14. Assignment of Proceeding
Michael R. Peevey is the assigned Commissioner and Richard Smith is the assigned ALJ in this proceeding. ALJ Smith is the presiding officer in this proceeding.
1. SCE offers discretionary and non-discretionary DA services to ESPs and DA customers through three rate schedules: Schedule ESP-DSF, Schedule CC-DSF, and Schedule ESP-NDSF.
2. Schedule ESP-DSF applies to ESPs who choose to receive certain metering, billing and other DA-related services from SCE. Schedule ESP-NDSF applies to ESPs who require certain services from SCE to offer optional services to customers. Schedule CC-DSF applies to DA customers who request certain meter-related services from SCE. Schedule CC-DSF also applies to bundled service customers not participating in DA who request meter-related services which are not already provided for by their applicable default rates.
3. If CCA is implemented in SCE's service territory, Schedule CC-DSF will also apply to any CCA customers who request additional meter-related services.
4. In A.99-06-040, SCE previously sought to revise its DA service fees and establish new fees.
5. SCE's existing DA service fees were developed when its DA service tariff was approved by D.97-10-087.
6. D.97-10-087 anticipated that issues concerning the appropriateness of the fees for all UDCs would be considered in a subsequent proceeding (Anticipated Proceeding). In the meantime, D.97-10-087 authorized UDCs' Discretionary Service Fees on an interim basis.
7. Due to events such as the California energy crisis, the Anticipated Proceeding was delayed and has not yet commenced.
8. Although enrollment of new DA customers is currently suspended, the Commission is presently considering whether, when, or how the suspension of DA may be lifted.
9. AReM's arguments and exhibits purportedly evidencing SCE's bias do not persuade us that A.07-01-045 is a malicious attempt to disadvantage ESPs or discourage DA customers.
10. In D.04-07-022 and D.06-05-016, the Commission adjusted DA service fees because of concerns that the fees were not aligned with costs, and, as a result, SCE's bundled service customers were subsidizing DA customers. However, these prior adjustments were not based on SCE's actual cost data.
11. While the enrollment of new DA customers is currently suspended, existing DA customers may continue to participate and new ESPs may enter the market.
12. The existing DA services and fees were based on predictions of what DA services would likely be required (including some services and fees which were never requested or used by DA service customers), and do not include some activities that have evolved since the tariffs were first established.
13. D.97-10-087 determined that only those non-recurring costs that vary with the number of ESPs should be recovered in fees for non-discretionary services.
14. D.97-10-087 determined that costs for non-discretionary services should be charged to a memorandum account pending a Commission decision regarding the appropriateness of such costs.
15. D.97-10-087 determined that requiring only those that exercise their choice to pay all the costs of having choice would result in unreasonable service fees for non-discretionary services and would impede the efficient operations of the market.
16. SCE's costing approach appropriately focuses initially on identifying costs attributable to DA services as distinguished from "bundled service."
17. Exceptions are processes that are not built into the Customer Service System, and are more costly and time consuming than providing routine services.
18. SCE embeds the costs of processing exceptions in the proposed DASR, MAMF and certain other fees regardless of whether those proposed to pay the fees cause the exception procedures to be required.
19. AReM's and CMTA's recommendation to notify customers of the acceptance or rejection of a DASR via email rather than by U.S. Mail is an example of a process improvement that is likely possible, less costly than existing processes, and a more efficient means of providing notification.
20. SCE's proposal contains unexplained inconsistencies in certain OEA estimates.
21. The Application does not explain why it requires ten minutes for a technical specialist performing a particular activity for one service but requires only five minutes for the same kind of technical specialist performing identical tasks for another service.
22. Most of the proposed fees for non-discretionary services are based on costs developed using OEA estimates.
23. The accuracy of the OEA estimates is unknown.
24. Except in limited instances, SCE has not verified or validated the accuracy of an OEA estimate by comparing the OEA estimate with results derived from a time and motion study for the same activity in order to establish a "benchmark" and to determine the average deviation from that benchmark.
25. D.97-10-087 requires that service fees be based only on recurring costs that recur each time a transaction is processed, but provides no guidance as to whether labor overhead costs should be reflected in DA service fees.
26. D.97-10-087 determined that the originally used term "competitive services" should be replaced by the term "discretionary services" because the customer has the right (e.g., discretion) to choose a service provider.
27. D.97-10-087 determined that the term "non-competitive services" should be changed to "non-discretionary services" because customers do not have a choice when services are available only through the UDC.
28. The DA tariffs adopted by D.97-10-087 provide that, during the interim period between the start of DA and a Commission decision approving specific fees for non-discretionary services, the UDC will charge the net incremental costs associated with providing non-discretionary services to a memorandum account pending the CPUC's decision regarding service fees.
29. SCE's currently effective Rule 22 tariff, Sheet 27752-E, provides that, during the interim period between the start of DA and a Commission decision approving specific fees for non-discretionary services, SCE will charge the net incremental costs associated with providing non-discretionary services to a memorandum account pending the CPUC's decision regarding service fees.
30. The CPUC has only approved specific non-discretionary fees for services related to ESP consolidated billing services.
31. D.97-10-087 authorized UDCs to book the interim fees and costs of providing discretionary DA services to a one-way memorandum account subject to refund.
32. D.97-10-087 distinguished discretionary DA services from non-discretionary services, first, as a way to identify the services for which an ESP or a customer could choose between a competitive provider and a UDC, but also in its treatment of how costs and revenues for discretionary and non-discretionary services would be recovered.
33. In compliance with D.97-10-087, SCE established Schedule ESP-SF and Schedule CC-SF, which were approved by the Energy Division and became effective on January 4, 1998. Schedules ESP-SF and CC-SF did not distinguish between discretionary and non-discretionary services.
34. In October 1998, SCE filed AL 1338-E establishing Schedule ESP-NDSF for billing services, that are required to support ESP consolidated billing authorized by D.98-09-070, which was approved by Resolution E-3582 on January 20, 1999.
35. SCE filed AL 1343-E to, among other things, rename Schedules ESP-SF and CC-SF to Schedule ESP-DSF and Schedule CC-DSF, respectively. AL 1343-E was approved by the Energy Division and became effective on December 31, 1999. AL 1343-E renamed SCE's service fee tariffs to more accurately reflect the nature of discretionary and non-discretionary services in accordance with D.97-10-087.
