Parties Filed Comments on Energy Division's Market Price Benchmark Proposal
CalCCA and the three IOUs submitted comments addressing the Energy Divison Staff Proposal to change the MPB issuance date from November 1 to October 1 of every year. Parties generally recommend waiting until the 2023 ERRA forecast cycle to implement any changes. Parties also generally agree that moving the MPB date alone, without making additional changes, would provide little benefit.
Implement the Staff Proposal next year (i.e., during the IOUs’ 2023 ERRA forecast cases);
Maintain the current, typical procedural schedules for the ERRA forecast proceedings that occur prior to each year’s update;
Require SCE and PG&E to file their ERRA forecast applications on May 1 each year instead of June 1, or, at the very least, on a filing date in the first half of May;
Target Q1 2022 implementation for this year’s ERRA forecast proceedings, similar to SCE’s request in its 2022 ERRA forecast application;
Adopt a Master Data Request ("MDR") approach for the SCE and SDG&E ERRA forecast proceedings.
CalCCA's Comments included the proposed schedule above. Major milestones are highlighted in blue.
Energy Division staff should conduct additional analysis regarding the impact of the proposed revision; if the analysis demonstrates that the proposed change is in the public interest, the Staff Proposal could be considered for the 2023 ERRA forecast year.
SDG&E's 2022 ERRA forecast is already underway; it is not clear how adoption would impact work and resources already dedicated to the current timeline.
The Joint Utilities do not believe the singular revision to the November Update should be adopted, if at all, prior to the 2023 ERRA Forecast cycle.
October Update is unlikely to provide parties any additional relief. For example, in PG&E’s typical ERRA Forecast schedule, the month of October is typically as compressed as the month of November.
Commission should revise additional components of the ERRA schedule including November Update meet-and-confer process concerning CCA load forecasts.
More analysis is needed to consider the potential impact an October Update would have on forecast balancing accounts and the likelihood IOUs would trigger rate adjustments in the current year.
