AECA’s participation resulted D.16-03-030, pp.36-38, and Agricultural in parties agreeing to additional and Pumping Rate Group Rate Design analyses to examine an Settlement Agreement pp. A-16 A-17. – Agricultural Class Balancing Account. (See 1.b above, raised by AECA testimony.) D.16-03-030, p.38, and Agricultural and Pumping Rate Group Rate Design Settlement Agreement p.A-18. Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s CPUC Assertion Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to Yes Yes the proceeding? b. Were other parties to the proceeding with positions Yes Yes similar to yours? c. If so, provide name of parties: California Farm Bureau Federation Yes (CFBF) AECA and CFBF have historically Yes d. Intervenor’s claim of non-duplication: submitted separate testimony in CPUC proceedings, raising distinct, issues, including recommended rate changes. During settlement negotiations the two agricultural groups coordinated our efforts. While both parties seek reasonable rates for agricultural customers, AECA has also specifically advocated for rate stability and demand management incentives, and effectively identified flaws in SCE’s development of marginal costs to calculate rates for the agricultural class. AECA has consistently documented allocation inconsistencies and volatility in SCE’s application of EPMC principals to the agricultural class. Here, AECA’s efforts resulted in rate decreases, rather than the increases proposed by SCE. In this proceeding, AECA also pursued the creation of demand-side management incentives, such as appropriate energy rate differentials, discussion hydrologic balancing accounts, including fluid milk production in the definition of agricultural power service and continuation of the PA-ICE program. AECA’s efforts to avoid duplication with other parties and dedicated pursuit of important issues should be recognized by the Commission.
AECA’s participation resulted in parties agreeing to additional analyses to examine an Agricultural Class Balancing Account. (See 1.b above, raised by AECA testimony.) D.16-03-030, pp.36-38, and Agricultural and Pumping Rate Group Rate Design Settlement Agreement pp. A-16 – A-17. D.16-03-030, p.38, and Agricultural and Pumping Rate Group Rate Design Settlement Agreement p.A-18. Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to the proceeding? Yes Yes b. Were other parties to the proceeding with positions similar to yours? Yes Yes c. If so, provide name of parties: California Farm Bureau Federation (CFBF) Yes d. Intervenor’s claim of non-duplication: AECA and CFBF have historically submitted separate testimony in CPUC proceedings, raising distinct, issues, including recommended rate changes. During settlement negotiations the two agricultural groups coordinated our efforts. While both parties seek reasonable rates for agricultural customers, AECA has also specifically advocated for rate stability and demand management incentives, and effectively identified flaws in SCE’s development of marginal costs to calculate rates for the agricultural class. AECA has consistently documented allocation inconsistencies and volatility in SCE’s application of EPMC principals to the agricultural class. Here, AECA’s efforts resulted in rate decreases, rather than the increases proposed by SCE. In this proceeding, AECA also pursued the creation of demand-side management incentives, such as appropriate energy rate differentials, discussion hydrologic balancing accounts, including fluid milk production in the definition of agricultural power service and continuation of the PA-ICE program. AECA’s efforts to avoid duplication with other parties and dedicated pursuit of important issues should be recognized by the Commission. Yes
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