36. A.99-06-040 sought to rename "discretionary services" to "competitive services" and "non-discretionary services" to "regulated services," contending that SCE's proposed terminology most accurately describes customers' options and the Commission's role in the new market.
37. A.99-06-040 requested that the Commission rely on the market to set prices for what SCE proposed to call "competitive services," and that SCE be permitted to price its competitive services freely in response to the market.
38. A.99-06-040 requested that the Commission eliminate the requirement that interim fees for competitive (discretionary) services be subject to refund, and that the DADSCMA be closed.
39. A.99-06-040 requested that the Commission authorize establishment of fees for regulated (non-discretionary) services.
40. D.03-01-072 dismissed A.99-06-040.
41. SCE filed AL 1808-E to eliminate the DADSCMA, which was approved by Resolution E-3895, effective January 27, 2005.
42. D.97-10-087 authorized UDCs to book the incremental costs of providing non-discretionary services to a memorandum account pending a Commission decision regarding the appropriateness of such costs and possible recovery under § 376 relating to restructuring costs.
43. D.99-09-064 approved a settlement of issues related to restructuring implementation costs pursuant to § 376, including recovery of certain DA implementation costs. D.99-09-064 did not address the issue of fees for DASR processing or fees for discretionary services because PG&E, SCE, and SDG&E had filed applications to address such fees.
44. D.99-09-064 determined that only those costs incurred to accommodate implementation of the Independent System Operator, Power Exchange, and DA through December 31, 1998 could receive § 376 treatment, and that costs incurred after 1998 or the costs of operating these programs on an ongoing basis were not eligible for § 376 treatment.
45. SCE's written testimony confuses discretionary with non-discretionary services in its citation of D.97-10-087.
46. During evidentiary hearings, SCE's witness, a manager who has worked on DA implementation activities since 1997, confused discretionary with non-discretionary services six times.
47. D.06-05-016 adopted "TURN's proposed inflation adjustment to reflect a 25% increase in discretionary DA service fees ... " D.06-05-016 did not authorize an increase in non-discretionary DA service fees.
48. 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 Consolidate ESP Billing services, and Exception Services.
49. If SCE's proposal were approved, Partial Consolidated ESP Billing, Full Consolidated ESP Billing services, and Exception Services would no longer be in SCE's tariffs. As a result, SCE would presumably bill for these services on a time and materials (T/M) basis as Special Service Requests, which it proposes to apply when an ESP or customer requests a service that is not required by SCE or provided by an existing service.
50. D.97-10-087 approved the interim DA tariff for the UDCs, including provisions permitting UDCs to assess a charge for accepted DASRs, if that fee was approved by the Commission.
51. The Commission has not yet approved any DASR fees.
52. The interim tariff adopted by D.97-10-087, and SCE tariff Rules 22.E.20.b. and 22.E.21, provide that any approved DASR charge will be billed to the ESP unless the customer is requesting to return to UDC service where the charge will be billed to the customer.
53. D.97-10-087 left open the possibility of temporarily waiving initial DASR switching fees for existing customers to help to level the competitive playing field between ESPs and UDCs, but deferred this issue to a future proceeding that would examine the appropriateness of non-discretionary fees.
54. Although D.97-10-087 foresaw situations where end-use customers might return to bundled service or change from one ESP to another, it did not consider UDC fees for facilitating these choices.
55. D.97-10-087 requires UDCs to develop service fees for non-discretionary services based on recurring incremental costs.
56. Less than 1% of the costs related to the proposed MAMF are attributable to the support systems shared by all DA participants.
57. Most of the costs included in the MAMF are for processing exceptions (33% of MAMF costs are attributable to billing and metering exceptions) or providing various levels of different services for some but not necessarily all ESPs (49% are attributable to the cost of notifying ESPs of changes to their particular customers' service accounts).
58. D.97-10-087 determined that fees for non-discretionary services should be based only on recurring costs, and that only those non-recurring costs that vary with the number of ESPs should be recovered in fees for non-discretionary services.
59. D.97-10-087 specifies that non-recurring costs such as those costs associated with developing new systems and processes may not be included in fees for non-discretionary services, and directs that the fees for non-discretionary services include only costs that recur each time a transaction is processed in order to send the proper price signals to allow a competitive market to develop.
60. SCE has identified the activities for each service addressed by the proposed MAMF and could develop separate fees for each of these components.
61. There is no record before us on issues concerning the potential impact of SCE's advanced metering infrastructure proposal on the proposed fees or meter-related costs.
62. SCE does not seek an increase in its authorized base revenue requirement.
63. SCE will include a forecast of its OOR for the service fees in its next GRC Application.
64. The advice letter process provides a quick and simplified review of the types of utility requests that are expected neither to be controversial nor to raise important policy questions.
65. The primary use of the advice letter process is to review a utility's request to change its tariffs in a manner previously authorized by statute or Commission order, to conform its tariffs to the requirements of a statute or Commission order, to get Commission authorization to deviate from its tariffs, or to request modification of a Commission resolution addressing a prior advice letter of the utility.
66. ESPs that compete with UDCs, their DA customers, and bundled service customers all have an interest in ensuring that non-discretionary DA service fees are appropriately priced in accordance with the established incremental costing standards.
67. Interested parties will have a keen interest in ensuring that new fees proposed for non-discretionary services are appropriately priced.
1. Ideally, prior to approving changes to SCE's DA and other service fees, the Anticipated Proceeding should take place because policy and other issues remain unresolved that apply to all UDC DA tariffs, and A.07-01-045 implicates some of these issues.
2. The passage of so much time is possibly resulting in fees that are becoming less and less related to SCE's actual costs, and, if so, may be undermining our policy of sending accurate price signals that would allow a competitive market to develop.
3. With the passage of time, the differences are likely increasing between the existing DA service fees and SCE's actual costs of providing DA services.
4. The passage of almost a decade since SCE's DA service fees were established persuades us to consider A.07-01-045 at this time.
