Phase One Issues - Policy and Implementation of AB 1002

We adopt the following unopposed Workshop Report recommendations requiring the utilities to:


a. Identify all customers exempt from paying the surcharge and establish procedures to prevent surcharge billing of exempt customers.


b. Recompense exempt customers who previously paid the surcharge. Amounts returned to exempt customers should include applicable balancing account interest.


c. Publish the approved surcharge by customer class, including exemptions, in a separate tariff rate schedule.


d. Present the surcharge as a separate line item on customers' invoices with a description of the surcharge purpose.6


e. Submit annual advice letters (AL) by October 31 with proposed surcharge rates.7 ALs shall include workpapers showing the derivation of the surcharge rates, supporting documentation for any forecasts, and citations identifying commission decisions authorizing each element of the proposed rates (e.g., authorized PPP costs, split between gas and electric operations, etc.)


f. Use the most recently adopted PPP budgets for the calculation of proposed surcharge rates. If a current program year budget for California Alternative Rates for Energy (CARE) subsidy costs has not been adopted by the Commission, utilities may use forecasts of expected CARE subsidy costs based on a reasonable estimate of future gas prices (using a credible, published source) and CARE customer penetration rates. Balancing account amortization shall be in accordance with prevailing Commission policy (e.g. whether over-collections should be carried-over, etc.).


g. Return exempt customer surcharge revenue collected between January 1, 2001, and July 1, 2001, including interest. Amounts will be returned from utilities to the affected exempt customers.8


h. Modify balancing and memorandum accounts, if necessary, to implement the unbundling of PPP costs from rates. Requested revisions should not seek to change the nature of any account currently authorized by the Commission (e.g., one-way or two-way balancing account, carry forward of over collections, etc.). Any requested accounting changes shall be made via an AL within 30 days of the effective date of this decision.


i. Each balancing account shall specify that while the surcharge collections are in the possession of the State, the applicable interest that applies is the actual amount of interest that accrued while the remittances were on deposit in the Fund.

In addition, we adopt the following unopposed Workshop Report recommendations for implementing AB 1002:


a. The use of the default rate will be discontinued. All utilities should calculate surcharge rates based on their specific PPP costs.9


b. Utilities may request a change in surcharge rates during the year. Such rate changes are only justified if failure to make the rate change would result in a forecasted total rate increase of 10% or more on January 1 of the next year. Requested rate changes will be through the AL process. The AL must include justification for the rate change and be filed at least 40 days prior to the beginning of the next quarter with an effective date to be determined by the Energy Division in consultation with BOE.10


c. Non-exempt interstate pipeline customer remittances to BOE, including applicable interest, are to be returned to the public utility in whose service territory the customer resides, and recorded in the appropriate PPP balancing accounts.


d. Utilities should receive interest accrued in the Fund, and credit this interest to PPP balancing accounts.

Below we discuss Workshop Report proposals of the Energy Division, which parties contested in their comments, or which require clarification.

PG&E and Sempra believe that the surcharge is a tax. In support of their position, they point to the analysis by BOE's legal staff,11 and the Legislative Counsel's Digest,12 both of which find the surcharge is a tax. PG&E adds that BOE is directed to "administer the surcharge imposed pursuant to this article in accordance with the Fee Collection Procedures Law Part 30 (commencing with Section 55001) of Division 2 of the Revenue and Taxation Code." (Section 2, Revision to Public Utilities Code Section 893), and that Public Utilities Code Section 896 states "Consumption does not include the consumption of natural gas which this state is prohibited from taxing under the United States Constitution or the California Constitution."13

PG&E explains that there are four differences between taxes and fees:

1. A tax is not treated as revenue by the utility, whereas a fee is treated as revenue by the utility when it is billed.

2. A tax resides in a liability account and is recognized as revenue when claims are returned to the utility, whereas a fee (utility revenue) is recorded in an interest-bearing account when it is billed.

3. Franchise fees are not assessed on tax-related revenue, whereas franchise fees are assessed on non-tax related revenue (fee).

4. A tax does not apply to customers exempted by the U.S. and California Constitutions, but a fee would apply to all customers except for those specifically exempted.

Avista argues that the surcharge is a fee and not a tax. Avista asserts the surcharge lacks key elements that would define it as a tax, including, legislative taxing authority, administration, and use of the proceeds.

