Details for: SDG&E AL 3219-E.pdf


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

May 7, 2018
ADVICE LETTER 3219-E
(U902-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
SUBJECT:

Revisions to the Clean Transportation Priority Balancing Account (CTPBA)
Pursuant to Decision 18-01-024

PURPOSE
SDG&E is submitting a revision to advice letter 3178-E previously filed on January 26, 2018 to
remove operating and maintenance (“O&M”) costs for years 2020-2022 for the Priority Review
Projects (“PRPs”). Although SDG&E intends to continue to maintain the equipment for the
PRPs after the one-year of data collection for the pilots is completed, the final decision does not
address additional O&M costs beyond year 2019. SDG&E inadvertently included the related
O&M costs for years 2020-2022 prematurely in the January 26, 2018 submission. Once the
pilot projects are complete, SDG&E will seek approval from the Commission to continue to
maintain the equipment for post 2019 and until its next General Rate Case.
The adjusted revenue requirement included in this advice letter removes any ongoing O&M
costs for the following Priority Review projects and years identified in the chart below as follows:
Priority Review Projects
Airport Ground Support
Equipment
Electrify Local Highways
Port Electrification
Fleet Delivery Services
Green Shuttle Priority Review
Project
Dealership Incentives
Total

Year
2020

Year
2021

Year
2022

Total

$68,287

$70,040

$71,760

$210,087

$53,327
$53,643
$52,672
$52,078

$54,661
$54,983
$53,993
$53,387

$55,972
$56,300
$55,290
$54,672

$163,960
$164,926
$161,955
$160,137

$0
$280,007

$0
$287,064

$0
$293,994

$0
$861,065

Below is a reconciliation of the revenue requirement that was filed in Advice Letter 3178-E on
January 26, 20181, identification of what changed, and the new adjusted revenue requirement
now requested in this advice letter. The reconciliation is as follows:

1

Approved by the Energy Division on February 26, 2018.