5. AReM's and CMTA's arguments for rejecting A.07-01-045 lack merit.
6. AReM and CMTA have not shown that A.07-01-045 is designed to undermine ESPs or the DA market.
7. Updating DA and other service fees at this time will help to ensure that they are based on current processes and cost studies that better reflect SCE's actual cost of providing these services.
8. Because the Anticipated Proceeding to address the appropriateness of DA and other fees on a statewide basis has been delayed, we have not yet had an opportunity to determine the appropriateness of the UDCs' DA and other fees or the underlying methodologies used to develop them.
9. The Commission may at some point in the future lift the suspension on DA, and if so, ideally, accurate, up-to-date cost-based fees should be in effect.
10. Important statewide DA and other service fee issues have not yet been decided.
11. It is appropriate to consider A.07-01-045 at this time, including SCE's proposals to add new DA and other services and fees that were not contained in the original schedules.
12. D.97-10-087 stated the Commission's intention to eventually adopt one uniform, statewide DA tariff. This requires consideration of, among other things, consistency in UDC costing methodologies and other issues affecting the appropriateness of DA service fees.
13. The non-discretionary service fees and their underlying costing methodologies should be considered in the Anticipated Proceeding.
14. A proper incremental cost methodology should accurately identify costs and appropriately assign those costs to the cost causers.
15. Accurate assignment of costs is necessary to send the appropriate price signals in a competitive market. These costs should be properly assigned to those who cause the costs so that customers are sent a true price signal of how much their electricity choices actually cost, and to avoid cost shifting or inappropriate cross-subsidization.
16. SCE's costing approach appropriately identifies the operational areas providing services to ESPs and DA customers which incur DA-related costs.
17. In certain cases, SCE's method of attributing costs either to DA customers or to ESPs inappropriately assigns to ESPs costs caused by end-use customers.
18. The Commission has an interest in ensuring that UDCs comply with its incremental cost policy, while also ensuring that the costing methods used are administratively feasible.
19. Although D.97-10-087 allowed each UDC to file its own DA tariff, the Commission prefers a uniform DA tariff for statewide use to eliminate inconsistent and differing rules among the utilities.
20. SCE's methodology which imposes fees on ESPs when end-use customers independently exercise choice is unreasonable and should not be approved because it assigns costs to those who do not cause those costs to be incurred and does not comply with D.97-10-087.
21. Recovering the costs for processing exceptions caused by particular ESPs or end-use customers equally from all ESPs is inconsistent with SCE's cost causation principles, and with the Commission's instructions to UDCs to develop fees that recover costs from those who cause those costs to be incurred.
22. Advances in technology make it possible to continuously improve the processes used for delivering DA services efficiently, and such improvements are among the issues that the Working Group was established to address.
23. The Working Group is comprised of utilities and other entities which have not participated in this proceeding and which have not had an opportunity to address the issue of reconvening the Working Group.
24. We do not have enough information at this time to conclude that SCE should be directed to implement AReM's and CMTA's recommendation to notify customers of the acceptance or rejection of a DASR via email rather than by U.S. Mail.
25. The process improvements that should be considered pursuant to this decision are specific to SCE's DA services, and focusing parties on SCE-specific process improvements at this time will likely be a more efficient and productive undertaking.
26. The Energy Division should convene and facilitate a meeting between SCE, AReM, CMTA, and other interested parties within sixty (60) days of the effective date of this decision to consider issues surrounding DA process improvements, including the timing for implementing any recommended improvements that may not be cost effective now at the currently low DA volumes but which may become cost effective if the suspension on enrolling new DA customers is lifted and the volume of transactions increases. Additional meetings should be scheduled thereafter as appropriate.
27. SCE, AReM and CMTA should be required to submit a joint report that identifies specific potential process improvements, proposes recommendations for SCE's DA process improvements, and recommendations for an ongoing process to consider possible future process improvements that reflect the needs and interests of all DA market participants in SCE territory. Parties should be allowed to submit with the report their comments addressing any disagreements or reservations that participants may have with any recommendations or other aspects of the report. The report should be submitted in R.07-05-025, and will be considered if, and when, Phase III of that proceeding is commenced.
28. The development of accurate and reliable costs requires the underlying data to be reasonably accurate and based on actual, recorded operational information.
29. Estimates based on historical records or time and motion studies are based on objective, quantified and easily verified measurement of the activities being performed or the cost of items purchased.
30. Costs based on SCE's OEA estimates are subjective and potentially less accurate because they are imprecise "best guess" approximations of those performing the activity being measured, and, in some cases, for activities that are not actually being performed.
31. The inconsistency in OEA estimates casts doubt on the accuracy and reliability of SCE's OEA estimates.
32. SCE has not taken steps, except in limited instances, to objectively verify the accuracy of its OEA estimates in a way that provides confidence in their accuracy or reliability.
33. OEA estimates were developed for some activities, such as ESP establishment, even though those activities were not being performed. The accuracy of an estimate of time required to perform an activity is questionable when that activity is not actually being performed.
34. In some cases, SCE's OEA estimates for the same tasks vary substantially, indicating that at least some of the OEA estimates are unreliable.
35. SCE's OEA estimating methodology is unreasonable because the methodology produces inconsistent results for identical activities, and because SCE has not objectively verified the accuracy and reliability of its OEA estimates.
36. Although the Commission established the policy that non-discretionary fees should be based on incremental costs, the Commission has not heretofore considered or approved the UDCs' incremental costing methodologies to ensure the Commission's policy is appropriately and consistently applied. Such a review would necessarily consider how cost data is gathered and used to develop fees, including, for example, the appropriate use of historical records versus time and motion studies versus OEA derived estimates.
37. UDC costing methodologies have implications for DA statewide, and should be considered in the Anticipated Proceeding that intends to examine the appropriateness of all of the UDCs' DA service fees and tariffs.
38. SCE's costing methodology used to develop the proposed service fees should not be approved.
39. SCE should be especially scrupulous in how it develops fees to be charged to its ESP competitors, and to its DA and other customers.
40. Before approving SCE's costing methodology, we should consider the appropriateness of charging ESPs for costs caused by end-use customers who directly contact the UDC.
41. DA and other services cannot be provided without paying the salaries and benefits, and providing A&G support for the employees providing DA services.