Southwest also believes the surcharge is a fee, and contends that a tax is a charge against an individual, property or activity for the support of the government, and that taxes are levied for the benefit of the general public. Alternatively, Southwest maintains that fees or surcharges serve a regulatory purpose, must be proportionate to the costs of the service or product and are imposed on those benefiting from the service or product supported by the fee. Southwest notes that the surcharge has characteristics of both fees and taxes; however in this instance, there is a specific regulatory purpose for the fees (surcharges) as opposed to revenue collection.

We note the surcharge contains elements of both fees and taxes, and AB 1002 uses both terms in describing the surcharge. However, we find that it is unnecessary to make that determination in order to address the issues raised by parties. For example, Sections 890(b) and 898, clearly specify those customers who pay the surcharge and those customers that are exempt. In addition, because the bill was passed into law by more than a two-thirds vote, we need not be concerned with the classification of the surcharge as a tax or fee for purposes of determining the validity of its enactment.14 Therefore, we decline to find whether the surcharge is a tax or a fee, and instead we will direct utilities in those matters not addressed by AB 1002, including accounting and franchise fees.15

The Workshop Report recommends that BOE return remittances to utilities after a year-end review of surplus amounts in the Fund. However, the utilities16 recommend that BOE remittances be returned in full to utilities during the year, so that over-collections may be retained by utility customers.

Sempra argues that when the non-remitted funds remain at BOE, ratepayers do not receive associated interest. Furthermore, leaving excess funds at BOE introduces too much uncertainty into excess fund balances that could result in cross-subsidization between utilities or loss of the funds to the California General Fund. Sempra prefers that funds are returned within 30 to 45 days of remittance to BOE.

PG&E recommends returning funds to utilities on at least a quarterly basis. PG&E points out that the recommended policy of the Workshop Report17 would result in an additional administrative layer, and potential funding of PPP by the utility, or payment of an excess surcharge by ratepayers. PG&E points out that funds remitted from BOE to the utilities remain in balancing accounts fully subject to the Commission's jurisdiction.

Southwest asserts that customer surcharge revenue must be returned in full to utilities in order that shareholders not pay for certain PPP costs. Southwest explains that because the Low-Income Energy Efficiency (LIEE) program is a one-way balancing account, if LIEE program costs in any year exceed reimbursements from the surcharge, and the excess revenues are not remitted to the utilities, then shareholders pay for any excess costs. Southwest also notes that to the extent CARE costs are less than CARE revenues, customers funding CARE costs should receive the benefit of any overcollection.

We agree with the utilities that all funds remitted to BOE should be returned to the utilities in a timely manner, except for R&D funds that should be paid to the R&D administrator, BOE and Commission administration costs, and deductions for any refunds issued by BOE.18 Since remittances to BOE are done quarterly, dispersals from the Fund shall be conducted on a quarterly basis as well. We share the utilities' concerns regarding excess funds, and desire that all collected funds be available to the utilities for PPP costs. Therefore, the Energy Division should work with BOE, other appropriate state agencies and the utilities19 to accomplish the timely return of surcharge remittances, including interest accrued in the Fund, to the utilities.20 These funds are to be recorded to the appropriate PPP balancing accounts. Interest should be apportioned to utilities according to the amount of remittances and the length of time remittances were held in the Fund and invested from the implementation of AB 1002 on January 1, 2001. Energy Division shall also work with BOE or other appropriate state agency to establish utility specific accounts in the Fund.

PG&E filed AL 2440-G on January 27, 2003, and AL 2440-G-A on May 26, 2004, to separately identify PPP revenue requirements from other base revenue and establish a new memorandum account to track surcharge collections remitted to BOE. PG&E's AL 2440-G and AL 2440 - G - A is approved subject to the following modifications:

1. The proposed preliminary statement referred to as "PPP-EE/LIEE/RDD" describing the accounting treatment of energy efficiency, LIEE, and R&D must be structured so that each PPP has a separate and distinct balancing account, and maintains the authorized treatment and amortization of any balances. (e.g., one-way balancing account, etc.)

2. Each balancing account shall specify that the amortization of any balance is in accordance with the policies established by the Commission for the treatment of these funds.

3. Each balancing account shall specify that while the surcharge collections are in the possession of the State, the applicable interest that applies is the actual amount of interest that accrued while the remittances were on deposit in the Fund.

