Edison's Position

Edison sees this as a simple and straightforward case. City wants a larger bill adjustment than it already received, based on City's assertion that it should be allowed to choose the rate schedule for calculating that adjustment. It matters not to City, Edison says, that TOU-PA-5 is not comparable to the GS-2 schedule City was actually on; that City did not meet the prerequisites for receiving TOU-PA-5 service during the period in question; that City previously rejected an Edison recommendation to move to TOU-PA-5 four years ago that would have obviated this entire issue; and that allowing City to choose to apply TOU-PA-5 retroactively with assumed usages would be granting it the benefits of hindsight.

Edison's willingness to issue an adjustment was based on two factors. First, it was unusual for a pumping customer to take service under the GS-2 rate and Edison could not rule out error on its own part because it lacked historical records to prove that City actually chose to be on GS-2 many years ago. Second, Edison desired to maintain good customer relations. Even assuming billing error, Edison's tariffs do not grant a customer the right to choose just any rate for purposes of calculating a bill adjustment. Rather, the most comparable, applicable rate should be used. City may, in fact, not have been entitled to any adjustment at all, let alone an adjustment that contravenes Edison's tariffs and requires time-of-use meter data that is simply not available.

Edison asks the Commission to deny City's claim for an additional credit. It does not seek to have City return the $7,411.26 credit already granted.