The Joint IOUs generally support the findings set forth in the Draft Resolution (“DR”), but note that it does not address the Joint IOUs’ requests to establish accounts necessary to implement the regulatory accounting process. The accounts would function to record all prepayments of PCIA obligations received pursuant to agreements reached between the utility and a prepayer.
In D. 18-10-019, the Commission authorized a prepayment option to allow Direct Access (DA) customers and Community Choice Aggregators (CCAs) to prepay their PCIA obligation or that of their customers.
In D. 20-08-004, the Commission adopted a consensus prepayment framework proposed by the Working Group 2 co-chairs and other details of the prepayment option, including a regulatory accounting process involving retention of any prepayment amount in an interest-bearing balancing account and calculation of a monthly “shadow bill” with transfer of the shadow bill amount to the Portfolio Allocation Balancing Account (PABA) on a monthly basis.
In accordance with that Decision, each IOU submitted an individual Advice Letter setting forth their respective proposals for protocols to administer prepayment requests and negotiations.
DR E-5134 would approve the IOUs’ with the following modifications:
The IOUs’ Joint Comments indicate support for the DR, but request that the Commission add an additional Ordering Paragraph to address the IOUs’ requests to establish regulatory accounts to track prepayments. Specifically, the IOUs request the following language be added:
6. The utilities are each authorized to establish a PCIA Prepayment Balancing Account (PPBA) as proposed in PG&E AL 5973-E, SCE AL 4309-E, and SDG&E AL 3631-E.
