris, Steven; Kilmer III, Robert
Cc:	Gregg Klatt
Subject:	SoCalGas/SDG&E BCAPs -- ALJ Brown Denies EGA Motion to Strike


ALJ Brown denied the EGA motion to strike, so testimony on both the  embedded cost-based and the long-run marginal cost-based (LRMC) methodologies  for revenue allocation among customer classes will be allowed in this  proceeding.   Attached is a copy of  her ruling.  Her primary rationale is expressed on page 6, as  follows:
".....the Commission has frequently  deviated from cost allocations based solely on LRMC, and has been moving  towards embedded costs for unbundled transmission and storage functions, as  evidenced in both the recent decision in the GIR, and in the Gas Accord for  PG&E.  Therefore, it is  apparent that the Commission is interested in comparing LRMC and embedded cost  for cost allocation purposes.  For  this reason, EGA's motion to strike testimony on embedded cost-based  allocation is denied.  Testimony  on embedded costs will be compared with the testimony on LRMC, to enable  parties and the Commission to determine which method, or combination of  methods, is most appropriate for allocation among customers of each utilities'  non-gas costs of service.   Including an embedded cost analysis in this BCAP might require more  work from all the parties, but the record will then be as complete as possible  so that the Commission can make a well-informed  decision."
She also ruled that, "The  evidentiary hearing schedule of May 21 through June 14, 2002, is not suspended  at this time.  No later than January  22, 2002, parties are to meet and confer to determine if a shift in the filing  dates for testimony will be sufficient to meet the needs of the parties' to  respond to the March amendments to Biennial Cost Allocation Proceeding  applications, and keep the established hearing schedule."
Dan
 
Law Offices of Daniel W. Douglass
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 - CPUC01-#114281-v1-A0109024_A0110005_Brown_Ruling_ (1).doc