Details for: PGE AL 5228-E-A.pdf


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Erik Jacobson
Director
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

May 7, 2018

Advice 5228-E-A
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California
Subject:

Supplemental: Establish the Solar On Multifamily Affordable Housing
Program Balancing Account (SOMAHBA)

Purpose
Pacific Gas and Electric Company (PG&E) responds to California Public Utilities
Commission (CPUC or Commission) request for Supplemental Information for PG&E’s
Advice Letter 5228-E to establish the Solar On Multifamily Affordable Housing Program
Balancing Account (SOMAHBA).
Background
On February 12, 2018, PG&E submitted Advice Letter 5228-E to “Establish the Solar
On Multifamily Affordable Housing Program Balancing Account (SOMAHBA) as
directed by D.17-12-022, Decision Adopting Implementation Framework for Assembly
Bill 693 and Creating the Solar On Multifamily Affordable Housing Program.
This supplemental Advice Letter amends PG&E’s original request in response to the
request from Tory Francisco, CPUC Energy Division dated April 18, 2018.
Supplemental Information
1. Please provide a table outlining the 2016, 2017, and 2018 Greenhouse Gas
Revenue Balancing Account amounts available to the SOMAH Balancing Account.





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Advice 5228-E-A -2- May 7, 2018 Table 1 Year Account Balance of SOMAH BA Calculation Methodology Recorded GHG Revenue Proceeds 20161 $1,934,435 R.14-07-002 (page 4, 1.a.) R.14-07-002 (page 2, footnote 2) Forecast GHG Revenue Proceeds $257,924,620 Multiply by 5% $ 12,896,231 Multiply by 15% $ 1,934,435 R.14-07-002 (page 2, footnote 2) 20172 $4,843,456 20183 $43,700,000 Total $322,897,048 Multiply by 10% $ 32,289,704.78 Multiply by 15% $ 4,843,456 Cal.Pub. Util.Code 2870(c) ALJ Tsen’s Ruling on 10-20-2017 D.15-01-027 (page 27, Table 1) $100,000,000 Multiply by 43.7% 4 $43,700,000 R.14-07-002 (page 4, 2.a.) $50,477,891 2. Please provide a list of cost categories PG&E expects to track under the umbrella of “administrative costs” as authorized by D.17-12-022 Page 37, FOF 26, and OP 2. Please provide a brief narrative explaining these cost categories. Answer: Though the SOMAH program shares some goals and features with the existing MASH program, it is in fact a new program, and will require the development of new procedures and administrative structures within PG&E. Please see the following cost categories5: 1 2016 Allowance Revenue Approved for Clean Energy or Energy Efficiency Programs Application: 2017 ERRA Forecast (A.16-06-003, D.16-12-038). 2 2017 Allowance Revenue Approved for Clean Energy or Energy Efficiency Programs Application: 2017 ERRA Forecast (A.16-06-003, D.16-12-038). 3 2018 Allowance Revenue Approved for Clean Energy or Energy Efficiency Programs Application: 2018 ERRA Forecast (A.17-06-005, D.18-01-009). 4 PG&E’s allocation. 5 All cost categories are currently estimates as the Statement of Work for the Program Administrator of SOMAH has not been finalized and PG&E does not know the extent of work needed to integrate with the third-party administrator until that contract is finalized.
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Advice 5228-E-A -3- May 7, 2018 • SOMAH Incentive Invoice Processing – Invoices from SOMAH Program Administrator need to be validated and paid. For administrative costs, this requires a review of the quarterly administrative invoices and the transfer of funds. For incentives, this requires review of the incentive invoice and validation of the customer of record and interconnection information to ensure that the application matches the utility database • Creation of SOMAH Interconnection Application – Interconnection forms will need to be updated to reflect the new SOMAH program and tariff option along with new allocation forms to bring alignment with other utilities. • Interconnection Portal Update to Add SOMAH – The Interconnection Portal will need to be updated to provide the same customer experience that all interconnection applicants receive. There are database additions that will also be required. Testing will also be required. • Billing System SOMAH Integration – The billing system for Virtual Net Energy Metering will require updating previous code to allow for the differences in SOMAH versus existing VNEM billing mechanisms. Testing will also be required. • Ad-hoc Data Requests Pertaining to SOMAH – PG&E receives a plethora of data requests from the Energy Division regarding programs it does not administer. Responding to such data requests is time-intensive and often requires multiple employees in different departments being utilized. • Creation of SOMAH Tariff – PG&E was required to create a new VNEM tariff for the SOMAH program. This also involved hosting a SOMAH VNEM Workshop at the Energy Division’s request. 3. For each cost category identified above and using the Energy Division provided list of Low Income Housing Tax Credit properties (and their respective number of units) served by PG&E, please provide a table for both the to-date and projected administration costs under low, mid, and high program participation scenarios. Answer (All numbers are estimates and subject to change): Table 2 Administrative Cost Category SOMAH Incentive Invoice Processing To-Date Costs ($) $0
