D.97-08-056

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IX. Master Meter Issues

A. Minimum Average Rate Limiter (MARL)

WMA proposes to reduce the MAR (or MARL for PG&E) for master-metered customers who elect direct access. The MAR applies to master-metered customers only and establishes a minimum level for recovery of energy costs and the Commission fee. WMA proposes that the utilities reduce the MAR to reflect the utilities’ cost of purchased power. WMA observes that the utilities will still be able to recover purchased power costs authorized in the CTC.

Edison and PG&E oppose WMA’s proposal. PG&E responds that AB 1890 mandated a rate freeze at levels in effect on June 10, 1996 which would be violated under WMA’s proposal. PG&E explains that it would treat master-metered customers electing direct access just as it would treat all other customers, that is, master-metered customers would only pay that portion of the MARL attributable to costs not related to PX energy. Edison makes similar comments, adding that WMA’s proposal could result in the utility selling its master-metered customers its services at a negative rate.

We do not adopt WMA’s proposal because it would effectuated a change in rates which is contrary to AB 1890. As they propose, the utilities will reflect the PX energy cost by way of a credit to the customer who chooses direct access.

B. Funding Costs to Implement Direct Access for Tenants

WMA proposes that master-metered customers be offered an additional discount on submetering to fund additional capital and operating expenditures park owners require to implement direct access for their tenants. Specifically, WMA says direct access will create new costs for park owners because of the need for them to educate and train customer and park employees, to change tenants’ bills, to accommodate competitors making sales presentations to park residents, and to provide for direct access metering.

PG&E and Edison oppose WMA’s proposal on the basis that it would violate the rate freeze required by AB 1890 by providing a discount to submetered customers beyond that allowed by AB 1890.

We concur with the utilities’ position that WMA’s proposal represents a rate change which is contrary to AB 1890. We understand that some customers may incur transactions costs as a result of electric restructuring. WMA’s proposal requires that either the utilities or other customers should bear those costs in higher electric bills, an outcome which we cannot adopt. If WMA believes park owners should receive higher submetering discounts because the cost of service to them will be lower or because the utilities’ avoided costs will be higher under direct access, it may propose discount changes in forums where we consider utility revenue requirements.

C. Tariff Modifications for Master-Metered Customers

WMA proposes that utility tariffs specify that tenants’ bills will not be unbundled by the park owners. Edison opposes the suggestion, observing that tenants of master-metered park owners are not Edison customers and therefore utility tariffs should not specify the relationships between park owners and tenants.

We reject WMA’s proposal because, as Edison points out, it assumes a relationship between the utility and the park tenants that does not exist. Park owners are responsible for the bills they render to their tenants, consistent with existing law.

Footnotes are bracketed and in blue

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