25. Incremental CSOL Activities
PG&E has identified two areas of change for its CSOL web presentment that are needed as a result of PDP.
First, PG&E indicates that it will need to modify tools for large C&I, small and medium C&I, agricultural and residential customers that already exist or are being built to incorporate aspects of PDP that are not in current rates. These changes include updating rate comparisons tools to include the PDP rates, as well as updating the rate comparison and load analysis tools to support the new rate structures.
These new structures include the choice of two different event windows for small and medium C&I and residential customers, and the ability to elect non-consecutive or consecutive day PDP participation for these same customers. For large C&I customers, the tools need to incorporate reservation capacity optionality that allows the customer to select a base load demand to which PDP will not apply on event days. In addition to these changes to customer facing tools, PG&E states it will similarly need to modify its internal rate analysis tool for supporting rate comparison and analysis requests from customers via the Customer Contact Center.
PG&E has identified the CSOL "My Account" architecture as the second CSOL area requiring change for PDP. For the on-line tools to promote customer transition to the new PDP and TOU rates, PG&E states that the customer will need a seamless and integrated on-line experience that facilitates analysis of multiple accounts. According to PG&E, its current "My Account" architecture was not created to support energy management and analysis at the level now anticipated for default PDP.
In general, we agree with the need for the additional CSOL activities that PG&E proposes. First of all, it is clear that updating rate comparisons tools to include the PDP rates, as well as updating the rate comparison and load analysis tools to support the new rate structures, is necessary. Second, we agree that there is a need, especially as it relates to agricultural accounts, for CSOL to be able to group and analyze multiple accounts. Both changes are necessary to facilitate customers' understanding of their usage and the effects of the PDP program. Due to the importance of CSOL in successfully implementing PDP, we will require verification of the results of PG&E's activities in this regard. PG&E should file a Tier 2 advice letter within 30 days after it has completed its proposed incremental CSOL activities.32 PG&E should provide sufficient information for Energy Division staff to verify that the new PDP functionalities that PG&E has implemented on its website appropriately suit ratepayer needs. The anticipated February 1, 2011 and November 1, 2011 PDP default processes should not begin until affected customers have had access to the verified PDP related CSOL tools for at least 45 days.
32 PG&E indicates that its proposed CSOL changes will be completed by March 31, 2010. See Exhibit 3 at 8A2-1, Figure 8A2-1.
