2. Statutory Verified, although Obligations/Commission citation to page CFC’s Questions 209 of D.14-06-029 is incorrect. CFC commented on the • functionality of time-varying and D.14-06-029 at page 209. dynamic pricing, flat fees, fixed charges, tiers, and default TOU Reply Brief of CFC to the arguing TOU rates should not be Amended Scoping Memo and mandatory during the initial phases Ruling of Assigned of the transition. Commissioner, filed 04.15.2014. Pages 2, 5-6. CFC argued against the application • of a fixed fee, contending that it The Consumer Federation of would negatively impact Opening California’s conservation measures at best and Comments on Rate Design serve as a cross-subsidy at worse. Proposals Submitted Pursuant CFC expressed concern regarding to Rulemaking 12-06-013, impacts on lower tier customers and pages 15-16. the potential for rate shock associated with a quick adoption of a Comments of Consumer two-tiered rate structure. Federation of California on the May 22, 2015 Alternate The Commission agreed that Proposed Decision. Page 2. should be avoided. D.15-07-001 at page 72, 86. It was that • CFC’s position Inclining Block Rate (IBR) design should be preserved but modified; IBR design should have three tiers and reflect geographic / climate zone Reply Brief of CFC to the differences. The differentials Amended Scoping Memo and between the tiers should be uniform Ruling of Assigned and substantial; baseline allowances Commissioner, filed must not unfairly impact energy 04.15.2014. Pages 3-4. consumers in individual tiers. The Consumer Federation of The Commission ultimately found Opening California’s that tiered rates could Comments on Rate Design disproportionately affect certain Proposals Submitted Pursuant customer groups, including the to Rulemaking 12-06-013, residential groups CFC argued pages 9-13. would be negatively impacted. D. 15-07-001 at pages 103-104, 313.
2. Statutory Obligations/Commission Questions • CFC commented on the functionality of time-varying and dynamic pricing, flat fees, fixed charges, tiers, and default TOU arguing TOU rates should not be mandatory during the initial phases of the transition. • CFC argued against the application of a fixed fee, contending that it would negatively impact conservation measures at best and serve as a cross-subsidy at worse. CFC expressed concern regarding impacts on lower tier customers and the potential for rate shock associated with a quick adoption of a two-tiered rate structure. The Commission agreed that should be avoided. • It was CFC’s position that Inclining Block Rate (IBR) design should be preserved but modified; IBR design should have three tiers and reflect geographic / climate zone differences. The differentials between the tiers should be uniform and substantial; baseline allowances must not unfairly impact energy consumers in individual tiers. The Commission ultimately found that tiered rates could disproportionately affect certain customer groups, including the residential groups CFC argued would be negatively impacted. D.14-06-029 at page 209. Reply Brief of CFC to the Amended Scoping Memo and Ruling of Assigned Commissioner, filed 04.15.2014. Pages 2, 5-6. The Consumer Federation of California’s Opening Comments on Rate Design Proposals Submitted Pursuant to Rulemaking 12-06-013, pages 15-16. Comments of Consumer Federation of California on the May 22, 2015 Alternate Proposed Decision. Page 2. D.15-07-001 at page 72, 86. Reply Brief of CFC to the Amended Scoping Memo and Ruling of Assigned Commissioner, filed 04.15.2014. Pages 3-4. The Consumer Federation of California’s Opening Comments on Rate Design Proposals Submitted Pursuant to Rulemaking 12-06-013, pages 9-13. D. 15-07-001 at pages 103-104, 313. Verified, although CFC’s citation to page 209 of D.14-06-029 is incorrect.
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