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July 11, 2016

The Honorable President Michael Picker
The Honorable Commissioner Mike Florio
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA   94102

RE:  Procedural Forum for Power Charge Indifference Adjustment Issues

Dear President Picker and Commissioner Florio:
The San Diego Energy District (SDED) wishes to join its voice with those of many other entities seeking a forum for adjudication of the reasonableness and fairness of the Power Charge Indifference Adjustment (PCIA).

SDED is a 501c3 non-profit founded in 2011 with the sole mission of encouraging formation of a community choice program in the San Diego region. SDED has followed developments regarding PCIA with increasing attention over the last year because of the serious impact that PCIA tariffs have on the customers of operating and forming community choice programs.

As such, SDED was troubled by last November's proposed decision in A.15-06-001 in PG&E's ERRA application, and filed comments in opposition. We were heartened by the Commission's March workshop to explore the issues of concern. Regrettably, despite what we understood to be a constructive exchange of perspectives and potential solutions in that Workshop, we join many in expressing disappointment at the absence of any process, venue or proceeding to continue that discussion.

The San Diego region completed its first study of Community Choice in 2004. At that time, and again in 2014-15, the composition, calculation methodologies, transparency and uncertainty surrounding the PCIA have been pivotal. On behalf of the region's many potential CCA jurisdictions and constituents, SDED urges the Commission to address these issues in an open, fact-based and transparent process.

The California Public Utilities Code Section 451.21 requires the Commission to ensure that the PCIA is just and reasonable. Given the rapid expansion of Community Choice statewide, we submit that further delay in formal consideration of this matter is inappropriate and unfair. We respectfully request that the Commission open a rulemaking on this matter at the earliest possible opportunity. 
Sincerely,

Lane Sharman, Co-Founder, Board Chair
Michael Hetz, Vice Chair
Erika Morgan, Secretary, Executive Director
Van Collinsworth, Director
Jamie Edmonds, Director
Jose Torre-Bueno, Director
Susan Davison, Advisor
David Sean Dufek, Advisor
Jay Klopfenstein, Advisor
Tobias Schultz, Advisor
Stuart Smits, Advisor
Charlie Wilson, Advisor
Kurt Yeager, Advisor


Copyright 2011-2021
San Diego Energy District is a 501(c)3.
Address:
249 South Hwy 101, #564
Solana Beach, CA 92075
1-858-342-1415
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