[2] Additionally, we have the contradiction that DSM costs are assigned to generation for purposes of Edison’s non-generation PBR, but SDG&E assigns them as non-generation costs in its filing. DSM and RD&D should in fact be assigned largely as public purpose costs for all utilities, as PG&E has done.

[3] Some utilities include the function of turning service on or off as customers move in Account 586. Others include this function in Account 587 where it would be captured as a “wires” cost. This specific function is likely to be a “wires” function, regardless of where it is accounted for.

[4] Material from such a presentation to Los Angeles County was introduced into evidence as an attachment to the testimony of Michel Peter Florio on behalf of TURN (Exhibit II-107) in A. 93-12-025 (Edison GRC Phase 2B, flexible pricing)

[5] There are extremely great privacy concerns with dissemination of this information to anyone, but for the purposes of this testimony, we assume that the customer has given consent for the information to be provided, and are examining only cost issues.

⁶ PG&E also proposes that its captive wires customers pay all of the salary of the President that is not allocated to Diablo Canyon or PG&E Enterprises now, except for a pittance allocated to transmission and public purpose programs. There will be no salary allocation to generation which PG&E does not divest, and no recognition that PG&E’s executive compensation paid by ratepayers may have some relationship to the size of the company managed by the executive.

[7] We are also assuming that absent poor management, administrative costs should not significantly rise as a fraction of the Company’s size.

[8] Because of the provisions of the SONGS and Palo Verde settlements adopted by the Commission and the Diablo Canyon allocation methodology, costs that would be otherwise allocated to nuclear plants (beyond those costs currently included in ICIP pricing) should remain with the distribution utility through the end of the nuclear settlements.

[9] While TURN and UCAN believe that the actual implementation of unbundling line extension allowances will occur in the Commission’s current line extension rulemaking (R. 92-03-050), we believe it is necessary and appropriate to raise the issue in this proceeding, since it is this proceeding where the unbundling of utility rates is to be heard.

[10] Load dispatching costs are 9.84% of adopted transmission costs in the General Rate Case. We reduced A&G costs and general plant costs (except vehicles) by 9.84% to reflect load dispatching costs.

¹¹ The $2.9 million total shown on page 41 of the decision is allocated 55% to the electric department and 45% to the gas department using PG&E’s customer accounts allocation factors.

[12] The CARE program (formerly known as low-income rate assistance (LIRA)) program provides a 15% reduction in the rates of low-income residential customers.

[13] TURN Data Request 2-4(a) in A. 94-12-005, Phase 2, cited in Mr. Marcus’ prepared direct testimony (Ex. 350, p. 16).

[14] Both of these departments directly allocate time to Diablo Canyon. This casts even more doubt on PG&E’s contention that they do nothing related to PG&E’s regulated generation.

[15] Our escalation method was simpler than SDG&E’s because we did not have the account-by-account breakdown into labor and non-labor expenses used by the Company. We simply escalated everything at the same rate.

[16] If, on the other hand, Edison’s real agenda is the abolition of baseline rates, then TURN believes that Edison should take that position in a straightforward manner, so that parties can respond accordingly.