4. Comments on Petition
The California Center for Sustainable Energy (CCSE), the Commission's Division of Ratepayer Advocates (DRA), PG&E and The Utility Reform Network (TURN) filed comments on the petition.
PG&E expresses support for the petition because it would give the IOUs flexibility to manage and adjust their CSI revenue requirements. Nevertheless, PG&E explains that it does not seek to suspend its own collections for CSI in 2009 because it has less carryover funds from SGIP than the Joint Petitioners, and PG&E has experienced high demand for CSI incentives. TURN expresses strong support for the petition, noting that a suspension of collections will benefit ratepayers by limiting rate increases in 2009 while not jeopardizing payment of CSI incentives or the future success of the program. CCSE states it does not oppose the petition.
DRA's comments take a more cautious tone. Rather than supporting the petition, DRA notes that ratepayers are neutral with respect to the level of funds held in the CSI balancing accounts as long as they receive interest on their funds. In other words, any interest accrued in these accounts now can offset future revenue collections, ultimately decreasing the dollar amount that must be collected from ratepayers in the future to fund CSI.5 DRA also observes that if the petition is granted and CSI funds are not collected in 2009, the funds will need to be recovered in later years. Therefore, DRA questions whether future rate increases to make up for a lack of collections in 2009 are in the ratepayers' interest. Finally, DRA expresses concern that Joint Petitioners could be attempting to mask the rate effects of their separately filed applications to invest in photovoltaic (PV) systems, which, if granted, could have an affect on rates.6 According to DRA, if a suspension of CSI collections lowers electric rates, this could make any rate effects from the utilities' own PV applications more palatable.
Joint Petitioners responded on October 24, 2008. They state the petition is intended to provide rate relief to their customers in 2009 and is not intended to promote either of Joint Petitioners' solar applications.
5 DRA questions whether SCE is properly accruing interest in its CSI balancing account because Attachment B of the petition does not show any interest accrual by SCE after March 2008. In response, Joint Petitioners state that the tariff for SCE's CSI balancing account indicates the account earns interest on an annual basis. Interest will be recorded for the entire year on December 31st of each year, rather than monthly. Thus, it appears that SCE is properly handling interest for its CSI balancing account.
6 See SCE's Application (A.) 08-03-015 and SDG&E's A.08-07-017.
