SDCP and CEA Filed a Joint Response to SDG&E's Untiered TOU Application
While the CCAs are supportive of efforts to incentivize residential electrification, questions remain about SDG&E’s proposal related to rate design and customer eligibility. To answer these questions, the CCA parties request party status and plan to conduct discovery, participate in hearings should they be necessary, and submit testimony, comments and briefs.
The CCAs' Response notes that the Application and supporting testimony raise questions about customer eligibility, especially as it relates to CCA and NEM customers and rate design. Since the new rate design departs from volumetric rates, the parties argue that the Application must be scrutinized carefully to ensure that the new rate achieves its intended purpose, does not impose additional costs on non-participating customers, and is consistent with applicable law and Commission decisions.
Customer Eligibility
SDG&E envisions that TOU-ELEC will be available to customers based on ownership of certain technology, namely, an electric vehicle, an energy storage system, or a heat pump. Eligibility would be determined based on self-reporting, but the testimony does not propose any definitions or criteria for the technology and does not include any means of verifying that a customer owns or is using the technology in question.
SDG&E’s proposal to make TOU-ELEC available to CCA and NEM customers also raises important questions about customer eligibility. One concern is that the Application and supporting testimony do not fully address whether making TOU-ELEC available to CCA customers is consistent with applicable law and rules.
Like CCA customers, NEM customers are also subject to rules and existing tariffs that may conflict with certain provisions of TOU-ELEC as proposed. SDG&E’s proposal needs further development in this regard. Coordination with the ongoing NEM proceeding, where new rules for rooftop solar owners are currently being developed, may be necessary to ensure that NEM customers are eligible and able to participate in TOU-ELEC, and that, for example, there are no conflicting rules or directives that would prevent the rate from being offered, make it impractical or render it excessively costly.
Rate Design
Whether SDG&E’s fixed charge accurately reflects distribution costs – and distribution costs alone – is a key question that must be resolved.
Whether CCA programs, who must factor the Power Charge Indifference Adjustment (“PCIA”) into their rates, can offer meaningful and competitive commodity service in conjunction with the fixed charge is another important question that needs to be addressed.
The CCA Parties also plan to investigate how the fixed charge was modeled and created, and related, the rate exposure that participating customers are likely to face.
