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SCE rate mechanics for a small Santa Monica studio (TRC / Tiny Room Studios)

Compiled 2026-09-06. Primary sources are SCE's live CPUC-filed tariff sheets, pulled from SCE's own SharePoint tariff book (the library.sce.com host in older links no longer resolves).

Tariff vintage used throughout: Advice 5837-E, effective June 25, 2026, the version in force today.

Local copies of every primary PDF:

How to re-fetch the tariff sheets (they are behind an anonymous SharePoint share; a plain curl of the file path returns 403 without first visiting the share link to pick up a cookie):

# 1. get the anonymous cookie for the "General Service & Industrial Rates" folder
curl -sSL -c cj.txt -o /dev/null \
  "https://edisonintl.sharepoint.com/:f:/t/Public/TM2/EszM_J-L6AhFmonA_791cIUBjKqTWzn4Qap-XVMbdqNQ4A"
# 2. download (response is multipart; strip everything before %PDF- and after %%EOF)
base="https://edisonintl.sharepoint.com/teams/Public/TM2/Shared%20Documents/Public/Regulatory/Tariff-SCE%20Tariff%20Books/Electric/Schedules/General%20Service%20%26%20Industrial%20Rates"
curl -sSL -b cj.txt -o raw.bin "$base/ELECTRIC_SCHEDULES_TOU-GS-2.pdf"
# Rules folder uses its own share link:
#   https://edisonintl.sharepoint.com/:f:/t/Public/TM2/EiNTgBFFxTdIiIsEZtplmhQBbhkD28HYDDo6z8EuJ9BeDw

Public landing pages (no login):

• SCE Tariff Books: https://www.sce.com/regulatory/regulatory-information/tariff-books
• Rates & Pricing Choices (schedules): https://www.sce.com/regulatory/regulatory-information/tariff-books/rates-pricing-choices
• Rules: https://www.sce.com/regulatory/regulatory-information/tariff-books/rules
• Historical Rates 2026: https://www.sce.com/regulatory/regulatory-information/tariff-books/historical-rates/historical-rate-schedules-for-2026
• PCOC form (direct PDF): https://www.sce.com/sites/default/files/custom-files/PDF_Files/PCOC-form.pdf

1. TOU-GS-1 applicability and the 20 kW threshold

Confidence: high.

Verbatim, Schedule TOU-GS-1, Sheet 1, APPLICABILITY:

Applicable to single- and three-phase general service including lighting and power, except that the Customer whose monthly maximum demand, in the opinion of SCE, is expected to exceed 20 kW or has exceeded 20 kW in any three months during the preceding 12 months is ineligible for service under this Schedule. Effective with the date of ineligibility, the Customer's account shall be transferred to Schedule TOU-GS-2. This Schedule is subject to meter availability.

Key points:

• The test is monthly maximum demand, not a 12-month peak. One 20 kW month does not disqualify you.
• Disqualification requires exceeding 20 kW in any three months out of the trailing twelve, or SCE forming the opinion that you are expected to exceed it.
• "Exceed 20 kW" means strictly above 20 kW. Billing Demand is rounded to the nearest kW (TOU-GS-2 Special Condition 6), so 20.4 kW registers as 20 kW.
• The same three-in-twelve test defines a "Small Business Customer" for the California Climate Credit (TOU-GS-1 Special Condition 13 / TOU-GS-2 Special Condition 13), credited in April and October.

Ari's internal ceiling of 19.5 kW is conservative but correct in spirit: it leaves headroom against rounding and against SCE's forward-looking "expected to exceed" discretion.

Source: cur_TOU-GS-1_clean.pdf Sheet 1, Revised Cal. P.U.C. Sheet No. 91383-E. Consumer-facing restatement: https://www.sce.com/factsheet/rate-schedule-tou-gs-1

2. The rule that moves a customer UP from GS-1 to GS-2

Confidence: high.

It is the same sentence quoted above. The mechanism is automatic and prospective:

...has exceeded 20 kW in any three months during the preceding 12 months is ineligible for service under this Schedule. Effective with the date of ineligibility, the Customer's account shall be transferred to Schedule TOU-GS-2.

