bundled customers only, and neither involves generation that PG&E was required to purchase before Joint CCA customers’ departure. As further support, the Joint CCAs point out that CCA customers already pay for PG&E generation through purchases from the CAISO to meet CCA load demands. In calculating the PCIA, PG&E excludes the sales revenues from these generation resources, and credits those sales on behalf of bundled, not departed customers. The Joint CCAs characterizes this practice as requiring CCA customers to pay for the same energy twice, first in purchases from the CAISO and then again through the PCIA. In its rebuttal testimony and briefs, PG&E states that fuel and variable costs for dispatchable generation are not load-driven costs. The Joint CCAs’ argument is premised on the assumption that PG&E bids resources into the CAISO market to meet demands of its bundled load only. However, these resources are dispatched by CAISO and PG&E has no discretion in whether to schedule and bid the resources into the market in compliance with the Commissions Standard of Conduct 4 for least cost dispatch. The dispatchable resources were procured to serve PG&E’s load as forecasted at the time of procurement, and PG&E is required to bid those resources into the market even though loads have departed. The CAISO revenues received from spot sales are reflected in the increased market value of the generation portfolio and, therefore are “netted” out of the PCIA calculation. The reason that CAISO revenues are netted against the costs to serve bundled customers only, and not also credited to departed customers, is because departed customers have already received the benefit of the CAISO market revenues through the application of the Market Price Benchmark (MPB). We find that PG&E’s calculation is in compliance with the Commission decisions; PG&E has appropriately included within its PCIA
bundled customers only, and neither involves generation that PG&E was required to purchase before Joint CCA customers’ departure. As further support, the Joint CCAs point out that CCA customers already pay for PG&E generation through purchases from the CAISO to meet CCA load demands. In calculating the PCIA, PG&E excludes the sales revenues from these generation resources, and credits those sales on behalf of bundled, not departed customers. The Joint CCAs characterizes this practice as requiring CCA customers to pay for the same energy twice, first in purchases from the CAISO and then again through the PCIA. In its rebuttal testimony and briefs, PG&E states that fuel and variable costs for dispatchable generation are not load-driven costs. The Joint CCAs’ argument is premised on the assumption that PG&E bids resources into the CAISO market to meet demands of its bundled load only. However, these resources are dispatched by CAISO and PG&E has no discretion in whether to schedule and bid the resources into the market in compliance with the Commissions Standard of Conduct 4 for least cost dispatch. The dispatchable resources were procured to serve PG&E’s load as forecasted at the time of procurement, and PG&E is required to bid those resources into the market even though loads have departed. The CAISO revenues received from spot sales are reflected in the increased market value of the generation portfolio and, therefore are “netted” out of the PCIA calculation. The reason that CAISO revenues are netted against the costs to serve bundled customers only, and not also credited to departed customers, is because departed customers have already received the benefit of the CAISO market revenues through the application of the Market Price Benchmark (MPB). We find that PG&E’s calculation is in compliance with the Commission decisions; PG&E has appropriately included within its PCIA
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