PG&E shall file a supplement to AL 2440-G - A within 30 days of the effective date of this decision reflecting these modifications.

Although the Workshop Report recommends using past gas usage to calculate the surcharge, PG&E and Sempra recommend the continued use of Biennual Cost Allocation Proceeding (BCAP) estimates for "throughput" volumes of gas.22

Sempra points out that BCAP volumes are more accurate estimates since they are weather adjusted, and thus will reduce potential interim rate changes. Sempra also notes that BCAP estimates have been reviewed and approved by the Commission.

PG&E argues that there is nothing in the language in AB 1002 to prohibit the use of BCAP estimates. PG&E also recommends that the Energy Division provide the utilities with exempt gas volumes, and interstate gas pipeline volumes so that utilities can adjust their estimated surcharge rates. In order to file timely ALs, so that surcharge rates can be effective January 1 for each surcharge year, PG&E believes information should be supplied by the Energy Division to the utilities. PG&E recommends that this information be provided by August 31 of the year prior to the January 1 effective date.

Southwest, which does not have a BCAP, recommends use of test year gas volumes to calculate the most accurate surcharge rate.

We agree with the utilities that BCAP estimated throughput volumes, or recent test year estimates are the most accurate gas volume projections for calculating the surcharge. However, we are concerned that BCAP estimates may not be timely available for surcharge calculations due to delays in BCAP proceedings. In addition, for the smaller gas utilities, there are no BCAP proceedings to provide gas estimates, and the use of test year estimates, as proposed by Southwest, is of limited use in the years between test years. Therefore, we will adopt a method that uses BCAP estimates when these are available and are less than three-years old, and have been adopted by the Commission. In all other instances utilities should use a three-year average (consecutive 36 month period) based upon the most recently available billed gas volumes. Utilities should state in their surcharge calculations, which of these two estimating methods are used. Energy Division should also obtain interstate pipeline customer gas volumes,23 and provide these to the appropriate utilities for determining surcharge rates.

Surcharge rates should continue to be segregated by customer class based on CARE participation. Thus, two formulas are necessary to determine surcharge rates for CARE and non-CARE customers.

Derivation of the cost components of the PPP surcharge rates are:

CARE cost surcharge component = [CARE administration expenses + CARE subsidy + authorized CARE balancing account amortization]24/ [non-CARE, non-exempt utility + non-CARE, non-exempt interstate pipeline gas volumes by customer class]

LIEE + EE + R&D cost surcharge component = [Energy efficiency + LIEE + R&D expenses + authorized PPP non - CARE balancing account amortization25+ administrative costs]26/ [non-exempt utility + non-exempt interstate pipeline gas volumes by customer class]

Thus, the PPP surcharge rates are:

1) CARE customer surcharge rate = LIEE +EE + R&D cost surcharge component

2) Non-CARE customer surcharge rate = [LIEE +EE +R&D cost surcharge component] + [CARE cost surcharge component]

Utilities shall provide workpapers showing these calculations with citations identifying Commission authorization for program expenses and customer class cost allocations included in AL filings for proposed surcharge rates and related information. PPP expenses to be included in surcharge rates are those described under unopposed workshop report recommendations paragraph (f). Pipeline gas volumes to be used in the calculation are as described in this decision.

Utilities shall allocate PPP costs to customer classes pursuant to authorized procedures as updated in Commission allocation proceedings, except for R&D, and BOE and Commission administrative costs as discussed herein.

PG&E recommends that BOE or the Commission issue regulations defining exempt customers. PG&E would refund any surcharges paid by exempt customers, including applicable credit interest,27 directly to exempt customers. PG&E also recommends that BOE require interstate pipeline companies to identify non-exempt customers consistent with the status notification requirement under Section 891(d).

Sempra believes its current tariff procedures have identified exempt customers, and that current processes are sufficient to return any surcharges paid by exempt customers. Sempra requests that the Commission order a return of any surcharges collected from exempt customers paid during the first half of calendar year 2001. Sempra also recommends that the utilities return collected surcharges to exempt customers, and not BOE.