The mirror-image language sits in TOU-GS-2's applicability, which is where a GS-2 customer's own upward test to GS-3 lives ("expected to reach 200 kW or has reached 200 kW for any three months during the preceding 12 months").

Note the asymmetry that matters operationally: going up takes three bad months; coming down takes twelve good ones (see item 3). A single summer of uncontrolled AC starts can cost a year on GS-2.

Source: cur_TOU-GS-1_clean.pdf Sheet 1; cur_TOU-GS-2_clean.pdf Sheet 1.

3. The rule that moves a customer back DOWN to GS-1, and what the PCOC form does

Confidence: high. This is the core of the plan and the wording is unambiguous.

3a. The default path: twelve consecutive months

Verbatim, Schedule TOU-GS-2, Sheet 1, APPLICABILITY:

Applicable to single- and three-phase general service including lighting and power Customers whose monthly Maximum Demand registers, or in the opinion of SCE is expected to register above 20 kW and below 200 kW. [...] Any Customer served under this Schedule whose monthly Maximum Demand has registered 20 kW or less for 12 consecutive months will be transferred to Schedule TOU-GS-1. This Schedule is subject to meter availability.

3b. The shortcut: Permanent Change in Operating Conditions

Immediately following, in the same APPLICABILITY section:

A Customer who makes a permanent change in operating conditions that SCE, in its sole opinion, anticipates will reduce the Customer's demand to 20 kW or less, may transfer to another applicable rate schedule before completing 12 consecutive months at the reduced demand levels. Such Customer shall be required to sign the Permanent Change in Operating Conditions Declaration, Form 14-548.

Underlying authority is Rule 12 § D.2, which permits an off-cycle schedule change where "There has been a change in the customer's operating conditions for that service which, in the opinion of SCE, justifies the change" (Rule 12 Sheet 2, § D.2.c). Rule 12 § D.2.a otherwise limits changes to once per twelve months, and § D.3 makes an ordinary elective change effective "for service rendered after the next regular meter reading following the date of notice to SCE."

3c. What the customer actually certifies on Form 14-548

The form is one page. Verbatim, the operative paragraphs:

The undersigned customer has made permanent change in operating conditions which is anticipated to reduce demand on SCE's electrical system and to result in the customer being eligible for another rate schedule. The customer has requested a change of rate schedule as provided by Section D.2 of SCE's Rule 12, from Schedule ______ to Schedule ______ before completing the required 12 consecutive months of service at the new demand level, and hereby:

1. Declares that a permanent change in operating conditions has occurred for service located at ______

2. Understands that:

   a. A permanent change in operating conditions is the result of permanent removal of electrical equipment or implementation of energy management measures acceptable to SCE at the customer's premises. Demand on SCE's electrical system must be reduced to a level which would otherwise qualify the account for a change of rate schedule provided the account would operate at the new demand level for 12 consecutive months.

   b. SCE has the right to inspect the customer's premises and electrical equipment to determine if, in SCE's opinion, a permanent change in operating conditions has occurred.

   c. SCE has the right to downsize its normal serving facilities to reflect the customer's reduced level of demand, at customer's expense if service has been for less than 36 months.

   d. For customers with such permanent changes, the effective date of the rate schedule change shall be the next regularly scheduled billing period following (1) the date of the written request to SCE for the change of rate schedule, (2) the date, verified by SCE of the permanent change in operating conditions, or (3) the date this Declaration is signed by both parties, whichever is later.

   e. If the above account's demand level, in any month following the effective date of this change of rate schedule, exceeds the demand level limit of the new schedule, the account shall be changed back to the original schedule. The account will be rebilled by SCE as if there had been no change of rate schedule. The account is subject to this change until it would be otherwise eligible for a change of rate schedule.

   f. This Declaration in no way alters, replaces or supersedes the provisions of Rule 12.

Signature blocks: Corporate or Customer Name, Telephone Number, By, Date, Title, and an SCE Major Account Representative countersignature with date.