42. It is appropriate to reflect A&G costs in DA service fees.
43. Division overhead costs support the employees providing DA services, and a share of those costs should be included in DA service fees.
44. Excluding A&G and division overhead costs will understate the actual cost of providing DA services.
45. The A&G and division overhead loadings included in the service fees are similar to those applied to other SCE services, and are reasonable.
46. The inclusion of A&G and division overhead loadings does not result in a double collection of the costs for DA services because the revenue from the DA service fees will be included in OOR in SCE's next GRC.
47. Because D.03-01-072 dismissed A.99-06-040, SCE was not authorized in A.99-06-040 to eliminate the "subject to refund" requirement for interim discretionary fees, close the DADSCMA, or to begin charging service fees for non-discretionary services as requested in A.99-06-040.
48. SCE's currently effective Rule 22 tariff requires SCE to charge the net incremental costs associated with providing non-discretionary services to a memorandum account. Therefore, SCE continues to have an accounting reason for distinguishing between discretionary and non-discretionary services.
49. The Commission's efforts leading to retail competition for electricity and the DA program were designed to achieve customer choice and more effective competition in the electric industry.
50. If, in the Anticipated Proceeding, the Commission approves different procedures for obtaining approval to revise fees for discretionary and non-discretionary services, SCE could possibly be required to maintain separate discretionary and non-discretionary DA service tariffs.
51. The Commission has a continuing interest in differentiating discretionary and non-discretionary services, because the Commission has established a policy in favor of competition.
52. Minimizing customer confusion will help further the Commission's goals for a competitive electric industry.
53. Separate discretionary and non-discretionary DA service tariffs should help reduce confusion about which DA services ESPs and DA customers have choice in obtaining from alternate providers.
54. SCE's differing explanations for changing or eliminating the categorization of discretionary and non-discretionary DA services in this Application, A.99-06-040, and AL 1343-E underscore the need to consider this issue for all UDC tariffs in a wider forum, as anticipated by D.97-10-087.
55. SCE's request to eliminate the discretionary/non-discretionary categorization of DA service fees should be denied.
56. 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.
57. SCE should be authorized to eliminate the discretionary billing and metering products and services as listed in Appendix A.
58. SCE should be authorized to file a Tier 2 advice letter to eliminate the discretionary billing and metering products and services as listed in Appendix A. SCE should file the advice letter within 60 days of the effective date of this decision. The advice letter should become effective upon approval by the Energy Division.
59. Permitting SCE to determine costs on a T/M (time and materials) 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.
60. SCE's request to eliminate Full Consolidated ESP Billing services, Partial Consolidated ESP Billing, and Exception Services should be denied.
61. SCE's methodology, for the most part, appears to reduce subsidies between DA customers and bundled service customers. However, SCE's methodology does not adequately reduce cost shifting between DA users who cause costs to be incurred and those who SCE proposes should pay those costs.
62. Overstating or understating an OEA estimate will result in cross-subsidies between DA and other customers, with the direction of the cross-subsidy depending on whether DA costs were overstated or understated.
63. Because the accuracy of the OEA estimates is unknown, the extent of cross-subsidization between DA and other customers, too, is unknown.
64. We are not confident that the costs underlying the service fees are as accurate and reliable as we would prefer. However, because ESPs and DA customers can obtain discretionary services elsewhere we are less concerned with the accuracy of the costs underlying the fees for those services, the proposed additions and revisions to discretionary service fees should be approved.
65. SCE should be authorized to file a Tier 2 advice letter to add new fees and to revise existing fees for discretionary billing, and metering products and services as identified in Appendix A. SCE should file the advice letter within 60 days of the effective date of this decision. The advice letter should become effective upon approval of the Energy Division.
66. SCE's proposal to charge ESPs for customer requests made directly to SCE is inconsistent with its cost-causation principles which state that the individuals who cause the costs to the system should pay for those costs.
67. Because the customer is the cost causer when it contacts SCE to return to bundled service, the customer should be responsible for the cost resulting from its decision.
68. Consistent with provisions adopted by D.97-10-087 with respect to customer-initiated DASR disconnections, SCE's Disconnect DASR Fee should not be charged to ESPs when a customer chooses to return to bundled service.
69. The proposed Disconnect DASR fee does not comply with D.97-10-087 or the DA tariff and should not be approved.
70. SCE's proposal to charge ESPs for customer requested services in cases where a customer contacts SCE directly to request DASR services is inconsistent with its cost-causation principles.
71. The customer is the cost causer when the customer directly contacts SCE for DASR services.
72. When a customer contacts SCE directly to request DASR services, if DASR fees are eventually adopted, the applicable fees should be billed to the customer requesting the service.
73. Proposals to charge ESPs for end-use customer choices raise important policy issues that should be considered in a statewide context.
74. SCE's proposal to price ESP Termination services on a T/M basis does not ensure that these non-discretionary services will be priced at their recurring incremental costs and does not comply with D.97-10-087.
75. SCE's request to price ESP Termination services on a T/M basis should be denied.
76. If assigning costs to those who cause the cost is the principle to be followed, then it is irrelevant that ESPs and DA participants as a group will ultimately be charged the same aggregate amount.
77. Since all UDC customers were given the ability to choose as a result of the DA program, recovery of costs associated with the development of a DASR processing system and other DA start-up costs, to the extent they are eligible for recovery, are appropriately recovered from all customers.
78. To require only those that exercise their choice to pay all the costs of having choice would result in unreasonable service fees for non-discretionary services and would impede the efficient operations of the market.
79. SCE's argument concerning tracking system costs that would be passed to DA participants is inconsistent with the requirements of D.97-10-087.
80. SCE's reasoning that a predictable monthly fee for all ESPs is convenient for ESPs (because it allows ESPs and DA customers to contact SCE with credit and billing inquiries as needed without being charged for each contact regardless of the number of inquiries) is contrary to SCE's cost causation principles because some ESPs or their customers may make extensive use of credit or billing services or require billing or metering exceptions, while others will not use these or other services frequently or at all but will still pay the same monthly fee.
81. The proposed MAMF should not be approved because it does not comply with the requirements of D.97-10-087, and is not consistent with cost causation principles.
