IV. Should the Commission Adopt a Uniform Statewide
Rate Structure for the Discount?

The parties agree that there are no differences in utility rate design methodology (fixed charges, minimum bill, etc.), billing practices or other differences among utilities that preclude the use of a uniform statewide rate structure for the discount. We see no reason to disagree.

PG&E and Sempra take no position on whether a uniform statewide rate structure for the discount should be adopted. However, if one is adopted, they recommend a uniform amount per space per day. SCE believes that there is no need to adopt a uniform statewide rate structure for the discount. However, it too recommends that if one is adopted, it should be a uniform amount per space per day. TURN recommends that a uniform amount per space per day should be adopted for PG&E, SCE, SDG&E, and So Cal Gas. For the smaller utilities, it recommends they retain their current rate structures. WMA recommends that a uniform amount per space per day should be adopted for all utilities. The Latino Issues Forum (LIF) takes no position on this issue.

The discounts for the major utilities are set in amounts equivalent to a fixed amount per space per day. The smaller utilities discounts generally amount to a uniform amount per space per month. A fixed amount per space per month is easily converted to a fixed amount per space per day. As a result, there is no reason not to require the discount to be structured as a uniform amount per space per day. Therefore, we will require that the discount be set as a uniform amount per space per day.