Section 745(c)(4) requires that a customer be “provided with not less than one year of interval usage data from an advanced meter and associated customer education.” SCE can identify customers without 12 month of interval usage data in its CSS and will ensure that none of these customers will be selected for the default pilot. SCE will provide all customers in the default pilot with a rate comparison in their pre-default notification, thus fulfilling the second part of the requirement. Community Choice Aggregator SCE currently has one Community Choice Aggregator (CCA) operating within its service territory – the City of Lancaster (City). CCA customers are not subject to default TOU, and can only be defaulted onto TOU rates if their CCA provider elects to do so. The City has indicated that it will not participate in the default pilot, but is still considering whether or not it intends to participate in the full default rollout. Thus, SCE will exclude the City’s customers from the default pilot. Should any other CCAs form ahead of the default pilot, those CCA customers will be also be excluded from the default pilot. Other Exclusions Finally, SCE proposes to exclude certain other categories of customers, including customers already on a TOU rate, customers accepted into the opt-in TOU pilots, smart-meter opt-out customers, customers without a TOU meter, master-metered customers and direct access customers. Default TOU is aimed at customers not already on a TOU rate, so it is reasonable to exclude those customers. The Working Group agreed that customers accepted into the opt-in TOU pilots should not be made to participate in another pilot. We agree, and additionally note that these customers are no longer representative of the typical default customer. Smart-meter opt-out customers and customers without a TOU meter would be excluded anyway under Section 745(c)(4), due to insufficient interval usage data. Master-metered customers will not see or experience the TOU price signals and direct access customers do not receive their generation service from SCE. Thus, these exclusions are also reasonable. Section 745(d) Section 745(d)(1) and 745(d)(2) require that the Commission consider whether or not default TOU rates will cause hardship to “customers located in hot, inland
TOU. Per ALJ Ruling, bill protection shall be provided to any customer who opts-in to Default Rate 1 or 2, on or before the last day of the default pilot period. This expansion of the bill protection provision guards against the anomalous result in which vulnerable customers ineligible for default TOU, who nonetheless elect to participate in TOU, would be ineligible for a consumer protection afforded non-excluded customers. This expansion applies to all customers who opt-in to Default Rate 1 or 2, regardless of whether or not the tiered rate was their previous rate schedule. Bill protection will be calculated for these customers in the same manner as for customers who move from the tiered rate to Default Rate 1 or 2, meaning that, even if customers opt-in to Default Rate 1 or Default Rate 2 from a different TOU rate, SCE will compare the amount the customers paid on Default Rate 1 or 2 rate against the amount they would have paid on the tiered rate, not their former TOU rate. Bill Protection Revenue Shortfall SCE estimates a revenue shortfall of $10.5 million related to providing bill protection. These shortfalls will occur across generation and distribution revenues and will be recorded in SCE’s Base Revenue Requirement Balancing Account, which includes both generation and distribution sub-accounts. Generation revenue shortfalls will be recovered across all of SCE’s residential generation customers and distribution revenue shortfalls will be recovered across all of SCE’s residential distribution customers. In its protest, ORA requests more information on the projected revenue shortfalls associated with bill protection payments and load shifting, and the estimated cost savings resulting from load shifting. It its reply to ORA’s protest, SCE states that it provided estimates of revenue deficiency due to bill protection to the Working Group, of which ORA is a member. SCE also states that any revenue deficiency related to load shifting would be small. We find that SCE has provided sufficient documentation to support its projected revenue shortfall of $10.5 million. We also find that estimates of revenue shortfalls and/or cost savings due to load shifting can be better assessed after the results from the opt-in TOU pilots are in. Marketing, Education and Outreach