SDG&E’s PCIA Trigger Application: Alliance Comments (October 2020)

Following the Protest, all Parties in proceeding A20-07-009 file comments explaining their position. Among points made by the Alliance:

  • Several rules in the controversial 2018 “Peterman Decision” that changed PCIA mechanisms were faulty in their design and application, exacerbating the very conditions the CPUC sought to avoid;
  • Any representation of SDG&E’s “under-collected PCIA balances” should be subject to discovery in this case (discovery was disallowed);
  • Collection of $8.92 million from the small numbers of Solana Energy Alliance customers over three months would lead to unconscionably high rate impacts, sufficiently unfair as to be unjust.
  • Finally, the Alliance asked Why Now? – Why has SDG&E applied to increase PCIA rates in 2020, posing a whopping penalty on Community Choice customers, literally months before launch of San Diego Community Power which represents roughly 3/4s of SDG&E’s load?

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SDG&E's PCIA Trigger Application: Alliance Comments