This excerpt taken from the PCG 8-K filed Oct 28, 2005.
Based on an evaluation of PG&E Corporations and Pacific Gas and Electric Companys, or the Utilitys, disclosure controls and procedures as of March 31, 2005, PG&E Corporations and the Utilitys respective principal executive officers and principal financial officers have concluded that such controls and procedures are effective to ensure that information required to be disclosed by PG&E Corporation and the Utility in reports the companies file or submit under the Securities and Exchange Act of 1934 is recorded, processed, summarized, and reported within the time periods specified in the Securities and Exchange Commission rules and forms.
As of January 1, 2004, PG&E Corporation and the Utility adopted Financial Accounting Standards Board, or FASB, revision to FASB Interpretation No. 46, Consolidation of Variable Interest Entities, or FIN 46R. In accordance with FIN 46R, the Utility consolidated the assets, liabilities and non-controlling interests of low-income housing partnerships that were determined to be variable interest entities, or VIEs, under FIN 46R. PG&E Corporation and the Utility do not have the legal right or authority to assess the internal controls of VIEs. Therefore, PG&E Corporations and the Utilitys evaluation of disclosure controls and procedures performed as of March 31, 2005 did not include these entities in that evaluation. PG&E
Corporation and the Utility have not designed, established, or maintained disclosure controls and procedures for consolidated VIEs.
There were no changes in internal controls over financial reporting that occurred during the quarter ended March 31, 2005, that have materially affected, or are reasonably likely to materially affect, PG&E Corporations or the Utilitys internal controls over financial reporting.