Gao, Beilei
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Sam Berndt
Tuesday, January 13, 2026 3:21 PM
cityclerk
MSC Public Comment - Agenda Item 1 - 1/13/2026
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The Cost of Service Study unfairly allocates the burden of the distribution system onto residential ratepayers.
Cost-of-service studies allocate costs to classes, not to individual customers. That means class construction is not neutral—it fundamentally determines who pays. The way that classes are aggregated allows the consultants to tell a simple story about how a single class, a class that contains a vast majority of the ratepayers in Pasadena, are responsible to pay a far outweighed burden of the distribution system.
What this simple story fails to explain is why those classes were formulated in a way such that individuals within the residential class, who individually contribute thousandths of a percentage less burden on the distribution grid than the large commercial ratepayers, are left footing the bill.
In the study's own figures, residential customers collectively consume about 33% of total energy across more than 59,000 accounts, while approximately 126 large commercial customers consume roughly 25%. On a per- customer basis, each large commercial account represents 3 orders of magnitude, 1000 times more system load than a residential customer. Turning on the AC in the summer does not spike residents' load by 1000 times. Despite this, large commercial customers are charged a calculated average distribution charge of about
2.7 cents per kWh, while average residential customers are charged between 9 and 18 cents per kWh—a three- to six-fold difference.
It is no wonder that the Vice President ofVolkswagen Pasadena praised the process, calling it "a perfect example of joint collaboration needed to help ease any concerns regarding future rate increases." Meanwhile, residents have had no meaningful opportunity to engage with the technical assumptions of the study.
Corporations that use electricity for the purpose of generating revenue do not have a right to cheaper electricity than people who use it to survive.
I urge you to reject the findings of the electric rate study and request a reapportionment of burden to more equitably distribute the cost of service.
Sam Berndt
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