7. Should SCE be Authorized to Remove Certain Offerings That are No Longer Relevant?
SCE proposes to eliminate 38 fees for services that have never been used or requested, are no longer necessary because SCE will no longer offer the service, or fees that are being consolidated into other service fees. No party opposes SCE's proposal to remove service offerings that are no longer relevant.
Discussion
Because discretionary services are services for which there are sufficient providers to ensure customer choice, their elimination does not impede ESPs' ability to compete or to serve DA end-use customers in SCE territory. ESPs may provide these services themselves or obtain them from non-UDC providers. Therefore, SCE should be authorized to eliminate the discretionary billing and metering products and services as listed in Appendix A.
SCE should be authorized to file a Tier 2 advice letter to eliminate the discretionary billing and metering products and services listed in Appendix A. SCE should file the advice letter within 60 days of the effective date of this decision to become effective upon approval of the Energy Division.
However, some of the services proposed for elimination are non-discretionary services that are available only from SCE. These include all of the services related to Partial Consolidated ESP Billing, Full Consolidated ESP Billing services, and Exception Services.
The interim UDC DA tariff approved by D.97-10-087 provides that ESPs have the right to select from three billing service options, and may choose partial or, with the UDC's approval and consent, full consolidated billing.114 SCE does not explain why it proposes to eliminate all of the non-discretionary services related to Full and Partial Consolidated ESP Billing, and the Exception Services associated with Consolidated ESP Billing.
If SCE's proposal were approved, these non-discretionary exception services would no longer be in SCE's tariffs. As a result, SCE would presumably bill for these services on a T/M (time and materials) basis as Special Service Requests, which it proposes when an ESP or customer requests a service that is not required by SCE or provided by an existing service. In the case of exception services that SCE provides due to an ESP's error, other customers may end up absorbing such costs if SCE does not charge the responsible ESP.
D.97-10-087 requires UDCs to develop service fees for non-discretionary services based on recurring incremental costs.115 Permitting SCE to determine costs on a T/M basis each time Full/Partial Consolidated ESP Billing or Exception Services are provided does not ensure that those costs will be computed consistently or that the costs for these non-discretionary services will be priced at their recurring incremental costs in compliance with D.97-10-087. Instead, we prefer to consider specific rates for approval before they are charged to customers. Therefore, SCE's request to eliminate non-discretionary Full Consolidated ESP Billing services, Partial Consolidated ESP Billing, and Exception Services should be denied.
114 Appendix A, Section N(1) and N(3) (76 CPUC2d, 351, 352)
115 76 CPUC2d, 307.