Kindly submit this form to SCE by email to: CICORR@sce.com

Form revision stamp: SCE 14-548 REV 5/1/24.

3d. Consequences , read paragraph 2.e carefully

This is the single most important sentence in the whole file, and it is harsher than a plain "transfer back":

1. The trigger is one month, not three. Paragraph 2.e says "in any month following the effective date... exceeds the demand level limit of the new schedule." The three-months-in-twelve grace in TOU-GS-1's applicability does not protect a PCOC transferee. One month above 20 kW breaks it.
2. Retroactive rebilling. "The account will be rebilled by SCE as if there had been no change of rate schedule." Every month billed on GS-1 since the effective date gets recomputed at GS-2 rates, including the $268.43/month customer charge and demand charges on every one of those months.
3. Minimum stay before you can try again. "The account is subject to this change until it would be otherwise eligible for a change of rate schedule", i.e. back to the ordinary twelve-consecutive- months-at-or-below-20 kW route.
4. Effective date is the latest of three dates, and one of them is SCE's own verification date. Filing the form does not by itself start the clock.
5. SCE may inspect (2.b) and may downsize service facilities at the customer's expense if service has been in place under 36 months (2.c). The current contract account [account] was opened around 1/29/26, so as of today the site is inside that 36-month window and the downsizing-at- customer-expense clause is live. Worth raising with Kari Gardner before filing.
6. It needs an SCE Major Account Representative countersignature, this is not a unilateral filing.

Practical read: do not file the PCOC until the physical change is done and interval data proves a sustained margin below 20 kW. The asymmetry (one bad month → full retroactive rebill) makes an early filing strictly worse than waiting.

Sources: cur_TOU-GS-2_clean.pdf Sheet 1; ELECTRIC_RULES_12.pdf Sheets 1-2; PCOC-form.pdf, https://www.sce.com/sites/default/files/custom-files/PDF_Files/PCOC-form.pdf

4. How SCE measures billed demand, and the verdict on compressor inrush

Confidence: high. This section answers the Ari/Farzad/Victor disagreement definitively.

4a. The tariff definition

Rule 1, DEFINITIONS:

Maximum Demand: The average kilowatts during the specified time interval when the customer's use is greatest in the billing period as indicated or recorded by the meter.

Billing Demand: The load or demand used for computing charges under rate schedules based on maximum demand, or a modification of either as provided for by applicable rate schedule.

Rule 1 also defines the meter class:

Interval Data Recorder (IDR) Meter: A metering device capable of recording minimum data required. Minimum data requirements include (a) hourly usage required for the Direct Access settlement process; and (b) data required to bill SCE's distribution tariffs including 15-minute demand data.

4b. The interval, stated in the schedule itself

Schedule TOU-GS-2, Special Condition 5:

Maximum Demand: The Maximum Demand shall be established for all applicable TOU Periods. The Maximum Demand for each TOU Period shall [be] the measured maximum average kilowatt (kW) input, indicated or recorded by instruments, such as SCE metering, during any 15-minute metered interval, but where applicable, not less than the diversified resistance welder load computed in accordance with the section designated Welder Service in Rule 2. Where the demand is intermittent or subject to violent fluctuations, a 5-minute interval may be used.

Special Condition 6:

Billing Demand: The Billing Demand shall be the kW of Maximum Demand, determined to the nearest kW. When applicable, the Time Related Demand (TRD) component shall be for the kW of Maximum Demand recorded during (or established for) each of the TOU Periods, as applicable according to the Customers TOU Option. The Facilities Related Demand (FRD) component shall be for the kW of Maximum Demand recorded during (or established for) the monthly billing period.

So: billed demand is the highest 15-minute average kW in the billing period (FRD), plus the highest 15-minute average within specific TOU windows (TRD). Not an instantaneous peak. Not an amp reading.

4c. The arithmetic on inrush

A 15-minute interval is 900 seconds. A locked-rotor surge is a fraction of a second and is averaged over the whole 900 seconds.

