Call to ACTION:  Exit Fees

CPUC proposed decision hikes Exit Fees 95% on CCA customers

Action Deadline:  December 17
November 13, CPUC issued a proposed decision that affects all PGE CCA and direct access customers. The proposed order hikes PCIA an average 95% in 2016.  These fees take nearly $70M from Marin Clean Energy (MCE)'s 175,000 customers.

Implications The Proposed Decision doesn't look good for CCAs.  It:

• Approves PGE's 2016 PCIA rate hike, independent of impact on CCA customers;
• Accepts PCIA methodology prior to a 2016 workshop to examine that methodology;
• Rejects rate stabilization proposals by MCE and LEAN, that would impose less harm on CCA customers;
• Rejects MCE's proposal to mitigate the PCIA increases with rate savings accrued to other customers exercising electricity choice (the Direct Access customers);
• Results in pricing that is anti-competitive in effect, and already stifling CCA developments in many municipalities. 

This PCIA Proposed Decision confirms again the outdated "regulated utility" model.  In what other business can management use outdated forecasts and still get a guaranteed rate of return?  Where else insulated from the risks other businesses carry and use their own judgement to survive.  And where customers lose, not shareholders, if they're wrong. 

What can you do.  Write Letters.  By December 17.  Please use the sample letters, and tailor as needed. 

Background  The Power Charge Indifference Adjustment (PCIA) is an exit fee.  Added to the CCA's market price of power, it is intended to offset the “above market” portion of contracts IOUs hold when customers choose the CCA. This is akin to a Trader Joe's shopper changing to Ralphs, then getting billed by TJ for the “above market” cost of groceries they procured and stocked for you.  Groceries you'll no longer buy. That Trader Joe will sell to someone else.  For most industries, grappling with the uncertainties of  "how many customers will we have next year" is a normal aspect of business. Its a risk borne by shareholders, not customers.  

PCIA: the Pivot of CCA Feasibility.  Depending on the PCIA, customers can save a little, a lot or not at all.  PCIA cannot be applied in a manner that hurts CCA customers; indeed, it may be argued that the anti-competitive result of PGE's charges violates SB790.  

In 2012, CPUC agreed that PGE had miscalculated PCIA, and required PGE to reimburse MCE customers for up to 94% of the PCIA those customers had paid.  In July 2015, MCE filed again to take issue with PGE's 2016 PCIA charges, with support from Sonoma Clean Power, LEAN Energy US and others.  SDED has opined on this matter to the City of San Diego's Sustainable Energy Advisory Board.  We will also file again before the December deadline. 

Reference Documents

• MCE Press Release on proposed PCIA
• MCE Description of PCIA
• CPUC history in Docket 15-06-001
  
• 15-06-001 Proposed Decision on PCIA

Action Documents

• LEAN's model letter - Municipality
• LEAN's model letter - Organization
• Feel free to originate your own letter, following the sample format.

Send your comments By December 17!
By email, to all 5 Commissioners:

• Commission President Michael Picker
• Commissioner Mike Florio
• Commissioner Catherine Sandoval
• Commissioner Carla Peterman
• Commissioner Liane Randolph

By mail to:
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102