Details for: 3640-E (Part 1 of 1).pdf

Click on the image for full size preview

Document data

Erik Jacobson
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

August 1, 2017

Advice 5119-E
(Pacific Gas and Electric Company – U 39 E)

Advice 3640-E
(Southern California Edison Company – U 338 E)

Advice 3103-E
(San Diego Gas & Electric Company – U 902 E)

Public Utilities Commission of the State of California

Update to Community Choice Aggregate and Energy Service
Provider Load Data and Utility Investment and Procurement

Pursuant to Ordering Paragraph (OP) 5 of California Public Utilities Commission (CPUC
or Commission) Decision (D.) 17-04-039, Pacific Gas and Electric Company (PG&E),
on behalf of Southern California Edison (SCE), and San Diego Gas and Electric
(SDG&E), respectfully submits this advice letter to update Tables 3 through 6 based on
the most current Community Choice Aggregator (CCA) and Energy Service Provider
(ESP) load data and utility investment and procurement information.
On October 21, 2013, the Commission issued D.13-10-040 to establish the Energy
Storage Procurement Framework and Design Program (“Energy Storage Program”).
The Energy Storage Program set a procurement target of 1,325 megawatts of energy
storage projects for the Investor-Owned Utilities (“IOU”) to procure through a series of
solicitations from 2014 to 2020.1 All storage projects must be online no later than
Additionally, the Energy Storage Program set a procurement target for all CCAs and
ESPs to procure one percent of their 2020 load, with all storage projects being online

D. 13-10-040, Appendix A, p.1


- Page 1 -

Advice 5119-E, et al. -2- August 1, 2017 no later than 2024.3 As determined by the Commission, the one percent procurement target for CCAs and ESPs is in addition to paying for a portion of IOU storage procurement via non-bypassable charges.4 On January 5, 2016, the CPUC issued a Scoping Memo and Ruling in Track 2 of the Energy Storage Order Instituting Rulemaking (OIR) seeking parties’ comments on revision of energy storage procurement targets.5 The Alliance for Retail Energy Markets and Direct Access Customer Coalition (AReM/DACC) argued that some CCA/ESP procurement obligations can exceed a utility’s, and proposed to prohibit future cost recovery through non-bypassable charges and credit ESPs with any excess storage for procurement that is above what the IOUs are obligated to procure. 6 In D.17-04-039, the Commission ruled that revisions to cost recovery of storage procurement were beyond the scope of the proceedings, but that it was in scope to consider revisions to the CCA/ESP storage procurement targets. The Commission reviewed the extent to which the combined one percent procurement obligation and non-bypassable charges assigned to CCAs/ESPs compares with the utility procurement obligations, as a percentage of utility load. In the instance that a CCA/ESP procurement obligation exceeds that of the utility, the Commission adopted an automatic limiter that proportionately reduces each CCA/ESP one percent procurement obligation by the amount the load serving entity’s procurement plus its customers’ share of non-bypassable charges exceeds the utility obligation by a percentage of load.7 Comparing IOU and CCA/ESP storage procurement obligations as a percentage of load is done using Tables 3 through 6 of D.17-04-039. D.17-04-039 requires the IOUs to update Tables 3 through 6 on an annual basis beginning August 1, 2017 through 2020. The updated tables are provided. 3 4 5 6 7 D.13-10-040, p. 46 Ibid. R.15-03-011 – “Assigned Commissioner and Assigned Administrative Law Judge’s Scoping Memo and Ruling Seeking Party Comments,” p. 5-6. D.17-04-039, p.22-23. D.17-04-039, p.27.
- Page 2 -

