OPINION
I. Summary
II. Background
III. Phase II Issues
A. Policy Considerations
B. Avoided Costs vs. Fully-Allocated Costs
1. SDG&E's Methodology
2. Billing Offsets to Credits to Account for Implementation Costs
3. Working Cash
4. Uncollectibles
5. Segmenting Customer Groups By Rate Schedule
6. Full and Partial ESP Consolidated Billing
7. Meter Ownership Credits
8. Meter Reading Supervision Costs as Semi-variable
9. Market Penetration Assumptions
C. Updates to Adopted Credits
D. Ratemaking Effects
IV. Issues Identified in D.98-07-032 for Final Resolution in Phase II
A. New Meter Installations
B. Gas Meter Reading Credits
C. De-Averaging Credits by Geographic Areas
V. Conclusion
VI. Findings of Fact
II. Conclusions of Law
ORDER