Two further points that push the real number even lower:

• The meter records kW, not kVA. Locked-rotor current runs at a power factor around 0.2-0.5, so the real power during inrush is roughly a third to a half of the apparent-power figures above.
• Even the worst case in that table, every compressor on site starting in the same instant, on the more aggressive 5-minute interval , moves billed demand by about a quarter of a kilowatt. Rounded to the nearest kW, it usually disappears entirely.

4d. Verdict

Compressor start-up inrush is not a driver of SCE billed demand. Victor and Farzad are right; the soft-starter theory is wrong as a demand-charge strategy.

Victor's exact words on 2026-08-28, "compressor savers... help with startup amps but not running amps so they won't do major changes to your electric bill", are correct on the tariff mechanics. Greg's reply, "It's just the startup amps that are the problem for us," is the part that does not survive contact with the 15-minute averaging rule.

What does set the 19.5 kW number is coincident running load sustained across a full quarter hour: seven AC compressors drawing steady running current at the same time, plus the LED video wall, the sauna, mini fridges, studio gear, and, the single largest identified item, Tesla charging at 11.3 kW, which is more than half the entire GS-1 allowance on its own and runs for hours, not milliseconds.

Two caveats stated honestly:

• Soft starters are not worthless. They reduce mechanical and electrical stress, cut voltage sag and light flicker, and reduce nuisance breaker trips on a marginal panel (relevant given the flagged Zinsco panel). They are simply not a demand-charge intervention.
• If any individual unit has a long, heavy unloading/pull-down period, several minutes at well-above-running current after a start, that period does land in the 15-minute average. That is a different phenomenon from inrush, and it is measurable in interval data. The $4,500 soft-starter quote should not be spent on the strength of the inrush theory alone.

Recommended test before spending anything: pull 15-minute interval data for 1/22/2026 (the 19.5 kW day) and 2/28/2026 (the 17.6 kW day) and identify which quarter-hour intervals peaked and what was running. See item 6.

Sources: ELECTRIC_RULES_1.pdf (Definitions sheet); cur_TOU-GS-2_clean.pdf Special Conditions 5-6.

5. Current rates and worked bill comparison

Confidence: high on the rate figures (read directly off the filed tariff sheets); moderate on the worked totals, which depend on an assumed load shape.

All figures below are $/kWh or $/kW, Advice 5837-E, effective June 25, 2026, and are the total of Delivery Service + Generation (UG) for a bundled service customer, plus the separately stated Fixed Recovery Charge and MCAM Charge.

5a. TOU-GS-1, small (≤ 20 kW)

5b. TOU-GS-2, medium (> 20 kW, < 200 kW)

5c. What a kilowatt costs on GS-2

A single summer-evening excursion from 19 kW to 22 kW costs $203 in that month alone on Option D, and, if the account is on GS-1 under a PCOC declaration, triggers the full retroactive rebill described in item 3d.

5d. Worked bill comparison

Load-shape assumptions (studio, evenings and weekends), applied identically to every rate so the comparison isolates the tariff difference:

• Summer (Jun 1-Sep 30): 20% of kWh in weekday On-Peak (4-9 pm), 8% in weekend/holiday Mid-Peak, 72% Off-Peak.
• Winter (Oct 1-May 31): 25% in Mid-Peak (4-9 pm all days), 42% Off-Peak (9 pm-8 am), 33% Super-Off-Peak (8 am-4 pm).
• Max demand 20 kW in every month, on both rates, three-phase service, 30.4 days/month.
• Climate Credit excluded (it applies in only two months and is identical on both schedules).

Best-available-option savings from moving GS-2 → GS-1:

Three findings worth flagging:

1. The single biggest line item is the customer charge, not the demand charge. GS-2 carries a $268.43/month fixed customer charge against GS-1's ~$15.63/month. That is $3,034/year of pure fixed savings before a single kilowatt-hour or kilowatt is priced.
2. The right GS-1 option flips with usage. Below roughly 4,000 kWh/month, Option E (no demand charges) wins. Above that, Option D wins despite carrying demand charges, because its energy rates are 60-70% lower. At 6,000 kWh/month, picking Option E over Option D costs about $270/month. Run SCE's rate comparison tool (https://www.sce.com/ratetool) against 12 months of real data before choosing; the default on GS-1 is Option E-CPP.
3. The reported "$3,600 for a month" bill is consistent with roughly 12,000-16,000 kWh on GS-2, not with a demand-charge spike on modest usage. That points at the load itself, Tesla charging, video wall, seven AC units, rather than at start-up transients.