Advice 5119-E, et al. -3- August 1, 2017 Updated Tables Table 3: ENERGY STORAGE COST RECOVERY (Data as of July 2017) SERVICE TERRITORY PG&E Storage MW recovered or approved for recovery via non-bypassable charges (to date)8 Future (known additional) MW expected to be recovered via CAM Total MW expected to be recovered via nonbypassable charges 9 SCE SDG&E 316.96 53.6711 None known 100.512 83.513 16.5 417.46 137.17 16.5 10 Table 4: DIRECT ACCESS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of June 2017) SERVICE TERRITORY Applicable ESP load (GWh)14 DA MW share of non-bypassable charges15 1% ESP procurement obligation (GWh) 8 9 10 11 12 13 14 15 PG&E 9,657 2 97 SCE 11,260 54 113 SDG&E 3,400 10 34 This information reflects Cost Allocation Mechanism (CAM) and distribution charge recovery, and only those contracts that have been approved for recovery to date. Storage projects resulting from the biennial storage solicitations have not yet come on-line, so their above market costs have not been identified, and PCIA costs have not yet been allocated to nonutility Load Serving Entities (LSEs). We do not include a requirement of a forecast of nonbypassable charges as suggested by CCA Parties in comments on the Proposed Decision as we find this too speculative and of limited value. 6 MW via distribution charge + 10 MW of customer-sited SGIP/PLS projects (R.15-03-011: Motion of PG&E to Further Update Information in its January 4, 2016 Report Regarding Energy Storage System Procurement Targets and Policies - July 7, 2017), and 0.5 MW for Browns Valley (A.16-03-001; D.16-09-007). 13.92 MW via distribution charge + 17.4 MW of SGIP/PLS + 22 MW of Aliso Canyon Energy Storage (ACES) projects (Resolution E-4804 - 5 MW of original 27 MW authorization was cancelled) + 263.64 MW in West LA Basin via SCE 2013 LCR RFO to replace SONGs capacity (D.15-11-041). 6.15 MW via distribution rates + 10.02 MW of SGIP/PLS (D.14-10-045, Attach A) + 37.5 MW of ACES storage projects (Resolution E-4798). 20 MW ACES Design Build Transfer project (Resolution E-4791) + Preferred Resources Pilot 2 - 60 MW (A.16-11-002) + 0.5 MW (A.14-11-016 - 2013 LCR RFO – Moorpark) + 20 MW ACES EGTs (A.17-03-020) A.17-04-017 June 2017 data, available at Supplemental Direct Access Implementation Activities Report – Statewide Summary – June 15, 2017. Direct Access (DA) ESPs are responsible for non-bypassable charges based on load share for CAM and distribution rates. This does not include PCIA for storage. ESPs comprise 13.0 percent of load share, based on the latest Direct Access Implementation Activities Report, published June 15, 2017, accessible at:
- Page 3 -

Advice 5119-E, et al. -4- 1% ESP procurement obligation (MW)16 August 1, 2017 17 20 6 Table 5: COMMUNITY CHOICE AGGREGATORS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of June 2017) SERVICE TERRITORY PG&E 17 Applicable CCA load (GWh) CCA MW share of non-bypassable charges19 1% CCA procurement obligation (GWh) 1% CCA procurement obligation (MW) 18 3,486 0.5 MW 35 6 MWs SCE 608 2 6 1 SDG&E 0 0 0 0 Table 6: COMPARISON OF UTILITY, DIRECT ACCESS, AND COMMUNITY CHOICE AGGREGATORS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of January 2017) SERVICE TERRITORY Storage obligation as % of total 2020 load forecast20 - Storage Target of 1325 MW Storage obligations as % total of 2020 load 21 forecast – Storage Target of 1825 MW ESP Current Share: 1% procurement obligation + non-bypassable charge (MW / % of load) CCA Current Share: 1% procurement obligation + non-bypassable charge (MW / % of load) PG&E 580 MW ~ 2.7% 746 MW ~ 3.5% 19 MW ~ 1.1 % 6.5 MW ~ 1.1 % SCE 580 MW ~2.6% 746 MW ~3.3% 72 MW ~3.6% 3 MW ~2.8% SDG&E 165 MW ~3.7% 331 MW ~7.4% 16 MW ~2.6% 0 The filing would not increase any current rate or charge, cause the withdrawal of service, or conflict with any rate schedule or rule. 16 17 18 19 20 21 Assumes 64 percent capacity factor (CF) for ESPs and CCAs. MW = 1000*GWh/(CF/8760) These totals only include existing CCAs for which data are available – Lancaster, Marin, and Sonoma. Planned CCAs are not included. When additional CCAs report load that load should be reflected in the updates to these tables. 2020 CCA load forecast data available at: Corrected LSE and BA Tables Mid Baseline – Mid AAEE. Currently active CCAs comprise 3 percent of forecasted 2020 load in PG&E territory; 0.5% of forecasted 2020 load in SCE territory. Percentages are derived from California Energy Demand Update Forecast, 2015-2027. California Energy Commission, accessible at: 2020 load assumptions: PG&E – 21,597 MWs – in 2020; SCE – 22,296 MWs – in 2020; SDG&E – 4,455 MWs – in 2020. Source: California Energy Commission Draft Staff Report. Docket 16-IEPR., December 5, 2016. Includes procurement under AB 2868.
- Page 4 -

