Timely comments on both the ALJ proposed decision and the alternate proposed decision were filed by PG&E, Edison, SDG&E, ORA, TURN et al., CUE, Farm Bureau, CIU et al. and EPUC/CAC. The City and County of San Francisco and the City of San Diego’s Metropolitan Wastewater Department also filed comments, along with motions to intervene. Timely reply comments were filed by PG&E, Edison, SDG&E, ORA, TURN et al., and the City and County of San Francisco. We have incorporated these comments as appropriate, which were particularly helpful in regards to technical clarification necessary to implement the Commission’s findings. We emphasize that in accordance with Rule 77.3, comments which merely reargue positions taken in briefs are accorded no weight. Furthermore, Rule 77.4 provides that comments are not to include new factual information which has not been tested by cross-examination. Such comments will not be relied on as the basis for assertions made in post publication comments.
The comments have addressed several issues, including the following areas: definition of current costs, clarifying the deferral of costs, clarifying the 1999 transition cost proceeding, clarifying exemptions, and addressing the provisions of § 369. We have addressed these issues throughout the decision, as appropriate.