Details for: 3861-E (Part 1 of 1).pdf

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Clay Faber - Director
CA & Federal Regulatory
8330 Century Park Court, CP32F
San Diego, CA 92123-1548

September 4, 2018
(San Diego Gas & Electric Company - U902 M)
(Southern California Gas Company - U904 G)
(Southern California Edison Company - U338 E)
(Pacific Gas & Electric Company – U39 M)


San Diego Gas & Electric Company (SDG&E), Southern California Gas Company (SoCalGas),
Southern California Edison Company (SCE) and Pacific Gas and Electric Company (PG&E),
(hereinafter “IOUs”) hereby submit this Advice Letter (AL) to propose a mechanism for shared
funding of statewide programs pursuant to Ordering Paragraph (OP) 24 of Decision (D.) 18-05041.
D. 16-08-019 required the IOUs to submit business plan proposals for the 2018-2025 period by
January 15, 2017, including proposing a single lead administrator for each of the designated
statewide programs1 and at least four separate downstream programs.2
On May 31, 2018, the Commission approved D.18-05-041, the Decision Addressing Energy
Efficiency (EE) Business Plans, wherein OP 24 requires the IOUs to submit a Tier 1 AL to
propose a mechanism for shared funding of statewide programs. This AL puts forth the
statewide shared funding mechanism for managing the funding for EE Statewide programs.


D.16-08-019, Decision Providing Guidance for Initial Energy Efficiency Rolling Portfolio Business Plan
Filings, p. 61.
Id., p. 65.


