BILL ANALYSIS                                                                                                                                                                                                              1
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                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                               DEBRA BOWEN, CHAIRWOMAN
          

          SB 32X -  Alpert                                  Hearing Date:   
          May 8, 2001                S
          As Introduced:  February 5, 2001        FISCAL           B
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                                      DESCRIPTION
           
          Under  existing law  , energy rates for customers of San Diego Gas  
          and Electric (SDG&E) are capped at 6.5 cents per kilowatt hour.

           This bill  would require SDG&E to provide the "economic value" of  
          this rate cap to direct access customers (customers purchasing  
          energy from other providers).

           This bill  also contains a statement of intent that direct access  
          customers in SDG&E territory not be discriminated against.

                                      BACKGROUND
           
          Because SDG&E recovered its stranded costs earlier than  
          expected, the rate freeze established by AB 1890 (Brulte),  
          Chapter 856, Statutes of 1996, ended for its customers in July  
          1999.  As a result, SDG&E customers were directly exposed to  
          wholesale energy prices as they rose to unprecedented levels  
          last summer.

          In response, AB 265 (Davis), Chapter 328, Statutes of 2000,  
          established a 6.5 cent/kwh cap for the energy portion of SDG&E's  
          residential, street lighting and small commercial customers  
          (those with demand under 100 kilowatts).  The rate cap was  
          applied retroactively to June 1, 2000 and extends until December  
          31, 2002, although the California Public Utilities Commission  
          (CPUC) may extend it until December 2003.  The CPUC may also  
          adjust the capped rate if it finds an adjustment is in the  
          public interest.

          SDG&E's energy purchase costs in excess of the capped rate  










          accrue in a "balancing account" and are credited against other  
          SDG&E revenue sources, such as retained generation.  SDG&E is  
          authorized to collect from its customers reasonable costs which  
          are not offset by other revenues.

          Pursuant to AB 1X (Keeley), Chapter 4, Statutes of 2001, the  
          Department of Water Resources (DWR) is now purchasing energy on  
          behalf of SDG&E.  As a result, SDG&E is no longer contributing  
          unrecovered energy purchase costs to its balancing account.   
          These costs are being incurred by, and will be collected by, DWR

          SB 43X (Alpert), Chapter 5, Statutes of 2001, has since extended  
          the 6.5 cent rate cap to all other SDG&E customers, retroactive  
          to February 7, 2001.  For these customers, the rate cap extends  
          until the rate freeze established by AB 1890 ends for Pacific  
          Gas and Electric and Southern California Edison customers. 






































          Direct access customers, whether located in SDG&E territory or  
          areas served by other investor-owned utilities (IOUs), have not  
          been protected by the initial rate freeze or the subsequent rate  
          caps established for SDG&E customers.  The energy rate for these  
          customers is established through voluntary agreements with their  
          direct access providers.

          This bill would require SDG&E to provide the economic value of  
          the 6.5 cent cap to direct access customers through a credit on  
          their bills.  In the context of the bill, it appears that the  
          credit would apply to residential and small commercial customers  
          in SDG&E territory, although the language is not specifically  
          limited to these, and could be read to apply to any direct  
          access customer.

                                       COMMENTS
          
          1.Bill requires SDG&E to subsidize direct access providers.    
            According to the author, this bill is intended to provide the  
            benefit of the rate cap to direct access customers in San  
            Diego.  However, the benefits delivered to direct access  
            customers and their providers come at the expense of SDG&E,  
            effectively forcing SDG&E to indefinitely subsidize rates  
            charged by competing energy providers.

            For example, if a direct access provider sells energy at  
            contract rate of 8.5 cents/kwh, SDG&E would have to provide  
            the customer a 2 cent/kwh credit, while the provider collects  
            the full 8.5 cents.  Or, if the direct access rate is 25  
            cents/kwh, SDG&E would have to provide an 18.5 cent credit,  
            which is passed on to the provider.  While customers would be  
            indifferent (receiving a net rate of 6.5 cents no matter  
            what), direct access providers could reap unearned profits at  
            SDG&E's expense.

            A more evenhanded method to achieve the author's intent would  
            be to require each direct access provider to shoulder the  
            under-collection associated with serving its customers at a  
            6.5 cent rate.  However, since this would be a losing  
            proposition for direct access providers, and they have no  
            obligation to serve their customers, the likely result would  
            be the return of all direct access customers to SDG&E.

           2.San Diego's direct access customers are not uniquely  
            disadvantaged.   SDG&E customers were placed in a unique  









            situation last summer, which justified a unique response.   
            They were the only IOU customers forced to pay unregulated  
            market rates, with no regulated rate alternative.  However,  
            there is not a similar basis for distinguishing  direct access   
            customers in San Diego from the rest of the state.

            Like direct access customers in the rest of the state, San  
            Diego customers who have chosen to leave bundled service are  
            not protected by regulated energy rates.  For better or worse,  
            they have chosen a market-based option.  If they don't like  
            the rates charged by their provider, they are free to return  
            to bundled SDG&E service.

            If the Legislature chooses to provide a regulated rate to  
            direct access customers, fairness demands that such a rate be  
            applied statewide.  Again, as noted above, unless the direct  
            access providers are subsidized, the likely effect of this  
            would be to drive them out of business.




































           3.If direct access customers don't get the rate cap, they  
            shouldn't be charged as if they have.   Direct access customers  
            in SDG&E territory have raised a legitimate issue with respect  
            to their treatment under the rate cap established by AB 265.   
            Those customers who return to SDG&E service are concerned  
            that, when the time comes to pay off SDG&E's balancing  
            account, they will be charged as if they had been served by  
            SDG&E all along (i.e. since June 1).  Because direct access  
            customers have not received the benefit of the rate cap, they  
            should not be charged for SDG&E's cost of providing energy  
            under the rate cap.

            This issue was not specifically addressed in AB 265 or SB 43X,  
            and has not been addressed by the CPUC.   The author and the  
            committee may wish to consider  , instead of attempting to cap  
            rates for direct access customers, simply amending the bill to  
            clarify the extent of these customers' liability for SDG&E's  
            under-collection.  This could be accomplished by stating that  
            customers who have been served by a direct access energy  
            provider and return to SDG&E service during the term of the  
            rate cap are liable only for the energy provided by SDG&E  
            under the capped rate.

            Suggested amendment to Section 332.1 (c), replacing existing  
            provisions of the bill (Page 3, line 8 of the bill):

            "For any residential or small commercial customer who has  
            purchased energy from a provider other than the San Diego Gas  
            and Electric Company on or after June 1, 2000, any cost  
            recovery authorized pursuant to this section shall be adjusted  
            to ensure that the customer does not pay the San Diego Gas and  
            Electric Company for energy it has not purchased from the San  
            Diego Gas and Electric Company."

           4.Technical amendment.   SB 32X was drafted prior to enactment of  
            SB 43X.  Both amend Public Utilities Code Section 332.1.  As  
            such, SB 32X would chapter out SB 43X.  To avoid this, SB 32X  
            needs to be amended to reflect Section 332.1, as amended by SB  
            43X.

                                       POSITIONS
           
           Sponsor:
           
          Author










           Support:
           
          Green Mountain Energy Company
          1 individual

           Oppose:
           
          None on file



          Lawrence Lingbloom 
          SB 32X Analysis
          Hearing Date:  May 8, 2001