Sources: cur_TOU-GS-1_clean.pdf Sheets 4-6; cur_TOU-GS-2_clean.pdf Sheets 4-7. Model: calc.py.

6. Interval data, Green Button, and demand alerts

Confidence: high on data access; moderate on the absence of a native demand-alert product (proving a negative from public documentation).

6a. What the site already has

An Edison SmartConnect meter on a non-residential rate records 15-minute interval data. SCE states this directly: "If you have an Edison SmartConnect™ or interval data meter, and you are enrolled in a non-residential rate, you should be able to view energy usage data at up to 15-minute intervals." (https://www.sce.com/customer-service-center/help-center/my-account/energymanager/data-issues/unable-to-view-15-minute-interval-data)

6b. Green Button Download, self-service, free, do this first

• Where: My Account → Data Sharing & Download, https://www.sce.com/mysce/abs/dataSharing
• Formats: CSV or XML (NAESB ESPI Green Button standard)
• History: up to 36 months depending on meter
• Cost: free
• Latency: daily

This is the direct route to the 1/22/2026 and 2/28/2026 quarter-hour peaks. It requires no forms and no vendor.

6c. SCE EnergyManager, not available to this site

EnergyManager is SCE's own 15-minute analytics suite, and it is the obvious tool for this job, but eligibility is explicit: "you must be a business customer with a monthly demand exceeding 200 Kilowatts at least three times in the past 12 months." A ~20 kW account does not qualify. (https://www.sce.com/business/resources/resources/sce-energy-manager)

6d. Green Button Connect My Data, the API route

Ongoing, automated third-party access over a RESTful API with OAuth 2.0 authorization; the customer authorizes and can revoke at any time. The third party must register with SCE and pass a connectivity test. Contact: GreenButton@sce.com.

• Registration: https://www.sce.com/partners/partnerships/thirdpartylandingpage
• Overview: https://www.sce.com/partners/3rd-party-energy-providers/access-energy-usage-data

UtilityAPI is an established aggregator with an SCE integration and is the shortest path to a live feed without building an ESPI client. Emporia is a separate proposition: it is a hardware CT-clamp monitor installed in the panel, giving second-resolution local data independent of SCE. For catching a demand creep in real time, panel-level hardware is the better fit than a utility API with daily latency.

6e. CISR Form 14-796, the paper route

Option 5 (Interval Meter Usage Data) costs $9.00 per service account, processed in about 10 business days. Useful for handing 36 months of interval data to a consultant in one shot. (https://www.sce.com/customer-service-center/help-center/my-account/other/customer-information-service-request-faqs)

6f. Demand alerts

SCE does not offer a demand-threshold alert for small commercial customers. Budget Assistant and Energy Alerts are residential bill-threshold tools. The Demand Response (DR) Alerts app notifies of CPP and DR events, not of the customer's own kW. Any "you are approaching 20 kW" alarm has to be built:

• a panel-level monitor (Emporia Vue 3, IoTaWatt, Sense, eGauge) with a webhook, or
• a nightly job pulling Green Button Connect / UtilityAPI and alerting on the daily max 15-minute average.

Given the retroactive-rebill exposure in PCOC paragraph 2.e, a real-time monitor with an alarm is not optional, it is the control that makes the PCOC filing safe. This matches Greg's stated want for an "electrical tracker."

7. Demand limiters, load controllers, batteries, and SGIP in 2026

Confidence: high on SGIP status; high on the tariff treatment of storage; moderate on the "acceptable to SCE" question, which is discretionary by construction.

7a. Do load controls or batteries affect rate eligibility?

