CPUC Proposed Decision Modifying Negative CTC Recovery

In the same Decision that the CPUC is considering voting out on suspending
Direct Access, the CPUC is considering a SoCal Edison recommendation to
suspend further payment of the Negative CTC to marketers.

The Decision would find that the earlier Stipulation does not require SCE to
make a cash payment in lieu of a bill credit (even though SCE has already
paid cash in previous periods for the Negative CTC).
The Decision orders SCE to not make cash payments to satisfy the Negative CTC
credit.
The Decision is unclear as to whether or not this is simply a suspension of
payment or would be permanent.
The Decision would apply the same findings and rulings to PG&E and SDG&E.

The key issue is that rather than having a cash receivable, EES would now
have a bill credit receivable. In addition, because EES re-sourced its
customers, the Utility account that holds the bill credit is EES, not the
customer account. The only method to obtain the economic value of the bill
credit is to utilize the Utilities' services. Even if EES physically serves
the customers going forward, it may not be the same account that has the bill
credit.

The outcome of this case would impact our current Complaint, but it is
unclear exactly how the CPUC would apply this Decision to that case.

We are intending to (a) try to remove this issue from the CPUC Decision, (b)
trying to clarify the suspension is not meant as a vehicle to deny us
payment, and © trying to determine that the Utilities' tariff would allow
us to be paid if our account became "inactive".

One other option to consider (at least for SCE) would be to contact SCE
management to work out a bill credit application process to allow EES to
route the economic value to our DA customers.

If anyone has any questions, please call me to discuss.

Jim