82. Fees for any services contained in the proposed MAMF should be considered in the Anticipated Proceeding where we expect to consider the appropriateness of non-discretionary costs.
83. Any proposed fees for services addressed by the components of the proposed MAMF should include only the incremental costs that recur each time a transaction is processed, and only those non-recurring costs that vary with the number of ESPs.
84. Any proposed fees for MAMF components should be consistent with cost causation. Fees for exception services should be proposed on a per occurrence basis to be applied when an exception is requested or required.
85. Until fees are approved for non-discretionary services, the incremental costs to provide these services may be booked to a memorandum account pending a Commission decision regarding the appropriateness of such costs and their recovery.
86. SCE should be required in its current GRC and future GRCs to remove the costs for non-discretionary DA services from bundled service customer rates.
87. SCE should be authorized, but not required, to file a Tier 2 advice letter to establish a memorandum account and subaccounts to track the costs of providing non-discretionary DASR services, voluntary and involuntary ESP Termination services, ESP Service Establishment services, CISR services, ESP Non-Energy Billing Receivables services, Meter Establishment services, and the non-discretionary services contained in the proposed MAMF services, pending further Commission action. If SCE chooses to establish a memorandum account or subaccounts for this purpose, SCE should file the advice letter within 60 days of the effective date of this decision. The advice letter should become effective upon approval of the Energy Division.
88. Authorization to establish a memorandum account is not a decision on the merits of any fees that may be developed for non-discretionary DASR services, voluntary and involuntary ESP Termination services, ESP Service Establishment services, CISR services, ESP Non-Energy Billing Receivables services, Meter Establishment services, or the costs for services addressed by the proposed MAMF.
89. Sending customers accurate price signals about the cost of their choices will help a competitive market develop.
90. Establishing a single monthly fee for several DA services is undesirable because all DA customers would pay the rate regardless of whether they use all of the DA services whose costs are included in the fee.
91. Bundling the costs for various services in a single mandatory MAMF will have a negative effect on DA customers, given the large proportion of DA service fee revenue it represents.
92. The effect of the proposed service fees on SCE's Other Operating Revenue is de minimus.
93. The proposed service fees do not affect SCE's revenue requirement.
94. Pursuant to GO 96-B, General Rule 5.1, SCE would be able to use the advice letter process to establish new DA service fees if this decision authorized it to do so. If the Commission were to grant such authority, those advice letters would be filed under Tier 3 and require Commission approval (i.e., a Commission resolution) to become effective.
95. There are important differences between discretionary and non-discretionary services. Discretionary products and services are somewhat less controversial than are non-discretionary services because ESPs and customers have a choice not to purchase discretionary services from the UDC. If ESPs consider the UDC's price for discretionary services to be too high, ESPs can provide the service themselves or purchase products and services elsewhere at a lower cost.
96. The level of controversy concerning the fees for new DA services or products introduced through advice letters will depend in part on whether the services and proposed fees are discretionary or non-discretionary.
97. Considerable controversy already surrounds certain non-discretionary service fees, due to the impact that the fees can have on facilitating or impeding competition for electric services.
98. A matter that requires an evidentiary hearing may be considered only in a formal proceeding, and a utility may seek a rate increase via advice letter only if use of an advice letter for this purpose is authorized by statute or Commission order.
99. If fees for non-discretionary services exceed the incremental costs of providing the service, ESPs and their customers will pay more than they should. Such a result could discourage competition for electric services and send inaccurate price signals that non-discretionary services cost more than they actually do.
100. If a proposed new fee for a non-discretionary service is less than the incremental cost of providing that service the UDCs' bundled service customers could ultimately pay the shortfall, thereby unfairly subsidizing ESPs and DA customers and sending inaccurate price signals to the market that the non-discretionary service costs less than it actually does.
101. Because GO 96-B limits the advice letter process to requests that are expected neither to be controversial nor to raise important policy questions, the advice letter process is not appropriate for non-discretionary services.
102. SCE's request to use the advice letter process for establishing new service fees for non-discretionary services should be denied.
103. Requests for establishing new service fees for non-discretionary services should be made by formal application, either in GRCs or ratemaking applications.
104. Important policy concerns could arise with respect to new discretionary products and services. However, these issues are likely to be less frequent and less controversial.
105. Because technology changes rapidly and because we want new equipment to become available quickly, the advice letter process is appropriate for introducing new discretionary products and services.
106. Controversies may arise if interested parties contend a proposed new product or service is, in fact, non-discretionary, and as a result, whether the advice letter process has been used appropriately. However, these questions should be resolved in the resolution addressing the advice letter.
107. SCE's request to use the advice letter process should be approved for establishing new discretionary products and services.
Therefore, IT IS ORDERED that:
1. The proposed discretionary service fees are adopted as indicated in Column D of Appendix A. Southern California Edison Company (SCE) is authorized to add the new fees and to revise existing fees for discretionary billing and metering products and services as indicated in Column D of Appendix A. SCE shall file a Tier 2 advice letter within 60 days of the effective date of this decision to add the new fees and to revise existing fees for discretionary billing and metering products and services listed in Appendix A. The advice letter shall become effective upon approval by the Energy Division.
2. SCE is authorized to eliminate those discretionary billing and metering products and services as indicated in Column D of Appendix A. SCE shall file a Tier 2 advice letter within 60 days of the effective date of this decision to eliminate those discretionary billing and metering products and services listed in Appendix A. The advice letter shall become effective upon approval by the Energy Division.
3. SCE request for approval of its costing methodology used to develop the proposed service fees is denied.
4. SCE's request for approval to eliminate the discretionary/non-discretionary categorization of DA and other service fees is denied.
5. SCE's request for approval to eliminate Full Consolidated Electric Service Provider (ESP) Billing services, Partial Consolidated ESP Billing, and Exception Services is denied.
6. SCE's request for approval of its proposed Direct Access Service Request (DASR) fees is denied.
7. SCE's request for approval to price ESP Termination services on a time and materials basis is denied.
8. Until fees are approved for the non-discretionary DASR services, voluntary and involuntary ESP Termination services, ESP Service Establishment services, CISR services, ESP Non-Energy Billing Receivables services, Meter Establishment services or the non-discretionary services contained in the proposed Monthly Account Maintenance Fee (MAMF), the incremental costs to provide these services may be booked to a memorandum account pending a Commission decision regarding the appropriateness of such costs and their recovery.