Nothing in Rule 12, TOU-GS-1, or TOU-GS-2 prohibits demand limiters, load controllers, or batteries. The tariff is neutral about how demand is reduced and cares only about the metered result. More than that, the PCOC form names load management as a qualifying mechanism:

A permanent change in operating conditions is the result of permanent removal of electrical equipment or implementation of energy management measures acceptable to SCE at the customer's premises.

So an automated load controller, one that hard-limits AC compressor coincidence and throttles the Tesla charger, is a textbook "energy management measure." The load-bearing phrase is "acceptable to SCE." That is SCE's discretion, exercised by the Major Account Representative who countersigns, and backed by the inspection right in paragraph 2.b. A permanent, hard-wired interlock is a far stronger case than a staff policy. The current 15-minute AC stagger rule (in force since 2026-03-17) is a procedure, not equipment; SCE is unlikely to accept a written staff policy on its own as a permanent change in operating conditions.

7b. Storage-specific rate options

• TOU-GS-1 Option ES / ES-CPP. Available to customers who install on-site behind-the-meter storage, standalone or paired. Minimum capacity is the greater of 4.8 kWh or 0.05% of the prior 12 months' annual usage. Capped at 15,000 customers statewide. Customers on Option ES are exempt from Standby service (Schedule S). Note the customer charge is higher: $1.321/meter/day (≈ $40.16/month) versus $0.468 on Options D and E. (cur_TOU-GS-1_clean.pdf Sheet 1 and Sheet 5)
• TOU-GS-2 Option R. For customers above 20 kW with renewable DG sized at ≥ 15% of annual peak demand. FRD $24.00/kW and no TRD. Not relevant if the goal is to leave GS-2.

A battery sized to shave a few kW off a 15-minute average is technically straightforward, the Kora Power product Ari found is aimed at exactly this. But note the sequencing risk: Kora's ship estimate has slipped from "around June" through "August-September" without a firm date, so the plan should not depend on it.

7c. SGIP in 2026 , effectively unavailable

The relevant budget for a small commercial customer is closed.

• The General Market Large-Scale Storage budget (the non-residential general-market category) closed to new applications after December 30, 2025.
• As of the current SGIP program-metrics page, SCE's status for Large-Scale Storage is "Closed" at Step 5 ($0.25/Wh, or $0.18/Wh with ITC), and Non-Residential Storage Equity is "Closed" at Step 5 ($0.85/Wh).
• The only category still accepting submissions is Residential Solar and Storage Equity (AB 209), which is residential-only and itself fully reserved with a waitlist.

Sources: https://www.selfgenca.com/home/program_metrics/ , https://www.sce.com/clean-energy-efficiency/solar-generating-your-own-power/billing-incentives/self-generation-incentive , https://sgipsd.org/budget

Plan the battery economics with a $0 SGIP rebate. Anything that arrives later is upside. The federal ITC remains a separate question and is outside this tariff research.

8. TOU-GS-1 sub-options and the right one for an evenings/weekends studio

Confidence: high on the option list and period definitions; moderate on the recommendation, which depends on the actual kWh and load shape.

8a. The options that exist

Schedule TOU-GS-1 contains ten rate structures. Note that the "GS-1-A/B/C" naming in the question is the legacy scheme; the current options are lettered differently:

8b. TOU periods (current, Options E / E-CPP / D / ES / ES-CPP / LG)

Verbatim from Special Condition 1:

Summer runs 12:00 a.m. June 1 to 12:00 a.m. October 1. Winter is the other eight months. Holidays are New Year's Day, Presidents' Day, Memorial Day, Independence Day, Labor Day, Veterans Day, Thanksgiving, and Christmas; a holiday on Sunday moves to Monday, and a holiday on Saturday does not move.

Yes, the peak window is 4-9 p.m., and the answer to "which option for an evening/weekend studio" turns almost entirely on that, because a studio's busiest hours sit squarely inside it.

