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

Reply comments allow a Party to summarize points made by other Parties with which they agree or disagree. The Alliance supported several positions taken by the Community Choice parties (CalCCA, Solana Energy Alliance and San Diego Community Power) while building on our central points:

  • PCIA mechanisms of “Cap” and “Trigger” ordered in the controversial Peterman Decision were flawed in design, especially when applied to such a small community choice program over a short period of time;
  • The Alliance concurred with the CCA Parties that any collection period must be significantly extended, yet rather than 3 years, we proposed 6.

At the conclusion of the Reply phase, the Administrative Law Judge presiding over this case will draft an order based on the record, applicable Commission rules and law. A proposed Decision is expected in this case in November.

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SDG&E's PCIA Trigger Application: Alliance Rely Brief