9. SCE is authorized to file a Tier 2 advice letter to establish a memorandum account and subaccounts to track the costs of providing non-discretionary DASR services, voluntary and involuntary ESP Termination services, ESP Service Establishment services, CISR services, ESP Non-Energy Billing Receivables services, Meter Establishment services, or the non-discretionary services contained in the proposed MAMF, pending further Commission action. If SCE chooses to establish a memorandum account or subaccounts for this purpose, SCE shall file the advice letter within 60 days of the effective date of this decision. The advice letter shall become effective upon approval of the Energy Division.
10. In its current GRC and future GRCs SCE shall remove the costs for non-discretionary DA services from bundled service customer rates, including costs for Full Consolidated ESP Billing services, Partial Consolidated ESP billing services, Exception services, DASR services, voluntary and involuntary ESP Termination services, ESP Service Establishment services, CISR services, ESP Non-Energy Billing Receivables services, Meter Establishment services, and the non-discretionary services contained in the propose MAMF.
11. SCE's request for approval to use the advice letter process for establishing new service fees for non-discretionary services is denied.
12. SCE's request for approval to use the advice letter process for establishing new discretionary products and services is approved. SCE shall file a Tier 3 advice letter to request authority to establish new discretionary products or services.
13. The Energy Division shall convene and facilitate a meeting between SCE, AReM, CMTA, and other interested parties within sixty (60) days of the effective date of this decision to consider issues surrounding DA process improvements at SCE, including the timing for implementing any recommended improvements that may not be cost effective now at the currently low DA volumes but which may become cost effective if the suspension on enrolling new DA customers is lifted and the volume of transactions increases. Additional meetings should be scheduled thereafter, as appropriate. Participants shall not be compensated for their participation or reimbursed for their out-of-pocket expenses.
14. SCE, AReM and CMTA shall submit a joint report that identifies specific potential process improvements, proposes recommendations for SCE's DA process improvements, and recommendations for an ongoing process to consider possible future process improvements that reflect the needs and interests of all DA market participants in SCE territory. Participants may submit with the report their comments addressing any disagreements or reservations that participants may have with any recommendations or other aspects of the report. The report shall be submitted in R.07-05-025 for consideration if, and when, Phase III of that proceeding is commenced.
15. Application 07-01-045 is closed.
This order is effective today.
Dated May 15, 2008, at San Francisco, California.
MICHAEL R. PEEVEY
President
DIAN M. GRUENEICH
JOHN A. BOHN
RACHELLE B. CHONG
TIMOTHY ALAN SIMON
Commissioners
Proposed and Approved Services and Fees
(A) Product/Service |
(B) Current Fee |
(C) Proposed Fee |
(D) Adopted Fee179 |
(E) Category of Service |
ESP Service Establishment Fees180 | ||||
ESP Establishment Fee |
New |
$747.00 per occ. |
Not Approved |
Non-discretionary |
Credit Establishment Fee |
New |
$221.00 per occ. |
Not Approved |
Non-discretionary |
Electronic Data Exchange Testing Fee (hourly rate) |
New |
$80.70 per occ. |
Not Approved |
Non-discretionary |
| ||||
Customer Information Service Request (CISR) Fees181 | ||||
Process Base CISR request |
New |
$15.90 per occ. |
Not Approved |
Non-discretionary |
Provide Cumulative Usage Data - Base |
New |
$10.00 per occ. |
Not Approved |
Non-discretionary |
Provide Cumulative Usage Data - per SA |
New |
$0.52 per acct. |
Not Approved |
Non-discretionary |
Provide Interval Usage Data - Base |
New |
$5.87 per occ. |
Not Approved |
Non-discretionary |
Provide Interval Usage Data - per SA |
New |
$6.07 per acct. |
Not Approved |
Non-discretionary |
| ||||
Direct Access Service Request (DASR) Fees182 | ||||
Connect DASR <20 kW |
New |
$8.19 per occ. |
Not Approved |
Non-discretionary |
Connect DASR >20 kW |
New |
$16.80 per occ. |
Not Approved |
Non-discretionary |
Disconnect DASR Fee |
New |
$8.56 per occ. |
Not Approved |
Non-discretionary |
Cancellation DASR Fee |
New |
$8.22 per occ. |
Not Approved |
Non-discretionary |
Reschedule DASR Fee |
New |
$11.10 per occ. |
Not Approved |
Non-discretionary |
Update DASR Fee |
New |
$7.05 per occ. |
Not Approved |
Non-discretionary |
ESP to ESP Switch Fee |
New |
$8.26 per occ. |
Not Approved |
Non-discretionary |
| ||||
UDC Consolidated Billing Fees | ||||
Bill by Mail Fee |
$0.63 |
$0.18 per acct/mo. |
$0.18 per acct/mo. |
Discretionary |
Bill by Internet Fee |
New |
$0.16 per acct/mo. |
$0.16 per acct/mo. |
Discretionary |
EDI VAN Charge Fee |
New |
$0.26 per occ. |
