3. Discussion

SDG&E, SoCalGas, and the ten other parties request that the TCAP filing date of September 1, 2011, that is contained in section II.B.3.M.a of Appendix A to D.09-11-006, be modified so as to require that the TCAP be filed no later than November 1, 2011. The petitioning parties contend that such a modification will: (1) minimize the conflict between the TCAP and the GRCs of SDG&E and SoCalGas, and help ease potential resource burdens on parties who plan to participate in both the GRCs and TCAP; (2) avoid the rate complexity and duplicative efforts with having to file the TCAP on September 1, 2011, only to be followed by the rate changes that will take effect on October 1, 2011 as a result of the further unbundling of backbone transmission costs that was authorized in D.11-04-032; and (3) to allow time for review of the 2011 backbone transmission open season process so that any potential adjustments to that process can be addressed in the TCAP.

If the September 1, 2011 filing date for the TCAP remains unchanged, the rates set forth in that TCAP filing will not reflect the new rates that go into effect on October 1, 2011 as authorized by D.11-04-032. It is expected that the rate changes authorized by D.11-04-032, will substantially increase the costs allocated to backbone transmission service, and that there will be a corresponding reduction in end-use customer transportation rates. Modifying D.09-11-006 to allow the next TCAP filing of SDG&E and SoCalGas to be filed by November 1, 2011, instead of by September 1, 2011, will allow SDG&E and SoCalGas to incorporate the October 1, 2011 rate changes into the TCAP filing.

In addition, modifying D.09-11-006 to require the TCAP to be filed by no later than November 1, 2011, will allow SDG&E and SoCalGas to include in the TCAP possible recommendations to change the backbone transmission open season process.

Also, modifying D.09-11-006 to allow the TCAP to be filed by November 1, 2011 will lessen the burden on parties who are participating in the SDG&E and SoCalGas GRCs and in the upcoming TCAP.

Accordingly, the May 19, 2011 petition for modification should be granted, and D.09-11-006 should be modified to require that the next TCAP of SDG&E and SoCalGas be filed no later than November 1, 2011, instead of the filing date of September 1, 2011 that is set forth in section II.B.3.M.a of Appendix A to D.09-11-006, referenced in footnote 8 of that decision, and at page 18 of the portable document format (pdf) version of D.09-11-006.