Details for: 3704-E-A (Part 1 of 1).pdf

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Russell G. Worden
Managing Director, State Regulatory Operations

February 6, 2018
(U 338-E)
Supplement to Advice 3704-E, Proposal and Funding Request
for Development of Click-Through and Performance Metrics
Website, Pursuant to Resolution E-4868


Southern California Edison Company (SCE) hereby submits this supplemental Advice
Letter (AL) seeking approval for its funding request and proposal to implement a
performance metrics website and to construct the Click-Through system (ClickThrough). This advice filing supplements AL 3704-E in its entirety.
In Decision (D.)12-11-025 the California Public Utilities Commission (Commission)
ordered the implementation of Electric Rule 24 (Rule 24) for Pacific Gas and Electric
Company (PG&E) and SCE and Electric Rule 32 for San Diego Gas & Electric
Company (SDG&E) (collectively, the Utilities).1 Rule 24 allows third-party Demand
Response Providers (DRPs) access to retail customers’ data to register and use those
customers’ loads in the California Independent System Operator (CAISO) market for
demand response (DR), after obtaining the customer’s authorization. D.12-11-025
ordered the Utilities to work with stakeholders to finalize the Commission staff’s
proposed Rule 24 and to create related documents to support this Rule. The related
documents included a Customer Information Service Request form for DRPs (CISRDRP), the Service Agreement between the DRP and the utility, the Registration Form


Henceforth, any reference made to the Rule 24 that refers to the three Utilities applies to
Electric Rule 24 for PG&E and SCE, and Electric Rule 32 for SDG&E.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-4177