$0.26 per occ. |
Discretionary |
Additional Page Charge Fee |
New |
$0.26 per occ. |
$0.26 per occ. |
Discretionary |
Bill by EDI Fee |
$0.56 |
Remove |
Remove |
Discretionary |
Summary by Mail Fee |
$0.69 |
Remove |
Remove |
Discretionary |
Summary by Diskette Fee |
$0.56 |
Remove |
Remove |
Discretionary |
Meter Reading Fees | ||||
Meter and Data Management (MDMA) Service Fees | ||||
IDR Meter MDMA Fees | ||||
Zone 1 |
$3.69 |
$4.86 per acct/mo. |
$4.86 per acct/mo. |
Discretionary |
Zone 2 |
$3.88 |
$5.12 per acct/mo. |
$5.12 per acct/mo. |
Discretionary |
Zone 3 |
$4.06 |
$5.28 per acct/mo. |
$5.28 per acct/mo. |
Discretionary |
Zone 4 |
$4.31 |
$5.42 per acct/mo. |
$5.42 per acct/mo. |
Discretionary |
Zone 5 |
$4.81 |
$5.67 per acct/mo. |
$5.67 per acct/mo. |
Discretionary |
Unscheduled Meter Read Fees (Interval) | ||||
Unscheduled Meter Read (IDR Meter) | ||||
Zone 1 |
$8.75 |
$5.73 per occ. |
$5.73 per occ. |
Discretionary |
Zone 2 |
$11.30 |
$10.80 per occ. |
$10.80 per occ. |
Discretionary |
Zone 3 |
$13.80 |
$13.70 per occ. |
$13.70 per occ. |
Discretionary |
Zone 4 |
$17.50 |
$16.60 per occ. |
$16.60 per occ. |
Discretionary |
Zone 5 |
$23.80 |
$21.50 per occ. |
$21.50 per occ. |
Discretionary |
Unscheduled Meter Read (Cumulative Meter) | ||||
Zone 1 |
New |
$4.46 per occ. |
$4.46 per occ. |
Discretionary |
Zone 2 |
New |
$9.50 per occ. |
$9.50 per occ. |
Discretionary |
Zone 3 |
New |
$12.50 per occ. |
$12.50 per occ. |
Discretionary |
Zone 4 |
New |
$15.30 per occ. |
$15.30 per occ. |
Discretionary |
Zone 5 |
New |
$20.30 per occ. |
$20.30 per occ. |
Discretionary |
3. Meter Data Posting Fee |
New |
$0.25 per occ. |
$0.25 per occ. |
Discretionary |
ESP Termination of Service Fees183 | ||||
Voluntary Termination Fee |
New |
T/M |
Not Approved |
Non-discretionary |
Involuntary Termination Fee |
New |
T/M |
Not Approved |
Non-discretionary |
| ||||
Miscellaneous Fees | ||||
Monthly Account Maintenance Fee |
New |
$1.35 per acct/mo. |
Not Approved |
Non-discretionary |
ESP Non-Energy Billing (NEB) Receivables Fee |
New |
$5.79 per ESP/mo. |
Not Approved |
Non-discretionary |
Special Services Request Fee184 |
New |
T/M |
T/M |
Discretionary |
Miscellaneous Customer Notification Fee |
$0.41 |
$0.46 per occ. |
$0.46 per occ. |
Discretionary |
Metering Fees | ||||
IDR Meter Sales for Customer-Ownership Fees | ||||
Basic I |
$490.00 |
$194.00 per occ. |
$194.00 per occ. |
Discretionary |
Basic I with pulse |
new |
$240.00 per occ. |
$240.00 per occ. |
Discretionary |
Basic I with modem |
$913.00 |
$329.00 per occ. |
$329.00 per occ. |
Discretionary |
Basic I with pulse & modem |
new |
$368.00 per occ. |
$368.00 per occ. |
Discretionary |
Advanced I |
$505.00 |
$270.00 per occ. |
$270.00 per occ. |
Discretionary |
Advanced I with pulse |
$605.00 |
$328.00 per occ. |
$328.00 per occ. |
Discretionary |
Advanced I with modem |
$769.00 |
$417.00 per occ. |
$417.00 per occ. |
Discretionary |
Advanced I with pulse & modem |
$828.00 |
$455.00 per occ. |
$455.00 per occ. |
Discretionary |
Basic I+ special |
$584.00 |
Remove |
Remove |
Discretionary |
Basic II+ with modem |
$1,923 |
Remove |
Remove |
Discretionary |
Pulse Meter (includes installation) |
$1,228 |
Remove |
Remove |
Discretionary |
Meter Installation Fees | ||||
IDR Meter |
$119.00 |
$232.00 per occ. |
$232.00 per occ. |
Discretionary |
IDR Meter with Pulse |
$119.00 |
$300.00 per occ. |
$300.00 per occ. |
Discretionary |
IDR Meter with Modem |
$148.00 |
$309.00 per occ. |
$309.00 per occ. |
Discretionary |
IDR Meter with Pulse and Modem |
$185.00 |
$355.00 per occ. |
$355.00 per occ. |
Discretionary |
Basic I+ special |
$119.00 |
Remove |
Remove |
Discretionary |
Basic II+ with modem |
$268.00 |
Remove |
Remove |
Discretionary |
Advanced I |
$173.00 |
Remove |
Remove |
Discretionary |
Advanced I (with Pulse Output) |
$173.00 |
Remove |
Remove |
Discretionary |
Advanced I (with Modem) |
$185.00 |
Remove |
Remove |
Discretionary |
Meter Establishment Fee185 |
New |
$5.41 per occ. |
Not Approved |
Non-Discretionary |
Meter Maintenance Service Fees | ||||
IDR Meter Maintenance Service Fees for Billing Meters | ||||
Basic I |
$5.94 |
$2.30 per acct/mo. |
$2.30 per acct/mo. |
Discretionary |
Basic I with pulse |
$5.94 |
$2.43 per acct/mo. |
$2.43 per acct/mo. |
Discretionary |
Basic I with modem |
$9.69 |
$2.66 per acct/mo. |
$2.66 per acct/mo. |
Discretionary |
Basic I with pulse & modem |
new |
$2.77 per acct/mo. |
$2.77 per acct/mo. |
Discretionary |
Advanced I |
$7.75 |
$2.51 per acct/mo. |
$2.51 per acct/mo. |
Discretionary |
Advanced I with pulse |
$7.75 |
$2.66 per acct/mo. |
$2.66 per acct/mo. |
Discretionary |
Advanced I with modem |
$10.40 |
$2.90 per acct/mo. |
$2.90 per acct/mo. |
Discretionary |
Advanced I with pulse & modem |
$10.40 |
$3.01 per acct/mo. |
$3.01 per acct/mo. |
Discretionary |
Basic I Special |
$3.94 |
Remove |
Remove |
Discretionary |
Basic II+ (with Modem) |
$20.60 |
Remove |
Remove |
Discretionary |
Pulse Meter |
$4.38 |
Remove |
Remove |
Discretionary |
IDR Meter Maintenance Service Fees for Non-Billing Meters | ||||
