3. The Petition
As support for their requests to change the dynamic pricing timetable and bifurcation of A.09-02-022, Petitioners provide the following reasoning:
· The Commission must consider this Application in the context of the current economy. It is too soon to say whether PG&E's cost or bill impact estimates are reasonable,4 but what is clear is that unnecessary increases in rates should be avoided or, at least, postponed. These are desperate economic times. Businesses have closed, many of PG&E's ratepayers have lost their jobs and their homes, and many more face an uncertain future. While dynamic pricing may be intended to "lower consumer costs," at this point, the only guarantee is that this proposal will increase costs to many medium and small commercial ratepayers of PG&E at a time when they can least afford it.
· While large commercial and industrial customers have interval meters and are already on time of use rates, many smaller customers will not have AMI until 2011 or 2012. Given the Commission's conclusion that "[i]t is reasonable for PG&E to provide a customer with maximum load less than 200 kW 12 months with a new advanced meter to observe its usage before moving to a default time-differentiated rate,"5 there is little benefit to be lost by deferring the implementation date to 2012 for medium and small commercial customers.
· As directed, PG&E has proposed a major overhaul of its tariffs. Given the complexity of the rate designs proposed by PG&E, informed customer choice requires that customers be provided ample time to understand the ramifications of the choices they are being offered, and to assess their possibilities to modify their energy consumption. All parties should be given sufficient time to evaluate PG&E's proposal to ensure, as far as possible, that the CPP/ PDP tariffs the Commission adopts will be fair, reasonable, and cost ratepayers as little as possible. Forcing PG&E and other parties to evaluate the complexities and ramifications of the proposed tariff changes pursuant to an abbreviated schedule set before the Application was filed does a disservice to the utility and to its ratepayers.
· Given the electric procurement outlook in the near-term, and the impact of the current economic difficulties in reducing demand, a near-term shortage of electric generation capacity appears improbable. Therefore, the near-term need for dynamic pricing appears to have diminished, allowing the Commission to extend the implementation schedule in order to fine-tune the rate design options for maximum customer acceptance.
4 DRA notes that PG&E is requesting revenue requirement increase for 2008 through 2010 of $32.1 million. In addition, many medium and small business customers will face other significant bill increases. For example, PG&E estimates that approximately 17% of customers currently on schedule A-1 will see additional annual bill increases from PDP rates of 8% or more during abnormal weather years, due to implementation of dynamic pricing via changes in rate design.
5 D.08-07-045, Conclusion of Law 14.
