Details for: SCE's Comments on Draft Resolution E-5131 (4280e).pdf


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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

March 30, 2021
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
Re:

Comments on Resolution E-5131: Request by Pacific Gas and
Electric Company, Southern California Edison Company, and
San Diego Gas & Electric Company to modify bundled customer
bills to show a Power Charge Indifference Adjustment (PCIA)
line item in compliance with Decision 20-03-019

Dear Energy Division Tariff Unit,
In response to Draft Resolution E-5131, issued on March 10, 2021, Southern California
Edison Company (SCE) respectfully submits these comments.
SCE supports the Draft Resolution, which would approve with modifications the joint
proposal by Pacific Gas and Electric Company (PG&E), SCE, and San Diego Gas &
Electric Company (SDG&E) (collectively, the Investor-Owned Utilities (IOUs)) to implement
bill presentation and tariff modifications to show a PCIA line item on all customer bills, in
compliance with D.20-03-019. SCE agrees that the Draft Resolution’s proposed language
changes to the PCIA definition on customer bills represent an improvement compared to
what the IOUs originally proposed. SCE believes, however, that the draft language should
be further amended to additionally facilitate customer clarity and understanding of what the
PCIA is, and to more closely track the purpose of the PCIA and how it operates. Below,
SCE sets forth proposed revisions to the draft language for the Commission’s
consideration.
Original Language Proposed by the IOUs:
“An amount to recover the above-market portion of [Utility’s] electric generation portfolio.”1
Draft Resolution Proposed Language:
“The PCIA is a charge to ensure that both [utility] customers and those who have left
[utility] service to purchase electricity from other providers pay the above market costs for
generation resources that were procured by [utility] on their behalf. ‘Above market’ refers

1

Draft Resolution at p. 4.

P.O. Box 800 8631 Rush Street Rosemead, California 91770 (626) 302-9645 Fax (626) 302-6396





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Energy Division Tariff Unit March 30, 2021 Page 2 to expenditures for electric generation resources that cannot be fully recovered through sales of these resources at current market prices.”2 SCE Proposed Clarifying Language “The PCIA is a charge to ensure that both [utility] customers and those who have left [utility] service to purchase electricity from other providers pay the above market costs for generation resources that were procured by [utility] on their behalf. ‘Above market’ refers to the difference between what the utility pays expenditures for electric generation resources and that cannot be fully recovered through sales of these resources at current market prices for the sale of those resources.” SCE respectfully believes its proposed clarifying language is both simpler for customers to understand and more accurately comports with the purpose and structure of the PCIA.3 SCE appreciates the opportunity to submit these Comments for the Commission’s consideration. Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:ra/ep:jm cc: Edward Randolph, Director, CPUC Energy Division Alexander Cole, CPUC Energy Division Dina Mackin, CPUC Energy Division Service List R.17-06-026 Service List for Draft Resolution E-5131 2 3 Draft Resolution at p. 8. If the Commission accepts SCE’s proposed clarifying language regarding the PCIA definition, SCE will also conform the language in its relevant tariff accordingly.
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