Clean Energy Alliance: Regulatory Update
Tim Lindl & Jake Schlesinger – Keyes & Fox LLP
September 28, 2023
Overview
A quick (re)introduction
SDG&E’s Phase I General Rate Case
SDG&E’s Phase II General Rate Case
CEA’s Petition for Modification in the Integrated Resource Planning proceeding 2 GRC Phase 1
Hearing in June, briefed in August
Goal: Ensuring utility generation costs do not last in the PCIA in perpetuity. . .
Miramar:
Tens of millions of investment to increase capacity by 9 MW Costs go to 2004/2008 PCIA vintages
SDG&E Claims all customers should pay
Vintaging Framework: Analytical tool to ensure new investment in older UOG for capacity, extensions of life, or change in nature is properly vintaged PG&E Update
3 GRC Phase 2
Status: Discovery/investigation on two main issues:
#1 Rate and Tariff Design
PCIA bundled
PCIA unbundled
CARE discount
#2 Schedule S (Standby Service)
Impossible for SD CCAs to serve
Not consistent with other IOUs
Next Steps: Expert testimony in January
4 Integrated Resource Planning
5 Issue: Prior Commission decision required SDG&E to purchase 49 MW of capacity just before 86,000 departures in Escondido and San Marcos (and 200k departures in SDCP service territory) Commission acknowledged unfairness and allowed CEA to purchase capacity from SDG&E SDG&E refused to provide enough capacity to account for Escondido and San Marcos CEA filed for clarification to avoid $50-$96M in costs over the next 12 years among both SD-area CCAs Proposed Decision denies CEA request
Next Steps: Decision anticipate October 12
QUESTIONS?
Tim Lindl / Jake Schlesinger
[email protected] / [email protected]
510-314-8385 / 970-531-2525
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