We note that Section 890(h) requires BOE to collect surcharges from non-exempt customers on interstate pipelines that might otherwise avoid surcharge payments, while Section 896 exempts certain customers from surcharge payments. In addition, exemptions include customer consumption of natural gas which this state is prohibited from taxing under the United States (U.S.) Constitution or the California Constitution.28 It is apparent from the Workshop Report, that adopting procedures implementing these two provisions has proven difficult.

In order to identify non-exempt customers on interstate pipelines, we request BOE to query all interstate pipeline companies29 for lists of customers and determine whether the customer qualifies for exemption under Section 896. The Energy Division should assist BOE in this effort, and utilities are directed to provide the names and address of interstate pipeline customers to BOE, if known. We also recognize California Energy Resources Surcharge Regulations 2315 and 2316, as identifying exempt customers under the California or U.S. Constitutions.

In order to identify all exempt customers, utilities are directed to review customer lists within six months of the effective date of this decision. Following this initial review, the utilities are directed to conduct an annual review of their customer accounts to identify any exempt customers. Questions regarding exemptions should be directed to BOE. All exempt customers should receive any past surcharges that have been paid, plus applicable balancing account interest. The utilities are responsible for these refunds in the event BOE has not made previous payments to these customers and shall notify BOE to prevent duplicate refunds.30 PG&E requests that language qualifying customers for exemption be included in the appropriate tariff, rather than on individual customer bills. As tariffs are intended to provide qualifications for service, this proposal is acceptable.

Southwest recommends that F&U be included in the surcharge rate. Southwest explains that it pays franchise fees on all revenue, including surcharge revenue. Thus, Southwest believes excluding franchise fees in surcharge calculations results in a mismatch between surcharge revenues paid to BOE and surcharge amounts collected from customers. Similarly, Southwest asserts that excluding uncollectibles from the surcharge also results in a mismatch between amounts paid and amounts collected from customers. Southwest points out that although uncollected amounts for CARE are recovered through the CARE balancing account, this is not true for LIEE uncollectibles. Southwest contends that since LIEE is a one-way balancing account, excluding uncollectibles from LIEE results in shareholders absorbing LIEE uncollectibles amounts.

PG&E agrees with the Workshop Report recommendation that F&U expenses are not directly related to PPP and therefore should not be included in the surcharge.

As explained in the Workshop Report, interstate pipeline customers are not obligated to pay franchise fees. In addition, franchise fees are not directly related to the PPP, and for these reasons no franchise fees should be paid on surcharge revenues. All utilities are directed to exclude surcharges in calculating franchise fee payments.

Although some surcharges will not be paid due to uncollectible customer revenues, Section 890 (2) addresses the problem of worthless accounts.31

As these two provisions provide for F&U, we determine that F&U should not be included in the calculation of the surcharge.

As a result of implementing AB 1002, newly exempt customers are no longer required to pay the surcharge, resulting in a shortfall in surcharge revenues. Sempra states that for SDG&E the shortfall amounts to $1 million per year. Sempra recommends that the re-allocation of the shortfall to non-exempt customers occur as part of this proceeding. Sempra argues that resolving this matter now minimizes future revenue shortfalls, and minimizes rate shock. Sempra also notes that its exempt customers paid the surcharge between January 1, 2001, and July 1, 2001, when the surcharge was included in Sempra's gas rates. As a result Sempra overcollected surcharge revenues in 2001.

The Energy Division recommends that this allocation of costs occur in the next BCAP, a position supported by PG&E.

R.02-10-001 is a quasi-legislative proceeding. Accordingly, some parties representing customer classes that might otherwise be interested in ratemaking have not participated in this proceeding. Therefore, although costs paid by exempt customers must be re-allocated to other customers, that re-allocation should occur in either a BCAP, or other appropriate ratemaking proceeding. Utilities that do not have BCAPs may file an AL to accomplish the re-allocation of PPP costs.

The Energy Division recommends that surcharge collections be deposited in an interest bearing account prior to remittance to BOE, a position supported by PG&E32 and other utilities, except Sempra. Sempra opposes this recommendation for two reasons. First, Sempra argues that the surcharge is a tax, and therefore is not revenue. Sempra asserts that taxes should not be recorded in interest bearing accounts. Secondly, Sempra contends that the Energy Division's proposal would require the addition of interest before the surcharge funds are received. In its comments, Sempra provides an illustration showing how revenue lags in customer payments result in the use of shareholder monies to fund shortfalls in revenue collections. Simply stated, Sempra remits approximately 3% of its billed revenues to BOE before these revenues are received. Although the revenue shortfall is eventually received, final receipt is many days after Sempra has made its remittances to BOE.

