Utility cost recovery process

Currently, the utility cost recovery process varies between utilities (and, in some cases, between different business units of the same utility, such as distribution and transmission) and the types of costs and proceedings at issue. For example, some utilities file cost claims under Rule 022 to recover certain external legal and consulting costs whereas others do not. Some utilities maintain hearing cost reserve accounts whereas others do not. As part of this consultation, the Commission asks each gas and electric utility (or each regulated business unit of a utility, if there is more than one and the practice varies between business units), default supply provider and regulated rate provider to summarize how it recovers the various costs (internal staff, external legal and consulting, disbursements, etc.) of rates proceedings. 

1. Should the Commission establish a uniform requirement for how all utilities, regulated rate and default supply providers recover their costs in rates proceedings? 
2. If so, should utilities, regulated rate and default supply providers seeking to recover external legal and consulting costs always be required to file a cost claim under Rule 022? For example, should a cost order be a mandatory pre‑requisite to record any such costs in a hearing reserve or otherwise include those costs in a utility’s tariff or rates? Why or why not?
3. If utilities, regulated rate and default supply providers are not required to file cost claims under Rule 022 before seeking to recover these costs from ratepayers, please explain how these costs should be recorded and how the Commission can ensure these amounts are just and reasonable.