Details for: SCE's Reply to Protest to Advice 3844-E et al.pdf


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

September 7, 2018
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
SUBJECT:

Southern California Edison Company’s Reply to Protest
Filed to SCE Advice 3844-E, Proposed Approach for
Determining a Bill Credit to End Cost Recovery from a
Competing Demand Response Provider’s Customers.

Dear Energy Division Tariff Unit:
In accordance with Section 7.4.3 of General Order (GO) 96-B, Southern California
Edison Company (SCE) hereby replies to the protest of the Alliance for Retail Energy
Markets (AReM), Direct Access Customer Coalition (DACC), Marin Clean Energy
(MCE), Sonoma Clean Power (SCP) and the California Choice Energy Authority
(CCEA) (the Joint Parties) to SCE’s Advice Letter (AL) 3844-E. The Joint Parties’
protest was timely filed on August 30, 2018.
1.

Background

On November 1, 2017, the Commission issued Decision (D.)17-10-017 (Decision) which
adopted steps to implement the competitive neutrality cost causation principle.1 The
Decision established the process by which a Competing Provider’s Demand Response
(DR) program can be determined to be similar to the Investor Owned Utility (IOU) DR
program. The Decision directed the IOUs to jointly serve a proposed approach for
determining the bill credit to end cost recovery for the IOU’s similar DR program from
the Competing Provider’s customers along with issuing a draft standardized letter to be
used to inform the Competing Provider’s customers.2 The Decision further authorized
the Commission’s Energy Division to facilitate a workshop to discuss the proposed
approach and develop a consensus.3 Finally, the Decision stipulated that the IOUs shall
work with parties to the proceeding and within 30 days of the workshop, submit a
proposed approach via Tier 3 AL.4 On August 10, 2018 Pacific Gas and Electric
Company (PG&E), submitted a joint Tier 3 AL on behalf of San Diego Gas & Electric

1
2
3
4

See D.14-12-024.
Decision, Ordering Paragraph (OP) 3, p. 88.
Ibid, OP 4, p 88.
Ibid, OP 5, p 88.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645 FAX (626) 302-6396





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Energy Division Tariff Unit Page 2 September 7, 2018 Company (SDG&E), SCE and itself. In addition to presenting areas of consensus, the AL included each IOU’s independent bill credit proposal as separate attachments. 2. Advice Letter Protest Within its protest, the Joint Parties state that “SCE, which did not provide an implementation cost recovery proposal, is presumably not seeking implementation cost recovery.”5 3. SCE’s Reply SCE clarifies that it is not appropriate at this time to seek cost recovery for implementing a bill credit for a “similar DR program” that has yet to be proposed to the Commission. If warranted, SCE intends to seek cost recovery of any implementation costs during the Tier 3 AL process after a Competing Provider has submitted and received Commission approval for a DR program deemed to be “similar.” At that time, SCE will have information regarding the potential size, impact, and scope of the implementation of the Competing Provider’s customers’ bill credit, and whether any cost recovery is warranted. 4. Conclusion SCE appreciates the opportunity to file this response. For the reasons stated above and within AL 3844-E, SCE requests that the Commission approve SCE’s bill credit proposal. Sincerely, /s/ Russell G. Worden /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:lm/ct:jm cc: Dorothy Duda, CPUC Energy Division Natalie Guishar, CPUC Energy Division David Peffer, SCP Sue Mara, AReM Nathaniel Malcolm, MCE Service List R.13-09-011 5 Joint Parties Protest, p. 12.
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