Advice 5119-E, et al. -5- August 1, 2017 Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or E-mail, no later than August 21, 2017, which is 20 days after the date of this filing. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: For PG&E: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: For SCE: Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Facsimile: (626) 302-4829 E-mail: Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company
- Page 5 -

Advice 5119-E, et al. -6- August 1, 2017 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: For SDG&E: Megan Caulson Regulatory Tariff Manager 8330 Century Park Court, CP31F San Diego, CA 92123-1548 E-mail: Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date PG&E, SCE, and SDG&E request that this Tier 1 advice filing become effective upon date of filing, which is August 1, 2017. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service list for R.15-03-011. Address changes to the General Order 96-B service list should be directed to PG&E at email address For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter filings can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List R.15-03-011
- Page 6 -

CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No. Pacific Gas and Electric Company (ID U39 E) Utility type: Contact Person: Kingsley Cheng  ELC  GAS  PLC  HEAT Phone #: (415) 973-5265  WATER E-mail: and EXPLANATION OF UTILITY TYPE ELC = Electric PLC = Pipeline GAS = Gas HEAT = Heat (Date Filed/ Received Stamp by CPUC) WATER = Water Advice Letter (AL) #: 5119-E, et al. Tier: 1 Subject of AL: Update to Community Choice Aggregate and Energy Service Provider Load Data and Utility Investment and Procurement Information Keywords (choose from CPUC listing): Compliance, Procurement, Storage AL filing type:  Monthly  Quarterly  Annual  One-Time  Other _____________________________ If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D.17-04-039 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: ____________________ Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: No Confidential information will be made available to those who have executed a nondisclosure agreement: N/A Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential information: __________________________________________________________________________________________________ Resolution Required? Yes No Requested effective date: August 1, 2017 N No. of tariff sheets: N/A Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed: N/A Pending advice letters that revise the same tariff sheets: N/A Protests, dispositions, and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: California Public Utilities Commission Energy Division EDTariffUnit 505 Van Ness Ave., 4th Flr. San Francisco, CA 94102 E-mail: Pacific Gas and Electric Company Attn: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, CA 94177 E-mail:
- Page 7 -

PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Division of Ratepayer Advocates Albion Power Company Alcantar & Kahl LLP Anderson & Poole Atlas ReFuel BART Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand Ellison Schneider & Harris LLP Evaluation + Strategy for Social Innovation G. A. Krause & Assoc. GenOn Energy Inc. GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Barkovich & Yap, Inc. Bartle Wells Associates Braun Blaising McLaughlin & Smith, P.C. Braun Blaising McLaughlin, P.C. CENERGY POWER CPUC CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Casner, Steve Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Clean Power Research Coast Economic Consulting Commercial Energy Cool Earth Solar, Inc. County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Defense Energy Support Center Dept of General Services Kelly Group Ken Bohn Consulting Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenna Long & Aldridge LLP McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Nexant, Inc. ORA Office of Ratepayer Advocates Office of Ratepayer Advocates, Electricity Planning and Policy B OnGrid Solar Pacific Gas and Electric Company Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Energy (Socal Gas) Sempra Utilities SoCalGas Southern California Edison Company Southern California Gas Company (SoCalGas) Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners TerraVerde Renewable Partners, LLC Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) YEP Energy Yelp Energy
- Page 8 -