Parties Submitted Comments on Market Price Benchmark Issue Date

Staff Proposal Background

Staff proposed shifting back the spread of transactions included in each MBP calculation – both forecasts and finals – by one month. This means that for the energy index, Energy Division would request energy forward data that Platts develops in September, rather than in October. For RPS and RA forecast and final adders, Energy Division would add one month of data to the beginning of each calculation dataset and remove one month of data from the end of each calculation dataset. The analysis suggests that the calculation changes in the Staff proposal likely will have a minor impact on forecasted MPB values and PCIA values. Removing one month of data off the end of the RPS and RA adder datasets (without adding a new month at the beginning, as anticipated in the Staff proposal), would have directionally similar effects for both forecast and final adders. The analysis concludes that the effect on final adders in general is minimal, whereas it can be larger for forecast adders, particularly forecast RA adders.

CalCCA Comments

• While the impacts of Staff’s policy are likely to be small, the only analysis that can bring certainty to the question of the extent of those impacts is a post hoc analysis. Therefore, CalCCA recommends the Commission include a review of the policy’s impacts at least two years after it has been enacted in any decision adopting the proposal to determine whether the policy should be revisited.
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• The Staff Proposal can address the underlying problems with the ERRA forecast timelines, while improving CCA parties’ ability to effectively participate within the proceedings, if the Commission:
  
     1. Maintains the current, typical procedural framework for the ERRA forecast proceedings that occur prior to each year’s update; and 
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      2. Requires 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 early May.

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SDG&E Comments

• SDG&E requests that consideration of the Staff Proposal be deferred to allow time for further analysis and that it be considered for ERRA Forecast year 2023, at the earliest.
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• By the end of 2022, SDG&E expects that 60 percent of its bundled service customers will have departed utility service to be served by non-IOU LSEs. Changing the MPB calculation methodology at this time could result in increased rate volatility for both bundled service and departed load customers.
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• If the ERRA forecast filing date is advanced to a date earlier than June, combining the Sales Forecast and ERRA Forecast applications will not be possible.

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