Resolution Template .gov



PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA AGENDA ID #16006ENERGY DIVISION RESOLUTION E-4880October 26, 2017 RESOLUTIONResolution E-4880. Approval for income-qualified customers who enroll in the Green Tariff Shared Renewables program to continue receiving the applicable California Alternative Rates for Energy or Family Electric Rate Assistance discounts.PROPOSED OUTCOME: Adopt Pacific Gas and Electric Company (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric’s (SDG&E) (collectively IOU) proposed tariff changes for the California Alternative Rates for Energy (CARE) and Family Electric Rate Assistance Program (FERA) discount for low-income customers who take service under the Green Tariff Shared Renewables (GTSR) rates pursuant to Decision (D.) 16-11-022 on CARE and Energy Savings Assistance (ESA) program applications.SAFETY CONSIDERATIONS:There is no impact on safety.ESTIMATED COST: There is no anticipated cost impact: for CARE and FERA-eligible customers, the IOU billing systems are already applying the GTSR charges as outlined in D.16-11-022.By Advice Letters PG&E 4976-E filed December 12, 2016, and Advice Letters SCE 3536-E, and SDG&E 3024-E, filed December 21, 2016.SummaryThis Resolution approves the proposals of PG&E, SCE, and SDG&E (“the IOUs”) to continue their current method of billing CARE and FERA-eligible customers who have also elected GTSR, which applies the full GTSR premium on top of the applicable CARE/FERA discount. This Resolution also directs the IOUs to begin implementing their targeted low-income outreach and communications plans as approved in Resolution E-4734.BackgroundAt the time GTSR Decision (D.)15-01-051 was adopted, the Commission was concurrently examining the CARE and ESA programs in another consolidated proceeding, Application (A.) 14-11-007: this CARE/ESA proceeding included a wide variety of stakeholders interested in the structure and funding of the CARE/FERA discount and the application of GTSR premiums for these customers. Consideration of how the GTSR premium would be calculated for CARE/FERA-eligible customers was taken up in in Ordering Paragraph 24 of D.15-01-051:The issue of how to apply the California Alternate Rates for Energy (CARE) discount to customers subscribing to the Green Tariff Shared Renewables program is referred to Application 14-11-007. Within 30 days of the issuance of a decision in Application 14-11-007 (CARE Decision), each of Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company shall each file Tier 3 Advice Letters as necessary to reflect the CARE Decision.This issue was extensively discussed in the CARE/ESA Proceeding, with notable contributions from PG&E, Marin Clean Energy, and The Utility Reform Network (TURN). Ultimately, the Commission ruled that low-income customers should continue to receive the full CARE/FERA discount on their non-generation rate, and that incremental GTSR charges should be added to the customer’s otherwise applicable rate. The advice letters approved in this Resolution affirm the direction set forth in the CARE/ESA Decision. NoticeNotice of ALs 4976-E, 3536-E, and 3024-E, were made by publication in the Commission’s Daily Calendar. PG&E, SCE, and SDG&E each state that a copy of the Advice Letter was mailed and distributed in accordance with Section 4 of General Order 96-B. ProtestsAdvice Letters PG&E 4976-E , SDG&E 3024-E, and SCE 3536-E were not protested.DiscussionThe IOUs’ Existing Methodology for Calculating the CARE Discount is Consistent with Commission Direction, and Ensures Parity with Other ProgramsD.16-11-022 ordered that the IOUs “calculate the discount a non-participating CARE customer would receive and then apply it to the total GTSR bill less the renewable premium on the generation rate.” This approach is consistent with how the IOUs were already calculating their bills. For CARE customers regardless of GTSR participation, the CARE discount is applied exclusively to non-generation rates only, which results in the same total discount being provided to a CARE customer regardless of whether they take service from an IOU, Community Choice Aggregator (CCA) or Electric Service Provider (ESP). This method also ensures that the IOUs maintain the nonparticipating ratepayer indifference required in SB 43 and codified in Public Utilities Code Sections 28314 to 2834. Therefore, the method proposed in these advice letters will not result in any substantive change to utility bills, rates, or billing systems.IOU Outreach to Low-Income and Vulnerable Customers In D.15-01-051, the Commission directed the IOUs to limit GTSR marketing efforts to CARE/FERA customers until the calculation of the GTSR-CARE and GTSR-FERA discounts were determined through the CARE/ESA proceeding. Preliminary marketing plans were discussed through each IOUs Customer Side Implementation Advice Letters (CSIALs), and implemented through Commission Resolution E-4734 on October 1, 2015.The Commission is bound by SB 43 to ensure that expenses, charges, and credits associated with GTSR are set to ensure non-participating ratepayer indifference. In practice, GTSR is a premium-price product, and therefore unattractive to most low-income customers who request rate assistance through CARE or FERA. Below is a table demonstrating each IOU’s 2016 system average rate and price premium for residential GTSR customers would pay in 2017 to enroll in the Green Tariff, in cents per kWh. In the last column is the number of CARE-Green Tariff customers enrolled in GTSR programs in 2016.IOUSystem Average Rate (?/kWh)GTSR Price Premium (?/kWh)CARE-GTSR EnrollmentsPG&E18.232.61200SCE14.903.7948SDG&E20.541.030SDG&E Should Launch its GTSR / Low-Income Communications PlanThe three IOUs noted in their CSIALs that they would begin targeted outreach and marketing to low-income and vulnerable customers according to direction from the CARE/ESA decision. SDG&E also specifically requests approval to move forward with direct marketing to the vulnerable and low-income segment in this advice letter. This request is granted.All IOUs are encouraged to implement, or continue implementing, their marketing plans to low-income and vulnerable customers as outlined in their mentsPublic Utilities Code section 311(g)(1) provides that this resolution must be served on all parties and subject to at least 30 days public review and comment prior to a vote of the Commission. Section 311(g)(2) provides that this 30-day period may be reduced or waived upon the stipulation of all parties in the proceeding.The 30-day comment period for the draft of this resolution was neither waived nor reduced. Accordingly, this draft resolution was mailed to parties for comments, and will be placed on the Commission's agenda no earlier than 30 days from today."FindingsOrdering Paragraph 24 of D.15-01-051 referred the issue of how to apply the CARE discount to customers subscribing to the GTSR program to A. 14-11-007, the CARE/ESA proceeding, which ordered the IOUs to continue applying the GTSR charge to the otherwise applicable CARE/FERA rate.PG&E’s AL 4976-E, SCE’s AL 3536-E, and SDG&E’s AL 3024-E are in compliance with the Commission’s order to incorporate the CARE discount into its GTSR program.While the IOUs are in compliance with the ratepayer indifference mandate of AB 43 and the PU Code, the program as implemented is unlikely to simultaneously achieve the legislation’s goal of expanding access to all eligible renewable energy resources to all ratepayers due to the relative affordability of GTSR as a premium price product.Therefore it is ordered that:The proposed tariff changes in Advice Letters PG&E 4976-E, SCE 3536-E, and SDG&E 3024-E are approved.SDG&E shall begin, and PG&E and SCE shall continue marketing GTSR to their vulnerable and low-income customers in accordance with the direction approved in Resolution E-4846. This Resolution is effective today.I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on September 28, 2017; the following Commissioners voting favorably thereon:_____________________TIMOTHY J. SULLIVAN Executive Director ................
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