Retail Suppliers Seek Further Unbundling at PG&E

Retail suppliers and other competitive supply parties have asked the California PUC to consider the further unbundling of distribution rates at Pacific Gas & Electric.

The request was made in comments concerning PG&E' request to implement new direct access service fees (see 1/3), filed by the Alliance for Retail Energy Markets, City and County of San Francisco, Direct Access Customer Coalition, Gas and Power Technologies, Marin Energy Authority, Retail Energy Supply Association, and the School Project for Utility Rate Reduction.

The direct access service fees cover various services provided by PG&E including metering and billing service.

The competitive supply parties said that fees for services provided to energy service providers and community choice aggregators should be similar, if not identical, to the costs charged to bundled PG&E customers for the same types of services. The competitive supply parties cited Public Utilities Code Section 453(a), which provides: "No public utility shall, as to rates, charges, service, facilities or in any other respect, make or grant any preference or advantage to any corporation or person or subject any corporation or person to any prejudice or disadvantage."

The competitive supply parties further cited Section 453(c) which provides: "No public utility shall establish or maintain any unreasonable difference as to rates, charges, service, facilities, or in any other respect, either as between localities or as between classes of service."

To ensure that the fees charged to energy service providers and community choice aggregators are not unfair, the competitive supply parties said that the PUC must perform an, "analysis of how similar services are charged to bundled customers to ascertain whether DA or CCA customers are potentially being double charged."

"For example ... PG&E proposes to charge [in the direct access fees] Meter Service Composite Fees, with a proposed cost of $460.37 per interval meter service request; Meter Data Management Fees, with a proposed cost of $8.27 per interval meter; and Billing Services, with a proposed cost of $1.50 per Service Account per billing cycle. What is not clear (and will require the use of discovery and/or cross-examination to determine) is how the same sort of costs are charged to and recovered from bundled service customers," the competitive supply parties said.

If the metering and billing costs provided to bundled service customers are being recovered in distribution rates, "then DA and CCA customers are being charged twice since these customers also pay PG&E's distribution rates."

"One possible method ... would be to allocate to PG&E's bundled procurement rate whatever CCAs and ESPs are charged for PG&E services. For example, if PG&E charges $0.44 per account per month to invoice a CCA or ESP customer, then $0.44 per account per month should be removed from distribution charges and put into commodity charges for the 'service' of billing commodity to bundled customers. The total bill to bundled customers would not rise, as the cost would simply be re-allocated from one charge that they pay to another," the competitive supply parties said.

The competitive supply parties noted that their requested relief would be similar to the Merchant Function Charge in place in New York.

Aside from the issue of unbundling, the competitive supply parties protested PG&E's proposal to combine numerous current direct access service fees into three categories, with a single price for each category. The competitive supply parties compared this to a "prix fixe" menu, and said that it will require energy service providers to pay for services they may not need because several services have been grouped together under one charge.