PUBLIC COUNSEL'S STATEMENT OF POSITION
l of its witnesses and exhibits, on the same date that such application, petition, or statement of intent to change its rates is filed with the commission. 7. OPC's position is that the COCJ&Y charge for the SUS rate violates PUC Rule 23.2...
AI summary The OPC argues that the COCJ&Y charge for the SUS rate violates PUC Rule 23.23 and PURA by allowing monthly fuel rate changes without a hearing. The Company suggests a 'good cause' exception, but OPC notes this would set a precedent with broad implications. The examiners previously rejected a similar exception in Docket 6765, emphasizing the need for rulemaking over adjudicatory hearings for such policy changes.