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17. Toward Utility Rate Normalization,
44 Cal. 3d 870 (1988), 750 P.2d 787.
The Court affirmed a Commission decision which authorized interim rate increases for PG&E pursuant to its major additions adjustment clause (“MAAC”). The Commission authorized the rate increase prior to reaching a final determination on the prudence of PG&E’s investment in the plant. TURN asserted that the Commission could award interim rate relief only where (1) such relief was required to forestall a financial emergency or (2) the cost basis for the relief was beyond dispute. The Court, without really fixing the parameters of the Commission’s authority to provide interim relief, found that the Commission had the discretion to order it here as a means of insuring that present and future ratepayers fairly shared in recovering PG&E’s costs. Future disputes related to interim relief may turn on what is “required by law” (See Para. 3 supra) before any order is issued.