Southern California Edison asked the CPUC to approve a dynamic pricing rate for large power customers — moving large C&I rates toward marginal-cost-based, time-varying prices. CLECA's members are precisely the customers the rate would serve.
What we filed
Sam Harper's direct testimony (January 2026) supported Commission authorization of SCE's proposed large power dynamic pricing rate, testifying that:
- The proposed rate is reasonable and consistent with the Commission's rate design principles and the CEC's Load Management Standards.
- The rate will not cause cost shifting to other customers.
- Base Interruptible Program (BIP) customers should be allowed to take service on the dynamic rate — preserving dual participation between demand response and dynamic pricing.
- The rate should be available to unbundled (direct access) as well as bundled customers.
Rebuttal testimony followed in February 2026 and supplemental rebuttal in May 2026, defending those positions as the record developed.
Why it matters
A voluntary, well-designed dynamic rate rewards exactly the operational flexibility large industrial customers can provide — and the design details adopted here will inform how dynamic rates are built at PG&E, SDG&E, and in the CPUC's broader advanced rate design rulemaking. The dual-participation and direct-access questions determine whether the customers best positioned to respond can actually use the rate.
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.