SDCP and CEA moved to compel SDG&E to produce documents fully responsive to its data request concerning the derviation of current PCIA rates, which SDG&E relied on to develop its 2021 PABA year-end balance. SDG&E's Response opposes the motion on the grounds that the requested workpapers have already been approced by the Commission and implemented into rates and, thus, are not relevant to the current proceeding.
SDCP and CCA submitted a Data Request that seeks the derivation of current vintage Power Charge Indifference Adjustment (“PCIA”) rates, which SDG&E relied on to develop its 2021 PABA year end balance.
In its Response, SDG&E argues that the CCAs' Motion should be denied because the requested workpapers support PCIA rates that have already been approved and implemented into rates. As such, SDG&E argues that the workpapers are irrelevant to the proceeding and outside scope of discovery.
SDG&E's argument against the Motion to Compel Discovery is broken down into the following arguments:
These workpapers have absolutely nothing to do with the forecast or rates SDG&E proposed in this year’s ERRA Forecast Proceeding, which seeks to set the revenue requirements and rates for 2022. Rather, the workpapers at issue deal with PCIA rates that were approved in three different Commission proceedings that are closed (i.e., D.21-01-017 issued in A.20-04-014 (SDG&E’s 2021 ERRA Forecast Proceeding), D.20-12-028 issued in A.20-07-009 (SDG&E’s 2020 CAPBA Trigger Proceeding) and D.21-02-014 issued in A.20-12-007 (SDG&E’s 2020 ERRA Trigger Proceeding) and implemented via Advice Letter (“AL”) 3669-E-A3 and AL 3696-E-A-B.4,5 Since these rates have already been approved and implemented, they are not relevant to any issue the Commission will be deciding in this instant proceeding.
