Details for: PG&E Reply to Protest of AL 3920-G_5206-E.pdf

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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

February 9, 2018

California Public Utilities Commission - Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102

Pacific Gas and Electric Company’s Reply to the Protests of Advice
3920-G/5206-E Green Tariff Shared Renewables Program Extension

Dear Energy Division Tariff Unit:
Pursuant to Rule 7.4.4 of the California Public Utilities Commission’s (Commission or
CPUC) General Order 96-B, Pacific Gas and Electric Company (PG&E) hereby submits
this reply to protests and responses from The Utility Reform Network (TURN); the Solar
Energy Industries Association (SEIA) and the Coaltion for Community Solar Access
(CCSA) collectively, the Joint Solar Interests; ForeFront Power, LLC; the CCA Parties;
the City and County of San Francisco (CCSF); Coalition of California Utility Employees;
and Office of Ratepayer Advocates (ORA) to Advice 3920-G/5206-E proposing to extend
PG&E’s Green Tariff Shared Renewables (GTSR) Program.
None of the protesting or responding parties opposes extension of PG&E’s GTSR
Program. Several parties, such as SEIA/CCSA, TURN, ForeFront Power, LLC, and ORA,
propose certain substantive modifications to PG&E’s extension request. PG&E
appreciates these recommendations and will be prepared to discuss them informally and
in more detail with interested parties at the February 21, 2018 GTSR Program Forum.1
The CCA Parties and CCSF raise various procedural and legal objections to PG&E’s
extension request. PG&E responds briefly to each below:


For example, PG&E notes that ForeFront Power LLC has requested clarification of the extension requests
in order to ensure that customers are allowed to receive service under the program for a period of up to
20 years from their original subscription date, and that developers should be able to replace load lost
due to attrition, up to the program cap. (ForeFront Power LLC Response, p. 2.) PG&E believes these
recommendations have merit and should be discussed in more detail at the Program Forum.


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PG&E’s Reply to Protest of Advice 3920-G/5206-E -2- February 9, 2018 1. The CCA Parties and CCSF argue that PG&E’s recommended modifications to its GTSR program may not be proposed by advice letter because they require modifications to the Commission’s prior GTSR decisions and therefore are proposing a “different structure or materially different capacity” than the original GTSR program.2 Contrary to the CCA Parties and CCSF, the original GTSR decision expressly authorizes advice filings that may require certain modifications to the original GTSR decisions, as long as the modifications do not propose a “different structure” or “materially different capacity.”3 PG&E’s GTSR extension request does not propose a “materially different capacity” but would only streamline and simplify the Enhanced Community Renewables (ECR) program process, fully consistent with the existing authorized GTSR structure.4 2. The CCA Parties and CCSF argue that PG&E’s proposal to communicate information on avoided greenhouse gas (GHG) emissions to customers would violate Decision (D.) 16-05-006’s prohibition on such customer communications and thus may not be considered in an advice letter pursuant to D.15-01-051’s advice letter extension process.5 Contrary to the CCA Parties and CCSF, PG&E’s obligation to publicly disclose GTSR avoided GHG emissions to its customers and the public on an ongoing basis is a mandatory requirement, not discretionary, pursuant to Public Utilities Code (PU Code) Section 2833(w). Also, contrary to the CCA Parties and CCSF, the calculation of GHG emissions intensity under Assembly Bill 1110 adopted in 2016 is irrelevant to PG&E’s GHG disclosure obligation under Public Utilities Code Section 2833(w). Additionally, PG&E appreciates TURN’s suggestion that PG&E should rely on the GHG accounting methodology adopted in the Integrated Resource Planning (IRP) proceeding. However, pursuant to PU Code Section 2833(v), PG&E’s GTSR program fully complies with the California Air Resources Board’s (CARB) Voluntary Renewable Electricity (VRE) Program, which provides clear direction to PG&E on how to calculate and disclose the GHG emissions avoided by its GTSR Program. The CARB Regulatory Guidance Document on the process for retirement of allowances from the VRE reserve account provides as follows: 7.4.2. Do I Need to Calculate the GHG Emissions from Voluntary Renewable Electricity Generation? No. CARB will perform this calculation. VRE program participants only need to report their qualified VRE generation pursuant to section 95841.1(b) of the Regulation. CARB staff will verify the eligibility and compute the number of allowances that will be retired. If applicants wish to calculate the avoided 2 3 4 5 CCA Parties Protest, pp. 3- 4; CCSF Protest, pp. 4- 5. D.15-05-051, Ordering Paragraph 13. ORA’s similar objection to using the advice letter process to consider non-material changes to the Commission’s prior GTSR decisions also should be rejected for the same reasons as the CCA Parties’ and CCFS’ procedural objections. PG&E will address ORA’s substantive recommendations on PG&E’s GTSR extension request informally and at the February 21, 2018 GTSR Program Forum. CCA Parties Protest, pp. 1, 3- 4; CCSF Protest, pp. 4- 5.
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PG&E’s Reply to Protest of Advice 3920-G/5206-E -3- February 9, 2018 emissions for their own reference, the equation to convert megawatt-hours of VRE generation to metric tons of GHG emissions is in section 95841.1(c) of the Regulation.6 Thus, CARB already has approved the methodology for publicly disclosing GHG emissions avoided by GTSR programs, and PG&E’s GTSR extension request fully complies with both PU Code Section 2833(w) and D.16-05-066.7 PG&E appreciates the interested parties’ comments in their protests and responses, and looks forward to responding further to those comments as well as to other questions and suggestions at the February 21, 2018, GTSR Program Forum. PG&E respectfully requests that the Commission approve Advice 3920-G/5206-E as filed. /S/ Erik Jacobson Director, Regulatory Relations cc: • • • • • • • 6 7 Alisha C. Pember, Adams Broadwell Joseph & Cardozo, Matthew Freedman, The Utility Reform Network, Jeanne B. Armstrong, Goodin, Macbride, Squeri &Day, LLP, John L. Clark, Goodin, Macbride, Squeri &Day, LLP, William K. Sanders, Deputy City Attorney, David Peffer, Braun Blaising Smith Wynne, P.C., Mike Campbell, Electricity Pricing and Customer Programs Branch, Office of Ratepayer Advocates, CARB Regulatory Guidance Document, Section 7.4.2.p. 3, accessed at PG&E notes that TURN’s protest supports PG&E’s proposal to provide accurate GHG emissions information to GTSR customers, but proposes a somewhat different methodology for GHG emissions, the GHG portfolio accounting methodology adopted in the Integrated Resources Plan (IRP) proceeding. PG&E believes the CARB-adopted VRE methodology is more accurate for determining the avoided GHG emissions from the GTSR program and will informally discuss with TURN why its alternative methodology is less accurate for determining the avoided GHG emissions from the GTSR program.
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