Details for: 3802-E (Part 1 of 1).pdf


Click on the image for full size preview

Document data

Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

May 10, 2018
ADVICE 3802-E
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
Electric Service Provider Financial Security Requirement
Reports for May 2018

SUBJECT:

In compliance with Decision (D.) 13-01-021, Southern California Edison Company
(SCE) hereby submits for filing the following reports to document the Electric Service
Provider (ESP) Financial Security Requirement. The reports are attached hereto as
Attachment A and Attachment B. The confidentiality declarations for Attachments A and
B are attached hereto as Attachment C.
PURPOSE
The purpose of this advice filing is to provide the California Public Utilities Commission
(Commission) with the updated ESP financial security amount as required by Ordering
Paragraph (OP) 6 of D.13-01-021.
BACKGROUND
In OP 10 of D.13-01-021, as corrected by D.13-04-001 and D.13-02-017, the
Commission adopted the methods (see Appendix 1 of D.13-01-021) for calculating ESP
financial security and re-entry fee amounts to cover incremental procurement cost
requirements for Direct Access (DA) customers who are involuntarily returned to SCE
service. The financial security and re-entry fee requirements are applicable to ESPs
who provide service to DA customers with demands of less than 20 kilowatts (kW) and
who are not affiliated with a larger customer who has demand of 20 kW or more.
Advice 2903-E was filed on May 24, 2013, to establish the ESP financial security
requirement. OP 6 of D.13-01-021 ordered the Investor Owned Utilities (IOUs) (i.e.
Pacific Gas and Electric Company, SCE, and San Diego Gas & Electric Company) to
update by the 10th of May and November of each year the applicable ESP financial
security amount via a Tier 2 Advice Letter.1
1

SCE submitted an extension request to the Commission’s Executive Director on November
8, 2017, requesting a brief extension to file this particular advice letter.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





- Page 1 -

ADVICE 3802-E (U 338-E) -2- May 10, 2018 Within Advice 2903-E, SCE performed the calculation specified in Appendix 1 of D.13-01-021. The results are provided in Confidential Attachment A (omitted from the public version of this advice filing). Per D.13-01-021, the required financial security amount for each ESP is the higher of the amounts set forth in Attachment A or the deposit required in D.99-05-034 for ESP registration pursuant to Public Utilities Code Section 394(b)(9). The Energy Division determines which amount is higher, and ensures the appropriate financial security amount is secured from each ESP. This advice filing will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule. CONFIDENTIALITY PROTECTION Attachments A and B to this advice letter contain confidential material that is subject to the protections adopted in D.16-08-024 and D.06-06-066. Attachments A and B are submitted confidentially with declarations from a subject matter expert with delegated authority from an officer pursuant to D.16-08-024 and D.06-06-066. These declarations are submitted as Attachment C to this advice letter. SCE is serving each ESP a set of its relevant confidential ESP data individually. Any confidential data relating to an ESP is removed in the public version of this advice letter. TIER DESIGNATION Pursuant to D.13-01-021, OP 6, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice filing will become effective on June 9, 2018, the 30th calendar day after the date filed. NOTICE 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 20 days after the date of this advice filing. Protests should be submitted to:
- Page 2 -

ADVICE 3802-E (U 338-E) -3- May 10, 2018 CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov 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: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: AdviceTariffManager@sce.com 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: Karyn.Gansecki@sce.com 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 shall be submitted expeditiously. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B and R.07-05-025 service lists. In addition, SCE is serving each ESP a set of its relevant confidential ESP data individually. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com 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 Process_Office@cpuc.ca.gov. 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 https://www.sce.com/wps/portal/home/regulatory/advice-letters.
- Page 3 -

ADVICE 3802-E (U 338-E) -4- May 10, 2018 For questions, please contact Amy Liu at (626) 302-4019 or by electronic mail at Amy.Liu@sce.com. Southern California Edison Company /s/ Russell G. Worden /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:al:jm Enclosures
- Page 4 -

CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company Utility type: Contact Person: Darrah Morgan  ELC  GAS  PLC  HEAT Phone #: (626) 302-2086  WATER E-mail: Darrah.Morgan@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com 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 3802-E Tier Designation: 2 Electric Service Provider Financial Security Requirement Reports for May 2018 Keywords (choose from CPUC listing): Compliance, Direct Access, Electric Service Providers AL filing type:  Monthly  Quarterly  Annual  One-Time  Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 13-01-021 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: Confidential treatment requested?  Yes  No If yes, specification of confidential information: See Attachment C 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: 6/9/18 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: Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: 1 Discuss in AL if more space is needed.
- Page 5 -

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 Attention: Tariff Unit 505 Van Ness Ave., San Francisco, CA 94102 EDTariffUnit@cpuc.ca.gov Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: AdviceTariffManager@sce.com 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: Karyn.Gansecki@sce.com
- Page 6 -

