SDCP, CEA, and SDG&E submitted comments on the scope of issues that should be included in SDG&E's 2022 ERRA forecast proceeding. Parties primarily disagree over whether's SDG&E's 2022 sales forecast update should be included in this proceeding. SDG&E maintains the position that it is precluded from incorporating an updated sales forecast in its ERRA forecast application until that forecast is approved in a standalone application that has yet to be filed. SDG&E also states that it would need at least four weeks from the date of the scoping memo if the Commission decides to incorporate the sales forecast update in this proceeding. SDCP and CEA note that SDG&E's arguments in favor of incorporating an outdated sales forecast mirror those rejected by the Commission in last year's ERRA forecast.
SDG&E makes essentially the same argument rejected by the Commission in the 2021 ERRA forecast proceeding, that it is required to use an outdated sales forecast from a different proceeding. As support, SDG&E cites to a settlement agreement in its GRC Phase 2 proceeding (“Settlement Agreement”). SDG&E fails to acknowledge, however, that the Settling Parties, including SDG&E, later filed a motion to admit an addendum to the Settlement Agreement (“Addendum”), which modified the relevant provision of the Settlement Agreement to require SDG&E to include its 2022 sales forecast in its 2022 ERRA forecast application.
As SDG&E indicated, the reason it did not include the 2022 sales forecast as part of this year’s ERRA Forecast Application is due to the fact that a Commission decision is still pending on an October 8, 2020 motion to adopt a Settlement Agreement in SDG&E’s 2019 GRC II, which, if adopted, would obligate SDG&E to file a standalone application to update its electric sales forecast for 2022, with a request for implementation to be made effective January 1, 2022.
That said, assuming a ruling in this proceeding includes the 2022 sales forecast within its scope, SDG&E would be able to do so, provided that SDG&E is allowed sufficient time – at least four weeks from the issuance of the Scoping Memo – to prepare a supplemental or amended filing to provide the necessary sales forecast information.