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Advice 5228-E-A -4- May 7, 2018 Creation of SOMAH Interconnection Application $0 Interconnection Portal Update to Add SOMAH $0 Billing System SOMAH Integration $0 Ad-hoc Data Requests Pertaining to SOMAH Creation of SOMAH Tariff Cost incurred but not tracked6 Cost incurred but not tracked6 Table 3 Projected Administration Costs ($) if 25% of eligible properties participate (Low) Projected Administration Costs ($) if 50% of eligible properties participate (Mid) Projected Administration Costs ($) if 75% of eligible properties participate (High) SOMAH Incentive Invoice Processing $64,119 $128,238 $192,357 Creation of SOMAH Interconnection Application $6,453 $6,453 $6,453 Interconnection Portal Update to Add SOMAH $50,000 $50,000 $50,000 Billing System SOMAH Integration $20,000 $20,000 $20,000 Unknown and highly variable Unknown and highly variable Unknown and highly variable Cost already incurred but not tracked6 Cost already incurred but not tracked6 Cost already incurred but not tracked6 Administrative Cost Category Ad-hoc Data Requests Pertaining to SOMAH Creation of SOMAH Tariff 6 As the Commission did not allocate any funding for the SOMAH program outside of the thirdparty administrator and the Energy Division, PG&E has not been tracking these costs.
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Advice 5228-E-A -5- May 7, 2018 4. Using the estimates above, please identify what percentage (and total) of SOMAH Program administrative costs identified in Table 3 will be paid for by interconnection request fees7 outlined in the recently submitted PG&E Advice Letter 5253-E – Establish New Electric Rate Schedule NEM2VSOM for the Solar on Multifamily Affordable Housing (SOMAH) Program Pursuant to Decision 17-12-022 and Assembly Bill 693. Answer: 0% ($0). Interconnection Application Fees do not go towards the creation of new processes or procedures as that is handled outside of the interconnection department and separate from the interconnection process. Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than May 29, 2018, which is 22 days8 after the date of this submittal. 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: EDTariffUnit@cpuc.ca.gov 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: 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 7 It is understood that interconnection fees differ based on project size. Please use historical MASH system size data, and the Energy Division provided list of Low Income Housing Tax Credit properties (and their respective number of units) served by PG&E to estimate the number of systems that will be installed by the SOMAH Program that will be greater than and less than 1MW. 8 The 20-day protest period concludes on a weekend and holiday; therefore, PG&E is moving this date to the following business day.
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Advice 5228-E-A -6- May 7, 2018 Facsimile: (415) 973-3582 E-mail: PGETariffs@pge.com 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 requests that this Tier 1 advice submittal become effective concurrent with original Advice 5228-E, which is February 12, 2018. 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 lists for R.14-07-002 and A.17-06-005. Address changes to the General Order 96-B service list should be directed to PG&E at email address PGETariffs@pge.com. For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter submittals can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service Lists R.14-07-002 and A.17-06-005
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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. Pacific Gas and Electric Company (ID U39 E) Utility type: Contact Person: Annie Ho  ELC  GAS  PLC  HEAT Phone #: (415) 973-8794  WATER E-mail: AMHP@pge.com and PGETariffs@pge.com EXPLANATION OF UTILITY TYPE ELC = Electric PLC = Pipeline GAS = Gas HEAT = Heat (Date Filed/ Received Stamp by CPUC) WATER = Water Advice Letter (AL) #: 5228-E-A Tier: 1 Subject of AL: Supplemental: Establish the Solar On Multifamily Affordable Housing Program Balancing Account (SOMAHBA) Keywords (choose from CPUC listing): Compliance, Balancing Account AL filing type:  Monthly  Quarterly  Annual  One-Time  Other _____________________________ If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: N/A 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: February 12, 2018 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 22 days1 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: EDTariffUnit@cpuc.ca.gov 1 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: PGETariffs@pge.com The 20-day protest period concludes on a weekend and holiday; therefore, PG&E is moving this date to the following business day.
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PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. Braun Blaising Smith Wynne P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Casner, Steve Cenergy Power Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand Ellison Schneider & Harris LLP Energy Management Service Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP 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 McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners 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
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