Details for: SDG&E AL 3201-E.pdf


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Clay Faber - Director
Federal & CA Regulatory
8330 Century Park Court
San Diego, CA 92123
cfaber@semprautilities.com

March 12, 2018
ADVICE LETTER 3201-E
(U902-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
SUBJECT:

MODIFICATIONS TO NET ENERGY METERING (NEM) TARIFFS TO
INCORPORATE A BILL CREDIT ESTIMATION METHODOLOGY PURSUANT
TO DECISION 18-02-008

San Diego Gas & Electric Company (SDG&E) hereby submits this filing for approval to the
California Public Utilities Commission (Commission) modifications to its electric tariffs as shown
in Attachment A.
PURPOSE
This filing is pursuant to Decision (D.) 18-02-008 – Decision Granting the Petition for
Modification of Decision 16-04-020 regarding the Net Energy Metering Bill Credit Estimation
Methodology for Generating Facilities Paired with Small Storage Devices – adopted by the
Commission (and effective) on February 8, 2018. Ordering Paragraph (OP) 2 in this decision
directs SDG&E to file a Tier 1 advice letter within 45 days of the effective date of this decision to
modify its NEM tariffs in compliance with this decision. SDG&E hereby submits revisions to its
Net Energy Metering Rate Schedules NEM and NEM-ST, its NEM Successor Tariff, to reflect
changes to this billing methodology.
BACKGROUND
In Decision (D.) 16-04-020, the Commission established a bill credit estimation methodology for
NEM-eligible generating facilities paired with small storage devices (10kW or less). The adopted
methodology requires a customer-specific estimation for each calendar month, using the
customer’s specific information and the California Solar Initiative Expected Performance-Based
Buy down (CSI EPBB) calculator.
On August 28, 2017, Pacific Gas & Electric (PG&E) filed and served a petition for modification
of D.16-04-020, to modify the bill credit estimation methodology (Petition) on behalf of Southern
California Edison (SCE) and SDG&E. The Petition requests the Commission modify D.16-04020 to allow electric investor owned utilities (IOUs) to estimate bill credits for NEM-eligible
facilities that are paired with small storage devices (10kW or less) to use a single per-kilowatt
(kw) profile for each climate zone in place of the customer-specific estimation using the EPBB
calculator as adopted in D.16-04-020.
D.18-02-008 approved the IOUs PFM, with some exceptions, and directed the IOUs to use a
single per kW scalable profile for each climate zone.





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Public Utilities Commission 2 March 12, 2018 PROPOSED TARIFF CHANGES SDG&E proposes to make the following changes to mostly the same Special Condition No. 11, subsection d) found under Rate schedules NEM and NEM-ST. This subsection describes the billing estimation for NEM-Paired Storage: d) Billing for NEM Paired Storage i) Estimation Methodology for Small NEM Paired Storage Small NEM Paired Storage billing uses an estimation methodology that caps NEM bill credits based on monthly solar renewable electrical generating facility production estimates. The approach used to develop the production estimates and apply them to Small NEM Paired Storage billing is described below: (A) SDG&E has established a cap for NEM eligible exports by climate zone for each calendar month based on standardized monthly estimates that are scaled for a given Small NEM Paired Storage customer based on the kW capacity rating of the customer’s solar renewable electrical generating facility. To develop the production estimates, SDG&E used the California Solar Initiative Expected Performance-Based Buydown (CSI EPBB) calculator to produce a single, scalable, production factor table. This table captures the estimated amount of kWh generated per installed kW of PV capacity (kWh/kW production factor) for each calendar month and each of the four climate zones in SDG&E’s service area. For a given Small NEM Paired Storage customer, the cap on NEM-eligible exports is calculated by multiplying the customer-specific production factor for a given month and climate zone and scaling the kWh by the customer’s installed PV capacity (in kW). The PV system configuration assumptions used in the EPBB calculator to prepare the scalable production factor table are as follows: Tilt: Optimal Tilt as defined by the EPBB Calculator Azimuth: 180 degrees For each climate zone, identified the three zip codes with the most residential PV installations; chose the zip code with the highest production estimate using the EPBB calculator Panel: SunPower.SPR-327NE-WHT-D Inverter: SPR-E20-327-C-AC (240V) Mounting Method: > 6 average standoff (EPBB default) Shade: Minimal (EPBB default) The scalable production factor table mentioned above will be finalized and publicly noticed prior to August 7, 2018 (180 days from the issuance of D.18-02-008), the implementation date by which the IOUs are allowed to update their billing and information technology systems to implement the revised estimation methodology adopted in D.18-02-008 (Appendix A, page 3).
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Public Utilities Commission 3 March 12, 2018 EFFECTIVE DATE SDG&E believes this filing is subject to Energy Division disposition and should be classified as Tier 2 pursuant to GO 96-B. SDG&E respectfully requests that this filing be approved on or before April 2, 2018, which is thirty-one days from the date of this filing. PROTEST Anyone may protest this Advice Letter to the Commission. The protest must state the grounds upon which it is based, including such items as financial and service impact, and should be submitted expeditiously. The protest must be made in writing and must be received no later than March 22, 2018, which is 20 days after the date this Advice Letter was filed with the Commission. There is no restriction on who may file a protest. The address for mailing or delivering a protest to the Commission is: CPUC Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Copies of the protest should also be sent via e-mail to the attention of the Energy Division at EDTariffUnit@cpuc.ca.gov. A copy of the protest should also be sent via e-mail to the address shown below on the same date it is mailed or delivered to the Commission. Attn: Megan Caulson Regulatory Tariff Manager E-mail: MCaulson@semprautilities.com NOTICE A copy of this filing has been served on the utilities and interested parties shown on the attached list, including interested parties in R.14-07-002, by providing them a copy hereof either electronically or via the U.S. mail, properly stamped and addressed. Address changes should be SDG&ETariffs@semprautilities.com. directed to SDG&E Tariffs by email _______________________________ CLAY FABER Director – Federal & CA Regulatory to
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