4. No Review Required if No Ratepayer Funds Sought
The ACR sought to make clear that when an IOU could provide "any needed co-funding without seeking any additional approval from the Commission, i.e., without raising rates or receiving a certificate of public convenience and necessity (CPCN) or permit to construct (PTC),"39 then no further Commission review of the project is required. The IOU, however, does need to comply with the reporting requirements listed above.
4.1 Positions of Parties
The situation in which no ratepayer funds are needed generated little comment, and no party opposed the proposal that such an application to DOE would not require additional Commission review of the reasonableness of the costs associated with the project.
On this matter, "CLECA thinks it would be wonderful if no additional ratepayer funds were needed, but considers this an unlikely outcome."40
DRA stated that it:
... does not oppose this process, but the Commission should clarify that Proposed Process 1 does not allow the IOU to shift ratepayer funding from existing programs into a Smart Grid project.41
PG&E observes that "[t]he first process (co-funding that requires no new ratepayer funding or other Commission approvals) is not at issue in this proceeding, so PG&E will not discuss [it] further in its comments."42
4.2 Discussion
Abstaining from Commission review of the costs associated with proposed Smart Grid projects that do not require further action by the Commission is reasonable and in the interest of the utility's ratepayers. In these situations, an IOU applicant for DOE funding need fulfill only the reporting requirements outlined above, which are required for our general oversight of regulated utilities.
39 ACR at 9.
40 CLECA Comments at 4.
41 DRA Comments at 5.
42 PG&E Comments at 2.