Fax (626) 302-6396


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ADVICE 3704-E-A (U 338-E) -2- February 6, 2018 for DRPs to register with the Commission, and a standard residential and small commercial customer notification letter for the purposes of Rule 24. On October 10, 2013, PG&E filed a Tier 3 Advice Letter (AL) 4298-E, on behalf of the Utilities, with the revised Rule 24 tariff and related documents. The Commission approved AL 4298-E on March 19, 2014 by Resolution E-4630 with modifications consistent with D.13-12-029, which addressed four Petitions for Modification (PFM) of D.12-11-025. This Resolution ordered the Utilities to file modifications in a Tier 1 AL, which PG&E filed on behalf of the Utilities on February 18, 2014 in AL 4361-E, and subsequently on April 2, 2014, under AL 4361-E-A. The Commission approved both AL 4361-E and 4361-E-A on April 8, 2014. Parties identified the Utilities’ processes for electronic submission of a CISR-DRP as cumbersome for customers, and in D.16-06-008 the Commission found that “direct participation is an evolving process that can be improved” and ordered the Utilities to develop a “click-through” electronic signature process that starts and ends on a thirdparty DRP’s website and provides customer authentication and authorization for the utility to release the customer’s data to a third party DRP.2 It also ordered the Utilities to meet with stakeholders to discuss how to simplify the direct participation enrollment process and to file a consensus proposal in a Tier 3 AL, by November 1, 2016. The Utilities and Energy Division hosted the first publicly noticed working group meeting with stakeholders and interested parties on Streamlining and Simplification of Direct Participation Enrollment Process on July 25, 2016. Subsequent publicly noticed meetings were held on August 24, September 13, September 29, October 5, October 18, and November 3. There were also two other in-person meetings during 2016 – on November 16 and December 1. These in-person meetings were supplemented by conference calls on August 4, September 6, September 28, September 30, October 26, November 10, and November 22, 2016. The working group included the Utilities, the Commission’s Energy Division, the Office of Ratepayer Advocates, Advanced MicroGrid, the California Energy Efficiency Industry Council, Chai Energy, CPower, eMotorWerks, EnergyHub, EnerNOC, Mission:Data, NRG, OhmConnect, Olivine, SolarCity, Stem, Sunrun, UtilityAPI, WeatherBug, and individuals interested in the working group discussions but who may not be parties. The Assigned Commissioner’s office also attended several of the meetings noticed in the Commission Daily Calendar. The Utilities filed their Click-Through ALs on January 3, 2017 in accordance with an extension granted by the Commission’s Executive Director on November 1, 2016. On August 25, 2017, Resolution E-4868 (the Resolution) was issued approving AL 3541-E with modifications. The Resolution grants SCE its proposed budget of $1.5 million to construct Click-Through, and up to an additional $3.2 million that SCE may request for additional improvements in direct participation demand response implementation 2 D.16-06-008, Ordering Paragraph (OP) 1, p. 33.
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ADVICE 3704-E-A (U 338-E) -3- February 6, 2018 including development of Click-Through, activities to help increase enrollments in thirdparty demand response programs, and costs for increasing customer registrations in the CAISO wholesale market.3 Among other requirements, the Resolution requires the Utilities to submit a Tier 2 AL (Tier 3 if funding is requested) within 90 days of the approval of the Resolution containing its proposal for building a performance metrics website to be implemented with Click-Through Phase 3.4 On November 22, 2017 SCE filed AL 3704-E to propose performance metrics for Click-Through and to request additional funding to construct Click-Through pursuant to the Resolution. SCE included in AL 3704-E tables detailing the amount of funding requested to construct Click-Through by expense category.5 Subsequently, staff of the Commission’s Energy Division requested that SCE file a supplemental advice filing focusing only on SCE’s request for additional Click-Through funding and providing more detailed descriptions of the budget categories presented in AL 3704-E, which SCE provides herein. SCE will file a separate advice filing for the performance metrics portion of AL 3704-E at a later date, in response to guidance from the Commission’s Energy Division. DISCUSSION Click-Through Funding Request With the changes to SCE’s Click-Through proposal resulting from the Resolution, SCE has identified a budget of approximately $3.6 million for Click-Through Phase 1. The categories in the table below are to conduct analysis, planning, and development work for the Click-Through Phase 1 features established in the Resolution. As SCE has worked on development of Click-Through Phase 1 for a longer time than on the metrics reporting, SCE has more confidence in its cost estimate and therefore uses a lower contingency of 20 percent. If actual costs are lower than this budget, SCE will use the remaining funds for development of Click-Through Phases 2 and 3 or future Click-Through and Rule 24 enhancements. Table 2 provides a breakdown of expected Click-Through Phase 1 costs. 3 4 5 Resolution, Finding of Fact (FOF) 95, p. 97. Resolution at OP 28, p. 105; Table 3, p. 83; Table 1, p. 75. AL 3704-E, Table 1 at pp. 4-5; Table 2 at pp. 5-6.
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ADVICE 3704-E-A (U 338-E) -4- February 6, 2018 Table 1: Updated SCE Costs for Development of Click-Through Phase 1 Project Management & Support $ 494,502 Analysis & Design $ 158,463 Development, Testing & Implementation Cybersecurity Audit & Support Infrastructure Support Project Delivery Support Sub-Total: UX Design Business Training Sub-Total: IT Capital Capital Total IT Software Misc Expenses O&M Sub-Total: Business OCM Sub-Total: O&M Total Sub-Total (Capital + O&M): Contingency Grand Total (Capital + O&M + Contingency) 20% $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ 1,820,700 46,111 33,145 78,897 2,631,817 206,775 20,988 227,763 2,859,580 57,449 2,500 59,949 59,539 59,539 119,488 2,979,068 595,814 $ 3,574,881
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ADVICE 3704-E-A (U 338-E) Budget Category Project Management & Support Analysis & Design Development, Testing & Implementation Cybersecurity Audit & Support Infrastructure Support Project Delivery support UX Design Training Software Misc Expenses OCM -5- February 6, 2018 Description of Table 1 Budget Categories Description General project management for the overall implementation of the project. Includes time from dedicated project managers and systems analysts that support the creation of project deliverables and execution of the project. Analysis - The effort spent in collecting, refining, and baselining the business requirements, and assessing the technical needs of the project. Design - Technical design of the application, including the customer-facing features as well as interfaces and back-office system changes. Development - The coding effort to build the requisite application and interfaces. Testing - The effort spent in performing functional testing of the new application features and interfaces. Also includes a performance test to ensure that the application is stable and performs well under load, and integration tests with third-party vendors to ensure proper hand-off of data via interfaces. Implementation - The effort spent to plan and execute deployment of the application and interfaces to customers