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Public Utilities Commission Priority Review Projects Total Rev Req January 26, 2018 FF&U O&M Total Adjustments Total Rev Req Adjusted April 19, 2018 2 2018 2019 May 7, 2018 2020 2021 ($1,286,797) $9,113,418 $4,231,996 $4,141,808 $0 $0 ($10,443) ($10,706) $0 $0 ($280,008) ($287,064) $0 $0 ($290,450) ($297,770) ($1,286,797) $9,113,418 $3,941,546 $3,844,038 2022 Total $4,007,020 $20,207,446 ($10,964) ($32,113) ($293,993) ($861,065) ($304,957) ($893,177) $3,702,063 $19,314,268 In accordance with Ordering Paragraph (OP) 31 of Decision (D.) 18-01-024, SDG&E submits this advice letter to establish Schedule CTPBA. The purpose of the CTPBA is to record revenues associated with the authorized revenue requirement and costs associated with SDG&E’s approved Priority Review Projects (PRPs)2. The under- or over-collection for these projects will be included in SDG&E’s annual electric regulatory account update Advice Letter to be amortized in rates effective January 1 of the following year. BACKGROUND On October 7, 2015, Senate Bill (SB) 350, the Clean Energy and Pollution Reduction Act (Chapter 547, Statutes of 2015) was signed into law, establishing new clean energy, clean air and greenhouse gas and reduction goals for California for 2030 and beyond. Among other things, SB 350 requires utilities to undertake transportation electrification (TE) activities. On March 30, 2016, the Commission issued an Amended Scoping Memo and Ruling (Amended Scoping Ruling) in Rulemaking (R.) 13-11-007 adding SB 350 TE issues to that Rulemaking. On September 14, 2016, an Assigned Commissioner’s Ruling (ACR) was issued in R.13-11-007 directing SDG&E, Pacific Gas and Electric Company (PG&E), and Southern California Edison Company (SCE), collectively referred to as the investor owned utilities (IOUs), to file their first round of TE applications by January 20, 2017. The ACR also set forth guidance that the applications should contain proposals for priority review projects and standard review projects. Priority review projects are non-controversial, short term (e.g. one year) investments, with budgets limited to no more than $4 million per project, with a total funding total of $20 million for each utility.3 On January 20, 2017, the IOUs, filed their applications4 for approval of proposed programs and investments to accelerate widespread TE. After the prehearing conference (PHC), a Scoping Ruling was issued on April 13, 2017. On January 11, 2018, the Commission adopted D.18-01-024, approving, with modifications, fifteen PRPs proposed by the IOUs. SDG&E’s Port Electrification Project was approved as proposed. SDG&E’s Airport Ground Support Equipment, Electrify Local Highways, Fleet Delivery Services, Green Shuttle, and Dealership Incentives Projects were approved with modifications. Per the decision, SDG&E is authorized to establish a new one-way balancing account to record the actual Operations and Maintenance expenses, payroll taxes, and capital revenue requirement (i.e., depreciation, return on rate base, property taxes, and income taxes) CTPBA will include actual operations and maintenance expenses, payroll taxes and capital revenue requirements such as depreciation, return on rate base, property taxes and income taxes. 3 ACR, Appendix A. 4 SDG&E Application in A.17-01-020 2
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Public Utilities Commission 3 May 7, 2018 associated with the approved Priority Review Projects. See revenue requirement summary in Attachment A. Costs incurred for each project up to the authorized funding level shall be considered per se reasonable subject only to the SDG&E’s prudent administration of the project. Costs above these authorized levels will be borne by its shareholders. Priority Review Project Airport Ground Support Equipment Electrify Local Highways Port Electrification Fleet Delivery Services Green Shuttle Priority Review Project Dealership Incentives Evaluation Total Capital $2,405,598 $3,309,212 $1,840,575 $3,231,963 $2,338,887 $13,126,235 Expense $434,140 $690,788 $565,000 $458,786 $818,918 $1,790,000 $715,355 $5,472,987 Total $2,839,738 $4,000,000 $2,405,575 $3,690,749 $3,157,805 $1,790,000 $715,355 $18,599,222 The following is a summary of SDG&E’s amended and approved priority review projects that align with SB 350’s TE goals: 1. Airport ground Support Equipment: SDG&E will implement a two-phase approach to this project. In Phase 1, SDG&E will upgrade any existing Electric Vehicle Supply Equipment (EVSE) at the San Diego International Airport that needs retrofitting, install load research meters on the existing electric ground support equipment and assess the existing fleet’s charging behavior and duty cycles. 2. Electrify Local Highways: SDG&E will install twenty Level 2 and two DC Fast Chargers at each of four Park-and-Ride locations. SDG&E will implement this project in conjunction with the California Department of Transportation to ensure the installation sites are in or adjacent to a Disadvantaged Community, and to produce data on the overall air quality and other environmental benefits occurring in the Park-and-Ride locations selected for this project. 3. Port Electrification: SDG&E will install load research meters within the San Diego Port District to collect consumption and charging data. This will to allow for an analysis of energy consumption relative to time and demand, operational and EV-specific charging patterns, and to help inform development of an optimized grid integration solution for medium- heavy duty and forklift electric vehicles that promotes EV adoption in these market segments. 4. Fleet Delivery Services: SDG&E will install, own, operate, and maintain the electric charging infrastructure for up to 90 new medium duty electric delivery vehicles. SDG&E will support 60 delivery vehicles by providing charging infrastructure at three UPS locations. SDG&E will partner with a locally-owned business(es) or a Minority-owned Business Enterprise/Woman-owned Business Enterprise(s) in selecting any additional fleets for charging infrastructure in this project. SDG&E will discuss its selection criteria and its choice of any additional fleet partner(s) with its Program Advisory Council. SDG&E will work with participating customers to determine the most appropriate available electric rate at the time of implementation.
