In this application, SDG&E is proposing a time-of-use rate with a fixed charge designed to encourage greenhouse gas (GHG) reduction by promoting electrification of behind-the-meter (BTM) technologies such as electric vehicles, energy storage units and heat pumps. The idea here is whether or not a specially designed rate will incentivize people to 1) buy more electric products and technologies and 2) use electricity at the optimum times during what is known as a “super off-peak” period (or in layman’s terms when electricity is abundant and cheap). UCAN has identified issues such as whether the TOU differentials are appropriately set to incentivize electricity usage outside of the on-peak period and whether the rate design avoids cost-shifts to non-participating customers. While UCAN supports California’s goals to reduce GHG emissions and believes this rate is a step in the right direction, UCAN continues to raise concerns about the costs and benefits to ratepayers of these state goals. UCAN plans to fully participate in this proceeding to protect the interests of all ratepayers in SDG&E territory.
