SDG&E's reply addresses the several protests and responses to its Application to implement TOU-ELEC. The reply maintains that the scope of the proceeding should be limited to the whether the proposed rate comports with the directives in the authorizing decisions, and whether it follows rate design principles.
SDG&E maintains that the scope of this proceeding should be limited to the directives set in D. 20-03-003 and D. 21-07-010 and whether the rate aligns with the Commission’s rate design principles. In the two decisions, the Commission ordered SDG&E to propose, by September 1, 2021, an opt-in, un-tiered, residential time-of-use rate with a fixed charge available to residential customers charging an electric vehicle, utilizing energy storage, or employing electric heat pumps for water heating or climate control. SDG&E’s reply dismisses several party proposals as out of scope with this narrow directive, and argues that concerns are better addressed in SDG&E’s next GRC.
SDG&E also argues that the Joint CCAs’ concerns about customer eligibility and CCA right to set rates are unfounded since the fixed charge only recovers distribution costs and would be the same for bundled and unbundled customers. This response does not address the CCAs’ concerns about the Application’s vague language concerning verification of eligibility and potential impact on NEM customers. The Reply also clarifies that SDG&E’s campaign promoting the rate would exclude outreach to CCA customers.
