Parties Filed Comments on Fourth Amended Scoping Memo

The following is a brief snapshot of party comments and full comments can be found in the link below:

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Cal Advocates:

• Cal Advocates supports the inclusion of a rate and bill impact tracking tool for Class A Water Utilities in Phase 2, as previously determined in the Third Amended Scoping Memo. A rate and bill impact tracking tool for Class A Water Utilities will provide the Commission a transparent view of the cumulative impact of rate increases across proceedings and advice letter filings.
• In advance of the November 15, 2021, Workshop, the Commission should develop a clearly defined agenda to ensure the appropriate experts attend and sufficient time is provided to discuss all crucial implementation issues at the Workshop.
• Cal Advocates supports the Commission’s general goal of considering a wide variety of strategies to address the quick and large increases in residential and small commercial customer rates. The Commission should also focus on the impact of the combination and numerosity of utility applications seeking cost recovery for new and diverse utility programs, so that affordability gains the Commission attains in one program are not usurped by another utility application.
• The Commission should focus primarily on reducing the aggregate level of cumulative rate increases across disparate proceedings and Advice Letter filings, in Phase 3.
• Finally, the Commission should keep in mind that approval of a wide variety of utility service programs has led to large increases in residential and small commercial customer rates in recent years, as a means of recovering the IOU’s rapidly increasing costs.
• Phase 3 should not include strategies to mitigate future increases in natural gas costs and bills. These strategies are more appropriately addressed in the Gas Transition Rulemaking.

Joint CCAs:

• Joint CCAs recommend that the Commission apply the Affordability metrics to proceedings that affect revenue requirements and total bills such as Resource Adequacy and Integrated Resource Planning to identify affordability root causes.
• Joint CCAs recommend that the Commission apply the Affordability metrics to past proceedings and Decisions, investigating historical impacts of increased costs.
• Joint CCAs recommend that the Commission supplement the three Affordability metrics with qualitative data from communities most impacted by increased cost trends.
• Joint CCAs recommend that the Commission incorporate learnings from programs that impact rate design and energy efficiency programs in Phase 3 of the proceeding.
• Joint CCAs recommend that the Commission explore the proposal to shift program funds from a regressive ratepayer model to taxpayers.

Joint IOUs:

• The joint utilities recommend that the Commission consider Gas Affordability in Order Instituting Rulemaking to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and Perform Long-Term Gas System Planning (R.20-01-007).