On October 19, 2022, San Diego Gas & Electric ("SDG&E") submitted Opening Comments in response to the Commission's Proposed Decision ("PD") issued on September 29, 2022. In these comments, SDG&E disagrees with the Commission that the flat-rate of $16 per month will advance the Commission’s electrification goals and accomplish a significant reduction in greenhouse gas (“GHG”) emissions. SDG&E suggests reconsideration of this rate and/or expansion of EV-TOU-5 to other electrification technologies.
In its Opening Comments on the Commission's September 29 PD, SDG&E argues that there is no evidence to support that the $16/month fixed charge proposed in the PD will create a meaningful reduction in volumetric rates such that it will incent beneficial electrification. SDG&E defends its proposed rate structure, stating that contrary to the PD's assertions, it does incentivize customers to shift load to off-peak hours through its commodity rates. SDG&E further argues that a new electrification rate with a very similar rate design to SDG&E’s EV-TOU-5 rate will potentially cause significant confusion for customers. According to SDGE's comments, if approved, both EV-TOU-5 and TOU-ELEC rates will have $16 fixed charges despite differing in TOU differentials and eligibility.
SDG&E claims that because TOU-ELEC was proposed prior to R.22-07-005 (Demand Flexibility), which will involve a more comprehensive review of rates for equity and to incent electrification for all customers, an opt-in electrification rate will likely soon be obsolete. As a result, SDG&E has now changed its position and argues that in lieu of implementing a TOU-ELEC rates, the Commission should consider expanding eligibility for EV-TOU-5 to heat pumps and energy storage, with the same eligibility cap of 10,000 as proposed in the PD.
In response to Ordering Paragraph (OP) 5 of the PD, which states that SDG&E “shall file a Tier 1 advice letter every 12 months, starting 12 months after the tariff first become available, and include the data requirements listed in Section 6.6 of this decision," SDG&E requests that this requirement be modified to allow SDG&E to seek permission, via a Tier 2 AL, to eliminate the reporting requirement after 5 years from the date of implementation.
