3. Joint Petition for Modification

On September 12, 2008, SDG&E and SCE (or "Joint Petitioners") jointly filed a petition for modification of D.06-01-024 relating to the annual revenue requirement for CSI. The petition requests that the Commission allow SDG&E and SCE to temporarily suspend collection of CSI funds from its electric customers in 2009 and approve an Advice Letter process to effect any similar future temporary suspensions.

According to the petition, the revenue collected and credited to the CSI balancing accounts of SCE and SDG&E is much greater than the solar incentives and associated program administration costs paid out to date in the SCE and SDG&E territories. SDG&E expects an overcollection of approximately $90 million at the end of 2008, and SCE expects an overcollection of $343 million at the end of 2008. (Joint Petition, 9/12/08, p. 3, as corrected by Joint Response of SDG&E and SCE, 10/3/08, p. 4.) According to Joint Petitioners, large solar projects take as long as 24 months to complete and performance based incentives under CSI are paid out over a five year period, causing revenue collections to outpace incentive payments thus far under CSI.

To support their petition, Joint Petitioners describe how a temporary suspension of the collection of CSI funds will provide a rate decrease to their respective electric customers in 2009. They maintain this rate relief is in the best interest of their customers in these challenging economic times, and the proposal will have no impact on the incentive funds available for CSI operations as there are adequate funds in the CSI balancing account to fund the program until collections resume in 2010.⁴ Both utilities would resume collections for CSI on January 1, 2010. In addition, Joint Petitioners urge the Commission to establish an advice letter process to allow future consideration of revenue requirement adjustments and to recover the temporarily suspended 2009 funding at a later date.

Pursuant to Rule 16.4, if more than one year has elapsed since the effective date of the decision, a petition for modification must state the reason the petition could not have been filed within one year. Joint Petitioners state the petition arises from the significant lag in payment of CSI incentives over time, the current economic climate and the anticipated rate pressures on customers from higher electric commodity costs. Given the timing of these events, Joint Petitioners assert the petition could not have been filed sooner. Joint Petitioners' reasons for filing beyond the one year deadline are reasonable and we will accept the petition for consideration.

⁴ According to the petition, a typical SDG&E residential customer would see a bill reduction of $0.90 per month, or 1.2%, and a typical small commercial customer would see a bill reduction of $2.73 per month, or 1.0%. For SCE, a typical residential customer would see a bill reduction of $1.35 per month, or 2.1%, and a typical small commercial customer would see a bill reduction of $3.16 per month, or 1.3%. (Joint Petition of SDG&E and SCE, 9/12/08, pp. 4-5.)