23. Notification of Event Cancellation
In its testimony, PG&E indicates that it will notify customers of a PDP event the day before it occurs, or as appropriate, notify customers if the PDP event is cancelled. PG&E intends to notify customers of a PDP event by 2 p.m. the day before the event, but does not indicate when it would notify customers of a PDP event cancellation.
In its prepared testimony, TURN recommended that PG&E be prohibited from canceling PDP events after customers have received day-ahead notification to protect participating customers from inconvenience, confusion, frustration, and hardship and to increase the desirability and effectiveness of PDP tariffs.
In response, PG&E indicated that it needs the latitude to cancel a PDP event in the case of unforeseen occurrences such as notification system technical problems, public telephone network failures, or some human error in initiating the event in the first place. Under such circumstances, PG&E states that it may need to cancel the event so that customers will not incur higher PDP energy charges for events of which they had no notice and therefore could not make arrangements.
In its opening brief, TURN recommended that the Commission prohibit PG&E from canceling a PDP event after 4 p.m. on the day before the event. This would give PG&E two hours from the 2p.m. notification deadline to detect the need for and communicate an event cancellation.
To support the reasonableness of its revised recommendation, TURN cites the cross-examination of PG&E witness Chan who agreed that PG&E should not be able to cancel a PDP event at any time. Chan also testified that in his personal opinion, "it would not be a bad statement to put in our tariffs to let a customer know that if we do cancel an event, when we should notify them."28 Moreover, Chan clarified that PG&E would only cancel a PDP event under very limited circumstances, and those identified by him would be obvious to PG&E in time for the event to be cancelled during the same afternoon as event notification.
TURN argues that its proposal reasonably balances PG&E's concerns about being able to react to a very narrow set of rare events that could support event cancellation, and the concerns of PDP customers in avoiding inconvenience, frustration, and/or hardship from event cancellation.
In its reply brief, PG&E indicated its agreement with TURN that a cancellation notice should go out as soon as possible, and that it has no objection to a reasonable cut-off time. However, PG&E argues that TURN's choice of a 4 p.m. cut-off is arbitrary, and states that for reasons not on the record, since TURN did not raise its new proposal until after the record closed, 4 p.m. is too early.
PG&E proposes that the Commission order that this matter be resolved by including the issue in an advice letter PG&E will file at the end of this proceeding. PG&E states that it will explain and support its current policy regarding cancellation cut-off time in the advice letter, to which TURN can file a protest if PG&E's explanation is not satisfactory.
23.1. Discussion
We agree with both TURN and PG&E that it would be reasonable to specify a cut-off time for PDP event cancellation in PG&E's tariffs.
Based on TURN's cross-examination of PG&E witness Chan, a 4 p.m. cut-off appears to be in a reasonable zone. However, the record on what the optimal time should be is limited by the timing of TURN's proposal and the fact that PG&E did not provide evidence regarding how much time it needs. As suggested by PG&E, we will allow the company to file an advice letter to explain and support an alternative cut-off time. Parties will have the opportunity to respond. If no protests are filed, PG&E's proposed cut-off time will be adopted and should be included in PG&E's tariffs. If protested, the cut-off time will be determined by Commission resolution.
28 PG&E, Chan, 3 RT 400.
