DRAFT

Pacific Gas & Electric Company
Comments on Proposed Changes to Rate Case Plan

PG&E agrees with comments of many of the participants in the Unbundling Scoping Workshop that in light of electric restructuring, the Commission's Rate Case Plan requires revision. PG&E notes that each of the three California investor owned utilities is in a different phase of the restructuring process with regard to Performance Based Ratemaking: SDG&E has an approved PBR in place; Southern California Edison has litigated its PBR and is waiting for a final decision; and PG&E will file its PBR Application on July 15 of this year. While it is desirable that all utilities be under the same Rate Case Plan after restructuring, in the transitional phase, each utility requires its own unique adjustment to the RCP to reflect is particular stage in the new ratemaking process.

PG&E expects that the following filings covered by the RCP will continue until electric restructuring and PBRs are fully in place.

As directed by the RCP, PG&E will file its 1998 ECAC Forecast/Reasonableness Application on April 1, 1997. PG&E may file a 1997 Rate Design Window Application on November 20, 1996. For PG&E, this is an optional filing. The company might also make a 1998 RDW Application as well. PG&E will file its 1999 ECAC Forecast/1997 Reasonableness Application on April 1, 1998.

PG&E expects that the following filings now in the RCP may change as a result of electric restructuring and PBRs.

If PG&E's PBR application is not approved by May 8, 1997, the RCP date for its cost of capital filing, the company will file a 1998 Cost of Capital Application. Similarly, if PG&E's PBR has not been approved by June 30, 1997, the date set out in the Roadmap Decision, PG&E will file a 1999 GRC NOI in July of 1997. PG&E must make a Phase I 1999 GRC Application if it appears possible that a PBR will not be in place before January 1, 1999.

Proposed Rate Case Plan Changes

As stated above, because each California utility is in a different stage of electric restructuring, the Commission should make changes to the Rate Case Plan that apply on a utility-specific basis. Where appropriate, suspension of some proceedings will result in a more efficient use of scarce resources. Given PG&E's particular stage of transition, no change in the RCP is necessary at this time.