35. Report on Bill Impacts for Agricultural Customers and TOU

AECA contends that, based on the extremely large number of agricultural customers currently on non-TOU rates that would be required to shift to TOU rates under PG&E's proposal, a more robust analysis is required to ensure that this large population of customers will not be inadvertently penalized by this migration. AECA proposed that PG&E provide analysis after 1,000 and 10,000 such customers were converted to SmartMeters to ensure that the analysis provided by PG&E was accurate enough to continue rate migration.

PG&E objected to that proposal and proposed an alternative recommendation in rebuttal testimony. In fall 2010, PG&E expects to have 12 months of available interval load information for at least 10,000 agricultural customers, with data from the AMI system. Using the most complete information available, PG&E proposes to develop an analysis of the projected bill impacts under TOU for this 10,000 customer sample of agricultural customers by November 2010.

In response, AECA stated its belief that the analysis proposed by PG&E will be robust enough to ensure adequate information for the Commission and parties to evaluate the migration. AECA requests that if the November 2010 analysis by PG&E illustrates a significant negative rate impact on existing non-TOU ratepayers, this issue remains pending and incorporated into PG&E's next GRC.

We will adopt PG&E's proposal to develop an analysis of the projected bill impacts under TOU for this 10,000 customer sample of agricultural customers by November 2010. The information should be provided to the Energy Division and AECA and the availability of the information should be made to the service list. If any party feels that the information necessitates a rate design modification, such recommendations should be presented in the next available rate design proceeding, whether it is a GRC Phase 2 or rate design window proceeding. If the analysis indicates a significant negative rate impact, any party may file a petition to modify this decision with respect to the associated TOU rates and/or the effective start date for migration to TOU rates for these agricultural customers.