Details for: SCE's Reply to DACC's Protest of Advice 4309-E-A.pdf

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Shinjini C. Menon.
Managing Director, State Regulatory Operations

September 10, 2021
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Southern California Edison Company’s Reply to the Protest of the Direct
Access Customer Coalition to Advice 4309-E-A

Dear Energy Division Tariff Unit:
In accordance with General Rule 7.4.3 of General Order (GO) 96-B, Southern California
Edison Company (SCE) hereby replies to the protest of the Direct Access Customer
Coalition (DACC) to SCE’s Advice 4309-E-A.
On August 13, 2021, SCE submitted Supplemental Advice 4309-E-A, which
supplemented in part SCE’s original Advice 4309-E establishing protocols to administer
SCE’s Power Charge Indifference Adjustment (PCIA) prepayment requests and
negotiations, as required by Decision (D.) 20-08-004.1
On September 2, 2021, DACC filed a timely protest to Advice 4309-E-A.2
I. SCE’s Response to DACC’s Protest
DACC recommends that SCE “issue a revised advice letter that separates out its
estimated common costs of negotiations (e.g., development of a PCIA forecasting
model), identifies those costs in a revised advice letter, and collects no more than 10%
of those common negotiating cost from any prepayer.”3 While SCE acknowledges
DACC’s concern about a potential “first mover” problem for PCIA pre-payment
negotiations, DACC’s proposal is inconsistent with D.20-08-004 and the broader
statutory framework prohibiting customer cost-shifting. For example, if fewer than 10
potential pre-paying DA customers expressed interest in negotiations – which SCE
believes to be a realistic if not a likely possibility -- then DACC’s proposal would lead to

D.20-08-004 was issued on August 12, 2020.
On September 9, 2021, DACC filed a corrected Protest to Advice 4309-E-A that did not
change the substance of the arguments addressed herein.
DACC Protest at p. 3.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-3377

Fax (626) 302-6396


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Energy Division California Public Utilities Commission September 10, 2021 Page 2 stranded costs that would then be shifted back to all non-pre-paying customers, bundled service and departing load alike. Finally, SCE notes that in Advice 4309-E-A, SCE provided a range of estimated costs showing potential variation of total costs “depending, in part, on the number of customers seeking prepayment.”4 Any “common costs,” as DACC puts it, can and will be equitably allocated among the total number of pre-payers depending on the number of counterparties, but setting an artificial cap of 10% of recovery of such costs for each individual pre-payer would violate the statute. II. Conclusion SCE appreciates the opportunity to submit this reply to DACC’s protest. Southern California Edison Company /s/ Shinjini C. Menon Shinjini C. Menon SCM:rf:jm cc: Edward Randolph, Director, CPUC Energy Division Daniel W. Douglass, DACC Service Lists SCE’s GO 96-B and R.17-06-026 4 Advice 4309-E-A at p. 4.
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