IOU and CCA Responses to PD on ERRA Timing Issues

IOU Response

• The Joint Utilities recommend that the PD’s recommendation to change the current ERRA November Update to an October Update be rejected. In the alternative, if an October Update is adopted, the final decision should include explicit language indicating that if Energy Division’s forthcoming analysis shows a material negative impact on PCIA forecasting accuracy due to the acceleration of the Joint Utilities’ Update testimony, then the traditional November Update that has been in place for many years shall be reinstated.
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• The Joint Utilities recommend that the PD’s proposed acceleration of the annual ERRA Forecast application filings to May 15th be deferred until 2023 (for the 2024 ERRA Forecast proceedings), given SCE’s and PG&E’s new role starting in 2022 as Central Procurement Entities. SDG&E recommends that for the 2023 ERRA forecast proceeding, it be allowed to file its application on June 1st consistent with SCE’s and PG&E’s current filing date.
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• Given the late-stage procedural posture of PG&E and SCE’s 2022 ERRA Forecast proceedings and the fact that SDG&E’s 2022 ERRA Forecast proceeding is already closed, the Joint Utilities propose that the PD’s sensible meet-and-confer requirement on data confidentiality issues be deferred until the IOUs’ 2023 ERRA Forecast proceedings.
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• The Joint Utilities urge the Commission to schedule a workshop on the important issue of fixing the currently-broken “brown” energy Market Price Benchmark used to set forecast PCIA rates as early as possible in 2022 so that it can be resolved in time for the Joint Utilities’ 2023 ERRA Forecast filings.

CalCCA Response

CalCCA fully supports the PD, but requests that the IOUs be required to provide their updated prepared testimony no later than 14 days following the issuance of the market price benchmarks on October 1st.

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