This entry covers CPUC proceeding A.24-06-014 / A.24-12-008, in which Southern California Edison seeks approval of the Large Power Dynamic Rate (LPDR) for high-voltage industrial customers. The excerpts below are drawn from CLECA’s opening and reply briefs.
Authorize the LPDR now on a separate track from the SDR
CLECA argues the LPDR can be deployed quickly without waiting on the billing-system rebuild the Standard Dynamic Rate requires.
Second, LPDR customers will be manually billed. SDR customers require extensive billing system upgrades, placing the two rates on separate implementation tracks.
Third, the SDR will not be available until at least Q1 of 2030. By contrast, the LPDR does not fully depend on the billing system upgrade, which is the principal driver of the implementation date.
The LPDR is distinct, not a duplicate of the SDR
In reply, CLECA rejects Cal Advocates’ contention that the LPDR merely duplicates the Standard Dynamic Rate.
The LPDR is not simply a large-customer version of the SDR. As discussed above, the LPDR differs from the SDR in its subscription-setting methodology, customer-selected pricing options, and long-term contract structure.
These features are not incidental. They are material design elements that facilitate large customer enrollment and load responsiveness and explain why a separate, tailored rate is warranted.
Preserving bilaterally negotiated subscriptions
CLECA defends the LPDR’s customer-specific subscription as a legitimate operational tool rather than a gaming device.
As discussed above, the LPDR subscription is an operational tool that allows each large customer to calibrate its exposure to volatile dynamic prices based on risk tolerance and load flexibility. Subscription-related challenges, therefore, do not apply to the LPDR, as LPDR subscriptions are bilaterally negotiated and manually billed.
Further, the subscription is not unilaterally selected by the customer; instead, it is bilaterally negotiated between SCE and the customer.
No cost shifting to non-participants
CLECA maintains that the LPDR preserves class-level revenue neutrality and leaves non-bypassable charges unchanged.
Second, the LPDR also preserves revenue neutrality at the class level by exposing participating customers to hourly prices and maintaining the same aggregate revenue requirement.
As a result, a customer receiving service on the LPDR remains responsible for the same underlying cost obligations as a customer receiving service under a standard tariff.
Dual participation with the Base Interruptible Program
CLECA argues that the LPDR and BIP serve different grid needs and should be treated as complementary.
The Commission should approve SCE’s proposal and allow customers participating in the Base Interruptible Program (BIP) to also participate in the LPDR. BIP is an emergency demand response program and therefore addresses fundamentally different grid needs from dynamic pricing.
Authorizing dual participation between LPDR and BIP does not create a risk of double-counting or double-compensation, as the existing tariff provisions ensure that compensation under the two programs is appropriately differentiated and non-overlapping.
Availability for unbundled as well as bundled customers
CLECA recommends extending the LPDR to unbundled customers who procure generation from an ESP or CCA.
The Commission should authorize the LPDR for unbundled customers, where SCE’s hourly rate would reflect only the distribution and transmission costs allocated to individual hours. Under this approach, unbundled customers would continue to procure generation service from their Electric Service Provider (ESP) or Community Choice Aggregator (CCA), consistent with existing practice.
Allowing unbundled customers access to SCE’s dynamic rate would support broader demand flexibility objectives, while leaving the design of generation-related rates to each customer’s ESP or CCA.
Read the filings
The excerpts above are drawn from CLECA’s filings in this proceeding. Read the complete documents: