Details for: PGE Reply to Protest of AL 5297-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

June 8, 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 Protest of Advice
Letter 5297-E Regarding Revisions to Sample Form Np. 79-1127,
“Agreement to Perform Tariff Schedule Related Work, Rule 20A
General Conditions”

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) hereby replies to a protest dated June 6,
2018 from the City of San Jose (San Jose) to Advice 5297-E regarding revisions to the
General Conditions Agreement for conversion of overhead facilities to underground
pursuant to Rule 20A
Pursuant to Resolution E-4919, issued May 10, 2018, PG&E filed Tier 1 Advice 5297-E
which added language describing the calculation of the one-time maintenance charge
associated with installation of non-standard subsurface equipment
On June 6, 2018, the City of San Jose (San Jose) filed a protest arguing that “[n]ot only
does the above-ground installation of special facilities undermine the purpose of the
Rule 20A, on its face, it appears to be unjust and unreasonable.” 1 San Jose further
argues that it is “unclear how the one-time maintenance cost is related to PG&E’s costs
of maintaining these facilities” and that “there appears to be no rationale for tying the
one-time maintenance costs for subsurface facilities in PG&E’s Rule 20A program to
Rule 2.” 2
As PG&E previously explained, the installation of subsurface electrical facilities is not a
standard installation, but a discretionary special facilities installation subject to PG&E’s

San Jose Protest at p.1.


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PG&E’s Reply to Protest of Advice Letter 5297-E -2- June 8, 2018 Electric Tariff Rule 2, which requires the applicant or requestor (in this case, San Jose) to pay for the installation and maintenance costs. 3 Resolution E-4919 approved PG&E’s proposed compromise of allowing cities and counties to use Rule 20A funds for the cost of installing subsurface equipment, which PG&E would otherwise install above ground. Resolution E-4919 further approved that cities and counties would be required to pay the costs of maintenance of subsurface equipment. Further, PG&E’s Electric Tariff Rule 2 has been approved by the Commission, which includes the cost of ownership charge. 4 Moreover, the authorized cost-of-ownership rate is also used in other parts of PG&E’s tariff, for example in the computation of distribution line extension allowances as described in Electric Tariff Rule 15, Part C.2. The use of the cost of ownership rate is appropriate for determining the one-time maintenance fee associated with the increased plant cost associated with non-standard subsurface equipment that a city or county may request for as part of a Rule 20A program. Accordingly, the protest of the City of San Jose should be rejected. PG&E respectfully requests that the Commission approve Advice 5297-E as filed. /S/ Erik Jacobson Director, Regulatory Relations cc: Kimberly Ide, City of San Jose, 3 4 In limited situations, PG&E will install subsurface equipment without special facility charges if installing pad-mounted equipment is physically impossible or not feasible. Advice 1114-E, submitted May 23, 1986, approved by letter July 3, 1986; Decision 86-12-014, December 3, 1986.
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