Basic I |
New |
$3.39 per acct/mo. |
$3.39 per acct/mo. |
Discretionary |
Basic I with pulse |
New |
$3.52 per acct/mo. |
$3.52 per acct/mo. |
Discretionary |
Basic I with modem |
New |
$3.76 per acct/mo. |
$3.76 per acct/mo. |
Discretionary |
Basic I with pulse & modem |
New |
$3.86 per acct/mo. |
$3.86 per acct/mo. |
Discretionary |
Advanced I |
New |
$3.60 per acct/mo. |
$3.60 per acct/mo. |
Discretionary |
Advanced I with pulse |
New |
$3.75 per acct/mo. |
$3.75 per acct/mo. |
Discretionary |
Advanced I with modem |
New |
$3.99 per acct/mo. |
$3.99 per acct/mo. |
Discretionary |
Advanced I with pulse & modem |
New |
$4.10 per acct/mo. |
$4.10 per acct/mo. |
Discretionary |
IDR Meter Test Fee | ||||
Single Phase |
$110.00 |
Remove |
Remove |
Discretionary |
Three Phase (kWh only) |
$128.00 |
Remove |
Remove |
Discretionary |
Three Phase (kWh/kVARh) |
$203.00 |
Remove |
Remove |
Discretionary |
Special IDR Meter Test |
New |
$176.00 per occ. |
$176.00 per occ. |
Discretionary |
Meter Removal Service Fee |
$123.00 |
$119.00 per occ. |
$119.00 per occ. |
Discretionary |
Third Party Return of an SCE Meter Penalty Fee |
$344.00 or Current Replacement Cost |
Replacement Cost of the Removed Meter |
Replacement Cost of the Removed Meter |
Discretionary |
Return to Third Party Single Phase Meter Fee |
$12.50 |
Remove |
Remove |
Discretionary |
Return to Third Party 3 Phase Meter Fee |
$16.30 |
Remove |
Remove |
Discretionary |
Meter Replacement with a Standard SCE IDR Meter Fee |
New |
$228.00 per occ. |
$228.00 per occ. |
Discretionary |
Meter Replacement>200 kW & <500 kW |
$210.00 |
Remove |
Remove |
Discretionary |
Meter Replacement>500 kW |
$268.00 |
Remove |
Remove |
Discretionary |
Meter Replacement with Standard SCE Demand Meter Fee |
New |
$185.00 per occ. |
$185.00 per occ. |
Discretionary |
Meter Replacement<200 kW |
$133.00 |
Remove |
Remove |
Discretionary |
Engineering Estimate or Job Design Fee |
New |
$44.00 per occ. |
$44.00 per occ. |
Discretionary |
Acceptance Testing of Customer-Owned Meters Fee |
New |
$45.00 per occ. |
$45.00 per occ. |
Discretionary |
Incomplete Trip Fee |
$78.80 |
$89.00 per occ. |
$89.00 per occ. |
Discretionary |
Investigation and Scheduling Fee |
$32.50 |
T/M |
T/M |
Discretionary |
Material Handling Fee |
$28.80 |
T/M |
T/M |
Discretionary |
Pulse Adapter Equipment and Installation Fee |
New |
$245.00 per occ. |
$245.00 per occ. |
Discretionary |
Dual Socket Adapter Equipment and Installation Fee | ||||
Dual Socket Adapter Device Fee |
$390.00 |
T/M |
T/M |
Discretionary |
Dual Socket Adapter Device Installation Fee |
$368.00 |
T/M |
T/M |
Discretionary |
A-Base Panel Equipment and Installation Fee |
$31.30 |
Remove |
Remove |
Discretionary |
Temporary Metering Charge | ||||
1st Month |
$393.00 |
Remove |
Remove |
Discretionary |
Each additional month |
$159.00 |
Remove |
Remove |
Discretionary |
Partial Consolidated ESP Billing Service Fees186 | ||||
VAN Transmission of Data Charge |
$0.15 |
Remove |
$0.15 |
Non-Discretionary |
EDI Bank Processing Charge |
$2.25 |
Remove |
$2.25 |
Non-Discretionary |
EDI Van Fee for Payment Charge |
$2.75 |
Remove |
$2.75 |
Non-Discretionary |
Daily Check for Payment Charge |
$73.80 |
Remove |
$73.80 |
Non-Discretionary |
Full Consolidate ESP Billing Service Fees187 | ||||
Hourly Rate to Assist ESPs with Rates and Systems |
$106.00 |
Remove |
$106.00 |
Non-Discretionary |
Billing Set-up and Ongoing Support |
T/M |
Remove |
T/M |
Non-Discretionary |
Exception Services Fees188 | ||||
Retrieval of Account Information Charge |
$6.25 |
Remove |
$6.25 |
Non-Discretionary |
Routine Account Analysis Charge |
$12.50 |
Remove |
$12.50 |
Non-Discretionary |
Complex Account Analysis Charge |
$56.30 |
Remove |
$56.30 |
Non-Discretionary |
Resend File/Report Charge |
$18.80 |
Remove |
$18.80 |
Non-Discretionary |
Investigate EDI Payments Charge |
$106.00 |
Remove |
$106.00 |
Non-Discretionary |
Refund account credits due to overpayment EDI Charge |
$6.25 |
Remove |
$6.25 |
Non-Discretionary |
Involuntary Billing Change Charge |
$10.00 |
Remove |
$10.00 |
Non-Discretionary |
(End of Appendix A)
179 Adopted fees are approved as indicated in Column D, except for those fees previously approved in Res. E-3582.
180 Services must be provided, but no fees may be charged for non-discretionary services except as authorized in Res. E-3582. Costs for non-discretionary services may be recorded in a memorandum account.
181 Id.
182 Id.
183 Id.
184 Fees shall not be applied to requests for non-discretionary services except as authorized in Res. E-3582. Costs for non-discretionary services may be recorded in a memorandum account.
185 Services must be provided, but no fees may be charged for non-discretionary services except as authorized in Res. E-3582. Costs for non-discretionary services may be recorded in a memorandum account.
186 Services must continue to be provided and charged as authorized by Res. E-3582. Costs for non-discretionary services may be recorded in a memorandum account.
187 Id.
188 Id.