We have generally held that ratepayers should receive interest on deposited revenues in balancing accounts held by utilities. Typically, the interest on these accounts accrues at the three-month commercial paper rate. Although we have not determined whether the surcharge is a tax or a fee, we find no reason that the surcharge balancing accounts should not also accrue interest. Therefore, we will direct that interest be paid on surcharge amounts in the possession of utilities prior to remittance to BOE, and be credited to the appropriate PPP balancing accounts. In order to address Sempra's problem resulting from a timing difference between payments and collections, we note that utilities are provided a "working cash allowance," an adjustment to rate base in general rate cases (GRC).33 The need for a working cash allowance compensates investors for funds provided by them for the purpose of paying expenses in advance of receipt of offsetting revenues. As Sempra's problem appears to be a result of a delay in customer revenues, Sempra may pursue this matter in its next GRC.

The Energy Division recommends that Commission and BOE administrative costs be allocated to utilities according to the number of utilities remitting into the surcharge fund. Sempra and Avista recommend the allocation be based on gas volumes or a similar method. Avista points out that allocating administrative costs based on the number of utilities would result in Avista customers paying over 200 times the administrative costs paid by PG&E customers.

It would be unfair to small utility customers to allocate administrative costs based on the number of utilities paying into the Fund. We believe Sempra's and Avista's alternative administrative cost allocation method based on utility gas volumes is reasonable. Therefore, BOE and Commission administrative costs allocated to each utility shall be based upon each utility's proportion of the total amount of throughput reported to BOE used to calculate remittances for the prior calendar year. Costs to be included in the surcharge will be any uncollected amounts for prior year (s) expenses and expected costs for the upcoming year, adjusted for any previous overcollections. In order to include administrative costs in the January 1 surcharge rates, we will direct the Energy Division to obtain BOE and Commission administrative costs by September 30 of the prior year, and provide these costs to the utilities for their October 31 surcharge filings. Administrative costs shall be allocated to customer classes on an equal-cents-per-therm basis. We direct the utilities to identify Commission and BOE administrative cost amounts in their quarterly remittances to BOE. Utilities shall send copies of the quarterly remittances to the Energy Division showing the amounts collected for these costs, following filing with BOE.

Although parties have not identified any current interstate pipeline customers outside of existing utility service territories, identification of all interstate pipeline customers continues. Southwest hypothesizes the existence of non-exempt interstate pipeline customers who do not reside in any current utility service territory. If any interstate pipeline customers outside of existing utility service territories are identified, the surcharge rate of the nearest utility service territory should be applied to such customers. Accordingly, any surcharge amounts remitted to BOE from such customers should go to the utility whose service territory is nearest the customer.

Southwest explains that several customers in its Southern California division take all or most of their service from PG&E through PG&E's intrastate pipeline, although these customers are located in Southwest's service territory.34 Southwest argues that the surcharges paid by these customers should benefit customers in Southwest's service territory and not PG&E customers.

AB 1002 does not specifically address the disposition of surcharge funds when non-exempt interstate pipeline customers are served by one utility, but are located in the service territory of a different utility. However, Section 890(e) states "The Commission shall annually establish a surcharge rate for each class of customer for the service territory of each public utility gas corporation. A customer of an interstate gas pipeline, as defined in Section 891 shall pay the same surcharge rate as the customer would pay if the customer received service from the public utility gas corporation in whose service territory the customer is located. The Commission shall determine the total volume of retail natural gas transported within the service territory of a utility gas provider, that is not subject to exemption pursuant to Section 896, for the purpose of establishing the surcharge rate."

As this issue concerns intrastate pipeline customers, and we have previously determined that these are certificated PG&E customers,35 surcharge amounts should be collected by PG&E and used for PG&E PPP purposes.

Sempra and PG&E recommend that third party gas storage providers be required to provide lists of their non-utility end use customers in an effort to identify all non-exempt customers.