8c. Recommendation

• On weekends, the 4-9 p.m. window is Mid-Peak, not On-Peak, materially cheaper. Weekend-heavy operation is already advantaged.
• Below ~4,000 kWh/month: Option E or E-CPP. No demand charges at all, which removes any residual exposure to a demand spike and is the cleanest complement to a PCOC filing.
• Above ~4,000 kWh/month: Option D, despite its demand charges, because its energy rates run 60-70% below Option E's. At 6,000 kWh/month, Option D is about $270/month cheaper (item 5d). The trade-off is that Option D reintroduces a $22.61/kW FRD and a $21.38/kW summer on-peak TRD, so it only makes sense alongside a working demand monitor.
• CPP: an account with 24+ months of TOU experience defaults to a CPP option annually each October. CPP gives four months of summer bill credits in exchange for 12-15 events at 4-9 p.m., with one year of Bill Protection. For a studio that can shed the video wall and defer Tesla charging on 12-15 notified days per year, CPP is a reasonable bet. Note the lock-in: unenrolling from CPP blocks any further rate change for at least one year.
• If a PCOC transfer is granted and the account was on a CPP option on GS-2, GS-1 Special Condition places it on Option E-CPP by default: "Customers enrolled in a CPP Option under another Schedule who are moved to this Schedule due to a permanent change in operating conditions and a change in their Maximum Demand will be enrolled in Option E-CPP or Option A-CPP of this Schedule, as applicable, or may elect another applicable Option."

Verify the option choice with SCE's rate comparison tool against 12 months of real interval data: https://www.sce.com/ratetool (it requires 12+ months of history).

Source: cur_TOU-GS-1_clean.pdf Sheet 1 and Special Conditions 1 and 11.

9. Is there any SCE rate at 20-30 kW that avoids demand charges entirely?

Confidence: high. The answer is no.

Every general-service schedule applicable above 20 kW carries a Facilities-Related Demand charge:

Option E is the closest thing to a no-demand-charge GS-2 rate, and it is not one. It removes the delivery portion of the TRD (delivery TRD is $0.00) but retains a generation TRD of $5.65/kW summer on-peak and $2.18/kW winter, and it keeps a $15.83/kW FRD. It buys that reduction with brutal energy rates: $0.85772/kWh in summer On-Peak, more than five times Option D's $0.16629. For a studio whose load sits in the 4-9 p.m. window, Option E is the worse choice at every usage level modelled in item 5d except low-usage summer months.

The structural point, stated plainly: the only SCE rate for a facility in this class with no demand charges at all is TOU-GS-1 Option E or E-CPP, and it is only reachable by staying at or below 20 kW. There is no 20-30 kW escape hatch. The rate design deliberately makes 20 kW a cliff, which is exactly why the ~19.5 kW ceiling and a real-time monitor are the whole strategy.

Note also that GS-2's $268.43/month customer charge is itself demand-driven in effect: it is 17× the GS-1 charge and is incurred whether the facility peaks at 21 kW or 199 kW.

Sources: cur_TOU-GS-2_clean.pdf Sheets 4-7; https://www.sce.com/sites/default/files/custom-files/PDF_Files/2025_Summary_of_Available_Residential_and_Nonresidential_Rates.pdf

Bottom line for the TRC decision

1. Inrush is a dead end. Billed demand is a 15-minute average; a half-second surge contributes about 0.013 kW. Do not spend $4,500 on soft starters as a demand-charge fix. (item 4)
2. The prize is roughly $5,000-8,000/year, and about $3,000 of it is the customer charge alone. (item 5d)
3. The PCOC shortcut is real but sharp-edged. One month above 20 kW after the transfer triggers a full retroactive rebill at GS-2 rates, not a simple transfer back. Do not file until the physical change is installed and interval data proves margin. (item 3d)
4. Build the monitor before filing the form. SCE offers no demand alert at this size, and EnergyManager is barred below 200 kW. Green Button Download costs nothing and answers the 1/22 and 2/28 spike questions today. (item 6)
5. Plan the battery with a $0 SGIP rebate. The non-residential budget closed to new applications after 12/30/2025. (item 7c)
6. The real load question is the Tesla charger at 11.3 kW, plus coincident AC running load. That is where the 19.5 kW comes from, and where a hard interlock earns its keep. (item 4d)