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Public Utilities Commission 4 May 7, 2018 5. Green Shuttle: SDG&E will deploy this project to focus solely on shuttle services serving fixed routes and may cover the cost of installing charging platforms that include Level 2 charging infrastructure and up to one DC Fast Charger for use by shuttle companies, and any partners the site host approves, that agree to participate in this pilot. SDG&E will work with program participants to design charging stations that best meet the shuttle companies’ charging needs and ensure sufficiently high utilization rates. SDG&E may install a solar array and energy storage at one project facility to test the use of stored renewable energy to reduce a facility’s demand during critical peak hours. To facilitate data collection, SDG&E may offer its proposed Public Grid Integrated Rate (GIR) at the charging stations SDG&E owns and operates for this project. SDG&E will not use any of the funds approved for this project for vehicle incentives. 6. Dealership Incentives: SDG&E will offer $250 incentives to dealerships and salespeople if the electric vehicle buyer or lessee enrolls in one of SDG&E’s electric vehicle time-of-use rates (EV-TOU or EV-TOU-2) or any new residential electric vehicle rate that is available at the time of purchase/lease. SDG&E will provide dealers with information on safe EVSE installation with incentive information. EFFECTIVE DATE This filing is subject to Energy Division disposition and is classified as Tier 2 (effective after staff approval) pursuant to GO 96-B and D.18-01-024. SDG&E respectfully requests that this filing become effective on June 6, 2018, 30 days from the date of this filing as required by Ordering Paragraph 31 of D.18-01-024. PROTEST Anyone may protest this Advice Letter to the California Public Utilities 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 May 27, 2018, which is 20 days from 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 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
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Public Utilities Commission 5 May 7, 2018 NOTICE A copy of this filing has been served on the utilities and interested parties shown on the attached list and to interested parties in service list A.17-01-020, 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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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. SAN DIEGO GAS & ELECTRIC (U 902) Utility type: Contact Person: Aurora Carrillo ELC GAS Phone #: (858) 654-1542 PLC HEAT WATER E-mail: acarrillo@semprautilities.com EXPLANATION OF UTILITY TYPE ELC = Electric PLC = Pipeline GAS = Gas HEAT = Heat (Date Filed/ Received Stamp by CPUC) WATER = Water Advice Letter (AL) 3219-E Subject of AL: Revisions to the Clean Transportation Priority Balancing Account Pursuant to Decision 18-01-024 Key words (choose from CPUC listing): AL filing type: Monthly Quarterly SB 350, Balancing Account Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D.18-01-024 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 AL1: N/A Does AL request confidential treatment? If so, provide explanation: Resolution Required? Yes No Tier Designation: Requested effective date: June 6, 2018 Estimated system annual revenue effect: (%): Estimated system average rate effect (%): 1 No. of tariff sheets: 2 3 N/A N/A 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 proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A Protests 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: CPUC, Energy Division San Diego Gas & Electric Attention: Tariff Unit Attention: Megan Caulson 505 Van Ness Ave., 8330 Century Park Ct, Room 32C San Francisco, CA 94102 San Diego, CA 92123 mas@cpuc.ca.gov and EDTariffUnit@cpuc.ca.gov mcaulson@semprautilities.com 1 Discuss in AL if more space is needed.
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cc: (w/enclosures) Public Utilities Commission DRA S. Cauchois R. Pocta W. Scott Energy Division P. Clanon S. Gallagher D. Lafrenz Tariff Unit CA. Energy Commission F. DeLeon R. Tavares Alcantar & Kahl LLP K. Cameron American Energy Institute C. King APS Energy Services J. Schenk BP Energy Company J. Zaiontz Barkovich & Yap, Inc. B. Barkovich Bartle Wells Associates R. Schmidt Braun & Blaising, P.C. S. Blaising California Energy Markets S. O’Donnell C. Sweet California Farm Bureau Federation K. Mills California Wind Energy N. Rader Children’s Hospital & Health Center T. Jacoby City of Poway R. Willcox City of San Diego L.Cosio Azar D. Weil Commerce Energy Group V. Gan CP Kelco A. Friedl Davis Wright Tremaine, LLP E. O’Neill J. Pau Dept. of General Services H. Nanjo M. Clark General Order No. 96-B ADVICE LETTER FILING MAILING LIST Douglass & Liddell D. Douglass D. Liddell G. Klatt Duke Energy North America M. Gillette Dynegy, Inc. J. Paul Ellison Schneider & Harris LLP E. Janssen Energy Policy Initiatives Center (USD) S. Anders Energy Price Solutions A. Scott Energy Strategies, Inc. K. Campbell M. Scanlan Goodin, MacBride, Squeri, Ritchie & Day B. Cragg J. Heather Patrick J. Squeri Goodrich Aerostructures Group M. Harrington Hanna and Morton LLP N. Pedersen Itsa-North America L. Belew J.B.S. Energy J. Nahigian Luce, Forward, Hamilton & Scripps LLP J. Leslie Manatt, Phelps & Phillips LLP D. Huard R. Keen Matthew V. Brady & Associates M. Brady Modesto Irrigation District C. Mayer Morrison & Foerster LLP P. Hanschen MRW & Associates D. Richardson Pacific Gas & Electric Co. J. Clark M. Huffman S. Lawrie E. Lucha Pacific Utility Audit, Inc. E. Kelly San Diego Regional Energy Office S. Freedman J. Porter School Project for Utility Rate Reduction M. Rochman Shute, Mihaly & Weinberger LLP O. Armi Solar Turbines F. Chiang Sutherland Asbill & Brennan LLP K. McCrea Southern California Edison Co. M. Alexander K. Cini K. Gansecki H. Romero TransCanada R. Hunter D. White TURN M. Hawiger UCAN D. Kelly U.S. Dept. of the Navy K. Davoodi N. Furuta L. DeLacruz Utility Specialists, Southwest, Inc. D. Koser Western Manufactured Housing Communities Association S. Dey White & Case LLP L. Cottle Interested Parties in: A.17-01-020
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New Adjusted Revenue Requirement to Eliminate O&M for Years 2020-2022 Previous Revenue Requirement submitted in Advice Letter Reduction in Revenue Requirement as a result of removing O&M costs for Years 2020-2022
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