AB 1002 does not exempt customers of third party gas storage providers unless the customer qualifies for exemption under Section 896. Thus, third party gas storage non-exempt customers should be expected to pay the surcharge. In order that such customers may be identified, we will direct third party gas storage providers to provide customer lists to BOE and the Commission. Non-exempt customers of third party gas storage providers should be assessed the surcharge rate for the utility service territory in which they reside.37 Remittances from non-exempt third party gas storage customers should be returned to the utilities in whose service territory the third party gas storage customer resides.

6 We will allow utilities to make required billing system changes, along with regular monthly changes, following the six-month deadline for this modification. 7 Annual ALs will calculate proposed surcharge rates to be effective January 1. This date is changed from September 30, as approval will be by Energy Division, without need for a Commission resolution. 8 Prior to issuing refunds, the utilities should confer with BOE to ensure payments were not previously made by the Board, in which case the refunds shall not be made. 9 Utilities subject to the default rate shall file an AL containing their proposed cost based PPP surcharge rates according to the formula adopted herein which will be used for remittances to BOE and customer collections including associated tariff pages within 30 days of the effective date of this decision. Energy Division will determine the effective dates for the rates. 10 Energy Division shall notify BOE of surcharge rate changes. 11 Memorandum dated February 9, 2001, from Timothy Boyer, Chief Counsel, BOE, to Honorable Dean Andal finding that both the Natural Gas Consumption Surcharge and the Electric Energy Surcharge are taxes. (Workshop Report, Appendix E.) 12 Exhibit 8, p. 1. The Legislative Counsel finds that AB 1002 results in a change in state taxes within the meaning of Section 3 of Article XIII A of the California Constitution. 13 All references are to the Public Utilities Code unless otherwise noted. 14 Sinclair Paint v. State Bd. Of Equalization, 15 Cal. 4th 866, 873 (1997). 15 See Franchise Fees and Uncollectibles and Interest Bearing Account for Surcharge Collections. 16 PG&E, Avista, Sempra and Southwest. 17 The Workshop Report recommends the filing of an annual AL requesting return from BOE of excess funds; however it is unclear whether all of the excess funds would be returned to utilities. 18 BOE should inform the Energy Division of refund payments they issue. 19 Remittances from a municipality, district or public agency should be returned to the municipality, district or public agency, including applicable interest. (See Section 898.) 20 BOE should provide Energy Division copies of Natural Gas Surcharge Returns quarterly from all accounts, and information showing amounts remitted. 21 Also see Intrastate Pipeline customers served by a Utility Different from the Utility operating that Service Territory. 22 BCAPs usually are held every two years for PG&E, SoCalGas, and SDG&E. There are no BCAPs for the other gas utilities. 23 We expect BOE to provide copies of natural gas surcharge returns showing gas volumes used for remittances to the Energy Division by July 31 of each year. 24 Balancing Account amortization shall be in accordance with authorized PPP accounting methods. 25 Balancing Account amortization shall be in accordance with authorized PPP accounting methods. 26 Commission and BOE administrative costs. 27 PG&E requests that BOE calculate earned credit interest and the timing for the utility to make refunds. 28 See California Energy Resources Surcharge Regulations, Regulations 2315 and 2316, Workshop Report, Appendix D. 29 See Section 891(d). 30 We note BOE administers the surcharge in accordance with Section 893. Therefore, should a utility fail to issue a corrected billing, the customer should have the right to file a claim for refund with BOE. In order that duplicate refunds not occur, BOE should exchange information on customer refunds with the appropriate utility, for past and any future refunds. 31 Section 890(2) states, in part, "that a public utility is relieved from liability to collect the surcharge insofar as the base upon which the surcharge is imposed is represented by accounts which have been found worthless and charged off in accordance with generally accepted accounting principles. If the public utility gas corporation has previously paid the amount of the surcharge it may, under regulations prescribed by the State Board of Equalization, take as a deduction on its return the amount found to be worthless and charged off." 32 PG&E states that all PG&E surcharge revenues accrue interest regardless of when amounts are remitted to BOE. 33 See Commission Standard Practice U-16, Determination of Working Cash Allowance, September 13, 1968. 34 PG&E's intrastate pipeline runs through Southwest's service territory. PG&E is certificated to serve these customers. 35 See D.88-12-090. 36 Third party gas storage providers are regulated by the Commission as public utilities. (See Decision (D.) 03-04-038.) 37 Third party gas storage providers may be instructed by the Commission to bill these non-exempt customers.

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