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Public Utilities Commission 2 September 4, 2018 On September 4, 2018, SDG&E, SoCalGas, SCE, and PG&E each submitted separate Tier 2 ALs requesting authorization to establish individual new interest-bearing gas and electric EE balancing accounts to track and manage the cost sharing among the statewide program lead administrators and the contributing program administrators (PAs).3 PROPOSAL Currently, the IOUs utilize co-funding agreements for collaborative program efforts. The existing IOU co-funding agreements provide for partnering utilities to be billed by the lead utility, following initiation of program activities, to facilitate reimbursement for program expenditures. The IOUs propose to modify the co-funding agreement process as follows: • Each IOU will provide a ratable monthly payment of the annual approved statewide budget to the lead IOU for each statewide program by the fifteenth (15th) of each month, beginning the 15th of the first month after subject contracts are signed, and the program implementation plan is uploaded to CEDARS. • Subsequent payments to the statewide lead IOU will be provided by the 15th of each month following provision of the initial payment. • If the program is successful and requires additional funding beyond the approved budget, the lead IOU will, in consultation with the funding IOUs, work to identify and allocate additional program funds. The master co-funding agreement will be updated by the program lead to reflect the new budget and monthly payment. • The proposed new interest-bearing balancing accounts will track (1) IOUs’ contributions to all the approved and contracted statewide programs for which the IOU is the lead PA; (2) all the funds transferred from other IOUs for programs that each IOU will be administering on behalf of all the IOUs; and (3) actual costs of the programs administered by the lead IOU. • The annual true-up, which will include accrued interest, will be handled through an agreed-upon annual report that provides each IOU with the status of their payments, expenses and related interest for the programs administered by each lead IOU. The proposed annual report template is provided as Attachment A. • The annual true-up reports will be submitted together with the annual EE reports by May 1 of the following calendar year. PROPORTIONAL FUNDING REQUIREMENT As required by OP 22 and OP 23 of D.18-05-041, each IOU will fund statewide programs based on the 25 percent of the total portfolio budget requirement for SDG&E, PG&E and SCE, and the 15 percent requirement for SoCalGas designated in D.16-08-019,4 consistent with each IOU’s proportional share based on load, unless a deviation is specifically approved by the Commission. 3 SoCalGas Advice 5348-G; PG&E Advice 4010-G/5374-E; SCE Advice 3860-E; and SDG&E Advice 3266-E/2699-G. 4 D.16-08-019, Decision Providing Guidance for Initial Energy Efficiency Rolling Portfolio Business Plan Filings, OP 6. p. 109, issued August 25, 2016.
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Public Utilities Commission 3 September 4, 2018 PROPOSED ANNUAL REPORT TEMPLATE As required by OP 24, the proposed annual report template is attached hereto as Attachment A. EFFECTIVE DATE Pursuant to OP 24 of D.18-05-041, SDG&E believes that this submittal is subject to Energy Division disposition and should be classified as Tier 1 (effective pending disposition) and respectfully requests an approval date of September 4, 2018, the date submitted. 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 September 24, 2018, which is 20 days of the date this Advice Letter was submitted with the Commission. There is no restriction on who may submit 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 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. For SDG&E: Attn: Megan Caulson Regulatory Tariff Manager 8330 Century Park Ct., CP31F San Diego, CA 92123-1548 E-mail: For SoCalGas: Attn: Ray B. Ortiz Tariff Manager – GT14D6 555 West Fifth Street Los Angeles, CA 90013-1011 Email: For SCE: Gary A. Stern, Ph.D. Managing Director – Statewide Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, CA 91770 Email:
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Public Utilities Commission 4 September 4, 2018 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: For PG&E: Erik Jacobson Director – Regulatory Relations c/o Megan Lawson Pacific Gas and Electronic Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, CA 94177 Email: NOTICE A copy of this submittal has been served on the utilities and interested parties shown on the attached list, including interested parties in A.17-01-014 and R.13-11-005, by providing them a copy hereof either electronically or via the U.S. mail, properly stamped and addressed. Address changes should be directed to SDG&E Tariffs by email to SDG& _______________________________ CLAY FABER – DIRECTOR California & Federal Regulatory
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ADVICE LETTER 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: ✔ ELC PLC ELC = Electric PLC = Pipeline ✔ GAS WATER HEAT Contact Person: Christina Sondrini Phone #: 858-636-5736 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 3268-E/2701-G Subject of AL: San Diego Gas and Electric Company, Southern California Gas Company, Southern California Edison Company and Pacific Gas and Electric Company’s Shared Funding Mechanism Proposal Pursuant to Decision 18-05-041 Keywords (choose from CPUC listing): Energy Efficiency AL Type: Monthly Quarterly Annual ✔ One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.18-05-041 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: N/A Summarize differences between the AL and the prior withdrawn or rejected AL: N/A Yes ✔ No N/A N/A Yes ✔ No 9/4/18 No. of tariff sheets: 0 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 proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Megan Caulson Title: Regulatory Tariff Manager Utility Name: San Diego Gas & Electric Address: 8330 Century Park Ct., CP31D City: San Diego Zip: 92123 State: California Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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cc: (w/enclosures) General Order No. 96-B ADVICE LETTER SUBMITTAL MAILING LIST Public Utilities Commission Clean Power Research Office of Ratepayer Advocates (ORA) T. Schmid R. Pocta G. Novotny Energy Division M. Ghadessi M. Salinas L. Tan R. Ciupagea Tariff Unit CA Energy Commission B. Penning B. Helft Advantage Energy C. Farrell Alcantar & Kahl LLP M. Cade K. Harteloo AT&T Regulatory Barkovich & Yap, Inc. B. Barkovich Braun & Blaising, P.C. S. Blaising D. Griffiths CA Dept. of General Services H. Nanjo California Energy Markets General California Farm Bureau Federation K. Mills California Wind Energy N. Rader City of Poway Poway City Hall City of San Diego F. Ortlieb B. Henry L. Azar Y. Lu Davis Wright Tremaine LLP J. Pau Douglass & Liddell D. Douglass D. Liddell Ellison Schneider Harris & Donlan LLP E. Janssen C. Kappel Energy Policy Initiatives Center (USD) S. Anders Energy Regulatory Solutions Consultants L. Medina Energy Strategies, Inc. K. Campbell EQ Research General Goodin, MacBride, Squeri, & Day LLP B. Cragg J. Squeri Green Charge K. Lucas Hanna and Morton LLP N. Pedersen JBS Energy J. Nahigian Keyes & Fox, LLP B. Elder Manatt, Phelps & Phillips LLP D. Huard R. Keen McKenna, Long & Aldridge LLP J. Leslie Morrison & Foerster LLP P. Hanschen MRW & Associates LLC General NLine Energy M. Swindle NRG Energy D. Fellman Pacific Gas & Electric Co. M. Lawson M. Huffman Tariff Unit RTO Advisors S. Mara SCD Energy Solutions P. Muller Shute, Mihaly & Weinberger LLP O. Armi Solar Turbines C. Frank SPURR M. Rochman Southern California Edison Co. K. Gansecki TerraVerde Renewable Partners LLC F. Lee TURN M. Hawiger UCAN D. Kelly US Dept. of the Navy K. Davoodi US General Services Administration D. Bogni Valley Center Municipal Water Distr G. Broomell Western Manufactured Housing Communities Association S. Dey Interested Parties in: A.17-01-014 R.13-11-005
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ATTACHMENT A ANNUAL REPORT TEMPLATE Statewide EE Report by Program Plug Load & Appliance Program Year 20XX Lead: SDG&E SDG&E SCG SCE PG&E Contributions Total $ Interest Expenses Remaining Balance $ $ $ $ $ $
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