on SCE's Production system, a.k.a. "GoLive". Includes post-implementation monitoring. Execution of a cybersecurity review of all aspects of the applications and interfaces to ensure that data is secured and safely exchanged in an acceptable manner that meets SCE's cybersecurity standards. Includes the labor spent from Cybersecurity specialists and vendors to support the project. Effort spent to install and/or configure hardware components required for the project on the Production environment. Performed by a separate Server/Hardware team in IT Operations. Support from the IT Operations teams who are not dedicated to the project team. These resources coordinate and perform application configuration and/or setup, application installation, systems administration, firewall configurations and other operations-related services on the Production environment. User Experience (UX) Design. Effort to design wireframes, layouts, visual designs, prototypes and content/copy for the customer-facing interface and interactions for the Click-Through application. Effort to develop training materials for the purpose of preparing SCE customer service staff to take calls on the new features and capabilities of the Click-Through application. Purchase of software and tools required to develop and/or build the ClickThrough application. Miscellaneous project expenses such as workshop supplies and materials and general administration. Organizational Change Management. Services provided by SCE's Human Resources organization (utilizing consultant services) to assess, drive and manage organization impacts and process changes in key operational areas (i.e. customer support teams including call center) in preparation for the roll-out of the ClickThrough application.
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ADVICE 3704-E-A (U 338-E) -6- February 6, 2018 As the expected budget of $3.575 million is more than the $1.5 million allocated to SCE for Click-Through in the Resolution, SCE hereby requests to use funding from the $3.2 million cap approved in D.17-06-005 and the Resolution.6 To offset the amount of money under the cap required for Click-Through Phase 1 and to conserve money for Click-Through Phases 2 and 3, SCE also requests to repurpose $1.254 million of unspent funds that were previously authorized for Rule 24 purposes. This funding was authorized in D.14-05-025 and repurposed for Rule 24 purposes in D.16-06-008.7 The funding was expected to be used primarily for labor to manually process CISR-DRP forms. As the number of registrations that SCE expected has not materialized and the majority of customer authorizations have occurred through SCE’s Green Button Connect (GBC) rather than through the paper CISR-DRP form, SCE has not needed to spend these funds.8 Therefore, SCE requests permission to use these funds for development of Phase 1 of Click-Through. If granted, SCE expects the remaining funds will be sufficient to complete Phases 2 and 3 of Click-Through. If not granted, SCE may not have enough funds to complete Phases 2 and 3 of Click-Through without filing an application for additional funds, which would delay implementation until the Commission issues a decision. Table 3 clarifies SCE’s funding request. Funding Source Res E-4868 D. 17-06-005; Res E-4868 Table 2: Summary of SCE's Proposed Click-Through Funding $000 Purpose Click-Through development Additional improvements in direct participation DR implementation including click-through, activities to help increase enrollments in thirdparty DR programs, and costs for increasing customer registrations in the CAISO wholesale market (A) Available Authorized Funding Subtotal Click-Through Phase 1 development Performance Metrics reporting9 (B) Click-Through Phase 1 & Performance Metrics Budget Subtotal (C) Remaining Authorized Funding (A-B) D.14-05-025; D.16-06-008 (E) 6 7 8 9 (D) Proposed Fund Transfer from Rule 24 Program (B+C) Remaining Authorized Funding With Transfer of Rule 24 Funds (C+D) Amount $1,500 $3,200 $4,700 $3,575 $817 $4,392 $308 $1,254 $1,562 D.17-6-005, OP 4, p. 20; Resolution, OP 28, p. 105. D.14-05-025, OP 17, p. 53; D.16-06-008, OP 7, p. 34. As of January 31, 2018 SCE had approximately 23,000 active Rule 24 registrations. SCE had expected to support up to 42,000 registrations in the Intermediate Implementation Step of Rule 24 Direct Participation. SCE has received more than 90% of Rule 24 registrations through GBC. SCE will file this budget request with its upcoming advice letter on Click-Through performance metrics, but includes it here to provide a more complete picture of overall Click-Through costs.
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ADVICE 3704-E-A (U 338-E) -7- February 6, 2018 TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.3, and Resolution E-4868, this advice letter is submitted with a Tier 3 designation, which is the same Tier designation as the original filing, Advice 3704-E. EFFECTIVE DATES This advice filing will become effective upon Commission resolution. NOTICE This supplemental filing has a shortened protest period of seven (7) days. Anyone wishing to protest this advice filing may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 7 days after the date of this advice filing. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-4177 Facsimile: (626) 302-6396 E-mail:
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ADVICE 3704-E-A (U 338-E) -8- February 6, 2018 Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice filing to the interested parties on the attached GO 96-B, A.14-06-001 et al and R.13-09-011 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-4039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by filing and keeping the advice filing at SCE’s corporate headquarters. To view other SCE advice letters filed with the Commission, log on to SCE’s web site at For questions, please contact Nathanael Gonzalez at (626) 302-5150 or by electronic mail at Southern California Edison Company s/ Russell G. Worden Russell G. Worden RGW:al:jm Enclosures
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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.: Southern California Edison Company (U 338-E) Utility type: Contact Person: Darrah Morgan  ELC  GAS  PLC  HEAT Phone #: (626) 302-2086  WATER E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE ELC = Electric PLC = Pipeline GAS = Gas HEAT = Heat Advice Letter (AL) #: Subject of AL: (Date Filed/ Received Stamp by CPUC) WATER = Water 3704-E-A Tier Designation: 3 Supplement to Advice 3704-E, Proposal and Funding Request for Development of ClickThrough and Performance Metrics Website, Pursuant to Resolution E-4868 Keywords (choose from CPUC listing): Compliance AL filing type:  Monthly  Quarterly  Annual  One-Time  Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: Resolution E-4868 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested?  Yes  No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information: Resolution Required?  Yes No Requested effective date: Upon Commission Approval No. of tariff sheets: -0- Estimated system annual revenue effect: (%): Estimated system average rate effect (%): 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 proposed1: Pending advice letters that revise the same tariff sheets: 1 Discuss in AL if more space is needed. None
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Protests and all other correspondence regarding this AL are due no later 7 days after the date of this filing, February 15, 2018, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-4177 Facsimile: (626) 302-6396 E-mail: Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail:
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