supported the movement of May to the winter season based on 2015 and 2016 Default Load Aggregation Point (DLAP) wholesale prices and load data, and Exhibits JT-2 and JT-4 (discussed in Section 8. Rate Design, below) utilize the five-month summer season in their joint testimony. (Chart 4 from Exhibit SDG&E-11 at 27) SEIA opposes the switch from a six-month summer to a four-month summer as proposed by ORA. “SEIA reviewed 30 years (1985 - 2015) of data on daily high temperatures for 26 weather stations in the San Diego area, determining the percentage of daily high measurements that fell into the Extremely Hot (greater than or equal to 95 F) category.” (Exhibit SEIA-01 at 22.) Taken together, the SDG&E DLAP prices for 2015 and 2016 and the SEIA figure shows that historically May is much like non-summer months in terms of the frequency of very hot days, a typical driver of peak electric demands. While we agree that SEIA made a strong case that the trend for May is increasing frequency of very hot days, we agree with SDG&E and ORA that based on current load data, May more closely aligns to April, not June or July. For that reason, we adopt a five-month summer (June-October) and seven-month winter (November-May) season and direct SDG&E to implement this revised seasonal definition as soon as practicable following the issuance of a final CPUC decision. Base Time-of-Use Periods “Historically, TOU rate intervals were designed to reflect time variations in the cost to serve loads, with higher-priced periods during summer week-day
Because dimmable streetlights support California energy policy, the CPUC should tailor the adopted dimmable streetlight rate design to maximize participation. Because the targeted customers for this dimmable option have indicated that SDG&E’s proposed rate design will limit participation, we adopt monthly fees based on wattage as CALSLA proposes, not on a fixed charge per lamp as SDG&E proposes. A wattage-based rate will enable cities with lower-wattage lamps to participate and will provide customers with lamps motivation to implement conservation strategies for their streetlights. We do adopt the SDG&E proposed $8,000/city up-front participation payment, and find $2.3 million a reasonable estimate for start-up implementation costs. We direct SDG&E to implement the dimmable streetlight rate option, as modified above, as soon as practicable following the issuance of a final CPUC decision. While it is unclear whether CALSLA’s proposed wattage-based rates, in combination with the up-front per city payment, will adequately collect the revenue allocated to the streetlighting customer class, a key component of SDG&E’s dimmable rate proposal is the inclusion of a memorandum account, which will record the implementation and ongoing maintenance costs of the rate program and revenue shortfall. The proposed memorandum account provides a financial safety valve and allows the true costs of the dimmable rate program to be monitored with the reasonableness of program costs in excess of $2.3 million and any revenue under or over-recovery from the new rate design addressed in future rate proceedings. Adopting a memorandum account ensures that the costs to implement the program that exceed the authorized start-up costs are reviewed for reasonableness and there is no revenue under or over-collection as a result of adopting wattage-based rate design for dimmable streetlights.
The Medium/Large C&I class as a whole will see a decrease of its share of allocated revenue of between 1.3 and 1.0 percent annually over three years, as compared to the system average change. Many schools do not receive information about their electric costs and thus have little incentive or information to effectively manage their energy usage because electric bills are received and paid in central business offices. The majority of the 40 individual school districts analyzed by SDG&E showed annual bill benefits from SDG&E’s TOU proposal. The school districts that are negatively impacted by the changing TOU on-peak period are schools that installed solar, who will receive less revenue crediting for their solar generation as a result of the modified TOU period. In recognition that customers, including schools, have made investments in solar facilities in reliance on expected revenue streams based on today’s TOU periods, we adopted grandfathering provisions in D.17-01-006. Both PG&E and SCE implemented specialized rates to promote commercial fleet electrification, but SDG&E has not. Exhibit JT-2 balances the opening positions of SDG&E and Farm Bureau, enables agricultural customers to adjust to changing electric rate structures, and is consistent with the joint testimony offered for residential and small commercial customers. No party opposed the agricultural customer optional rate. SDG&E utilitizes both a Consolidated Model (revenue allocation) and a Lighting Model (rate design) to develop streetlighting rates. No discrepancy exists in the authorized revenues and rates between the Revenue Allocation Settlement, the Consolidated Model, and the Lighting Model.