In Southern California Edison's test-year 2025 general rate case, Sam Harper testified for a seven-organization coalition spanning California's industrial and agricultural ratepayers.
What we filed
The February 2024 direct testimony (with rebuttal in April 2024) recommended that the Commission:
- Acknowledge the seriousness of current electric rate unaffordability and the uncertainty in the timing and location of anticipated load growth from transportation electrification.
- Not allow SCE to dramatically increase its revenue requirement in ways that hinder ratepayers' own electrification decisions — the cost-effective load growth that could put downward pressure on rates.
- Approve only investments that promote load growth resulting in reduced electricity rates within the GRC cycle.
- Establish broadly available dynamic price tariffs and related rate reforms before approving massive distribution investments to connect new loads.
Why it matters
The testimony framed a discipline the Commission can apply to every load-growth spending request: does the investment lower rates for the customers who fund it, within the period they fund it? That framing carries directly into PG&E's 2027 GRC and the load-growth investment debates now running across all three California IOUs.
Facing a related regulatory or commercial question? Harper Advisory works with a focused number of large industrial energy users across ERCOT, CAISO, PJM, and other US markets.
Contact UsThis summary is drawn from documents on the public record and is provided for general information. It is not legal advice, and it does not disclose any confidential client matter.