-----Original Message-----
From: Dan Douglass [mailto:douglass@energyattorney.com]
Sent: Tuesday, September 11, 2001 10:46 PM
To: ARM; Vicki Sandler; Tamara Johnson; Mara, Susan; Steve Huhman; Roger Pelote; Rob Nichol; Randy Hickok; Nam Nguyen; Jim Crossen; Dasovich, Jeff; Janie Mollon; Jack Pigott; Greg Blue; George Vaughn; Gary Ackerman; Ed Cazalet; Denice Cazalet Purdum; Curtis Kebler; Curt Hatton; Corby Gardiner; Charles Miessner; Carolyn Baker; Bill Ross; Karen Shea; Max Bulk
Subject: EPUC Comments re DWR Decision


Attached are EPUC's comments opposing the draft decision.  They argue that, "The DD implicitly overstates the Commission's obligation under these provisions and, consequently, risks the public interest.  While the Commission must assure recovery of the costs incurred by DWR, the statute does not require the Commission to assure full recovery of a fixed value in the face of variable assumptions.  Failing to address these variables could lead to unnecessary rate increases and further injury to the state's economy.  Moreover, while the Commission must adopt a "stop gap" allocation of DWR costs among utilities to determine who will make the payments, there is statutory requirement or practical  need for a final, absolute allocation to be adopted before a more careful examination can be made."
 
EPUC concludes by saying that it, "urges the Commission to tailor narrowly its decision adopting a DWR revenue requirement.  The Commission should adopt a mechanism, as described herein, that would limit or eliminate the difference between DWR actual costs and utility remittances.  The Commission should also adopt only an interim inter-utility allocation, to be reconciled with a final methodology pending a careful and thorough examination of cost responsibility."
 
Dan
 
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