On March 31, 2017, a group of California parties, consisting of
various public power utilities and the California Public Utilities
Commission (the "Complainants"), alleged in their
complaint at FERC that Pacific Gas and Electric Company's
("PG&E") proposed transmission rates in its
eighteenth rate filing ("TO-18") contained significant
errors and overstated expenses. The Complainants requested
that FERC investigate the proposed TO-18 rates, which FERC had
already set for hearing and settlement judge procedures in a
separate proceeding. In addition, the Complainants requested that
FERC exercise its authority to supplement the refund effective date
established for the proposed TO-18 rates, in the event that the
record eventually justified establishing a revenue requirement
below PG&E's last "clean" rate, established
through settlement in its seventeenth rate filing
On July 29, 2016, PG&E submitted TO-18 for filing,
requesting an increase in its current wholesale Network
Transmission Revenue Requirement of approximately $386.6 million.
In their March 31, 2017 complaint, the Complainants stated
that they had identified numerous errors in PG&E's
cost-of-service calculations that would require a significant
reduction to its proposed TO-18 rates. Specifically, the
Complainants alleged that various "themes" occurred
throughout PG&E's TO-18 filing, including: (1) proposed
expenses that were inconsistent with established FERC policies and
practices, which thereby resulted in overstated proposed rates; (2)
an overstated wholesale Network Transmission Revenue Requirement;
and (3) an improper allocation of expenses to wholesale Network
The Complainants stated that the numerous errors in
PG&E's cost-of-service calculations would reduce
PG&E's Network Transmission Revenue Requirement below the
level requested by PG&E in its TO-18 filing, and below the
level previously approved by settlement in TO-17. Therefore,
the Complainants explained that the March 31, 2017 complaint would
"ensure that the Commission has the requisite authority to
order refunds below the rate level established in TO-17."
Lastly, the Complainants moved to consolidate the proceeding in
which their March 31, 2017 complaint was filed with the ongoing
TO-18 proceedings, stating that "common issues of law and fact
warrant deciding the Complaint and the TO-18 case
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