INDIVIDUAL TRACKING OF AB 265 BALANCES

SDG&E opposes the individual tracking of AB 265 balances on bills monthly, on an individual customer basis. It also opposes allowing customers to make optional payments on their individual AB 265 balances. SDG&E believes that the requirements for individual accounting are premature and unnecessary, and should not be addressed by the Commission prior to a decision on SDG&E's surcharge filing (A.01-01-044).

SDG&E argues that the bill information might be misleading to customers since the final balance cannot be determined at this time, as there are adjustments that are not reflected in the ERCRSA (Energy Rate Ceiling Sub-account). SDG&E believes that these adjustments, which are contained in other balancing accounts (e.g., the TCBA and the PECA), need to be included in developing the AB 265 balance. We disagree. Future determinations on other balancing accounts do not deter SDG&E from displaying individual customers' AB 265 benefits. Customers will not be disturbed by refunds that might occur later following reasonableness reviews. SDG&E views the optional payment provision as complex, costly, and very time-consuming and complains that it is imposed without allocating the money and manpower for implementation.

The complexity of individual tracking and the optional payment provision at this point are likely to outweigh their benefits. Moreover, returning DA customers should be treated the same as any new customer who moves to SDG&E service territory. No party has argued that such customers should be exempt from the recovery of the undercollection.

ARM argues that customers who continue to receive direct access service should not be assessed for any portion of the SDG&E's undercollection. SDG&E agrees with AReM that DA customers who never receive the AB 265 rate cap should not be required to pay any portion of the resultant undercollection. But SDG&E points out that " DA customers that switched from bundled service to DA during the AB 265 period have received benefits under AB 265." We clarify that DA customers shall have no responsibility for repaying any portion of the SDG&E Energy Rate Ceiling Sub-Account. Customers who have switched back to utility bundled service will be responsible for repayment of undercollections resulting from the AB 265 rate cap. have been free to switch back and forth between DA and SDG&E bundled service since June 2000, when the AB 265 benefit became effective. Therefore, in response to SDG&E's point, the DA repayment exemption is a rough but expedient means of addressing the equity issue for DA customers that were excluded from the Plan.