CONFIDENTIAL ATTACHMENT A ESP FINANCIAL SECURITY REPORTS
- Page 7 -

CONFIDENTIAL ATTACHMENT B ASSUMPTIONS OF ESP FINANCIAL SECURITY REPORTS
- Page 8 -

ATTACHMENT C CONFIDENTIALITY DECLARATIONS REGARDING ESP FINANCIAL SECURITY REPORTS
- Page 9 -

DECLARATION OF STEVEN VAN DEVENTER REGARDING THE CONFIDENTIALITY OF CERTAIN DATA I, Steven van Deventer, declare and state: 1. I am an Energy Market Specialist at Southern California Edison Company (SCE). As such, I had responsibility for preparing the confidential attachments of the ESP Financial Requirement report for May 2018. I make this declaration in accordance with Decisions (“D”) 06-06-066 and D.08-04-023, issued in Rulemaking 05-06-040. I have personal knowledge of the facts and representations herein and, if called upon to testify, could and would do so, except for those facts expressly stated to be based upon information and belief, and as to those matters, I believe them to be true. 2. I have reviewed SCE’s confidential attachments of the ESP Financial Requirement report for May 2018. Listed below are the data in the response for which SCE is seeking confidential protection and the categories of the Matrix of Allowed Confidential Treatment Investor Owned Utility (IOU) Data (“Matrix”) appended to D.0606-066 to which these data correspond. Data Electric Price Forecasts RA Adder, IOU Loss Factor Location Attachment A CONFIDENTIAL DA Security May 2018 – Price Adders Inputs, ESP1, ESP2, ESP3, ESP4, ESP5, ESP6, ESP7,ESP8, ESP9, ESP10, ESP11 Worksheets and in Attachment B CONFIDENTIAL ESP Assumptions May 2018 Fwd Prices, RA Adder and IOU Loss Factor worksheets Attachment A CONFIDENTIAL DA Security May 2018 – Price Adders Inputs, ESP1, ESP2, ESP3, ESP4, ESP5, Matrix Category Limitations on Confidentiality Specified in Matrix II.A.1 Vendor is Platts and do not have permission to release the information for 3 years V.H Front 3 years of forecast data confidential
- Page 10 -

ESP6, ESP7,ESP8, ESP9, ESP10, ESP11 Worksheets and in Attachment B CONFIDENTIAL ESP Assumptions May 2018 RA Adder and IOU Loss Factor worksheets 3. I am informed and believe that SCE is complying with the limitations on confidentiality in the table in paragraph 2 specified in the Matrix that pertain to the data listed in the table above. 4. I am informed and believe and thereon allege that the data in the table in paragraph 2 above cannot be aggregated, redacted, summarized, masked or otherwise protected in a manner that would allow partial disclosure of the data while still protecting confidential information. 5. I am informed and believe and thereon allege that the data in the tables in paragraph 2 above has never been made publicly available. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on April 24th, 2018 at Rosemead, California. _______________________ Steven van Deventer
- Page 11 -

DECLARATION OF STEVEN VAN DEVENTER REGARDING THE CONFIDENTIALITY OF CERTAIN DATA I, Steven van Deventer declare and state: 1.I am an Energy Market Specialist, at Southern California Edison Company (SCE). As such, Colin Cushnie, Vice President of Energy Procurement & Management, has delegated authority to me to make this declaration on SCE’s behalf. I have responsibility for preparing the confidential attachments of the ESP Financial Requirement report for May, 2018. 2. I am making this declaration in accordance with D.17-09-023 and D.16-08-024, which govern the submission of confidential documents to the California Public Utilities Commission (Commission). 3. I have personal knowledge of the facts and representations herein and, if called upon to testify, could and would do so, except for those facts expressly stated to be based upon information and belief, and as to those matters, I believe them to be true. 4. Listed below are the data for which SCE is seeking confidential protection and the basis for SCE’s confidentiality request. Location of Confidential Data Attachment A CONFIDENTIAL DA Security May 2018.xlsm Pages (if available) Summary, ESP Inputs, ESP1, ESP2, ESP3, ESP4, ESP5, ESP6, ESP7,ESP8, ESP9, ESP10, Description of Information that is Confidential Customer account and usage information Basis for SCE’s Confidentiality Claim Civil Code §§1798.85- 1798.89
- Page 12 -

Location of Confidential Data Attachment B CONFIDENTIAL ESP Assumptions May 2018.xlsx Pages (if available) ESP11, Worksheets ESP Accounts Data, ESP Load worksheets Description of Information that is Confidential Customer account and usage information Basis for SCE’s Confidentiality Claim Civil Code §§1798.85- 1798.89 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on April 24th, 2018 at Rosemead, California. _______________________ Steven van Deventer
- Page 13 -