Details for: PGE Reply to Protest of AL 5379-E.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

October 4, 2018

California Public Utilities Commission - Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102
Subject:

Pacific Gas and Electric Company’s Reply to the Protest of Advice
Letter 5379-E, Glidepath for Legacy RES-BCT Customers

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) hereby replies to the Protest dated September
27, 2018 by the Counties of Santa Clara and San Joaquin (Counties) to Advice 5379-E.
That advice letter was filed to comply with Ordering Paragraph (OP) 40 of D.18-08-013
to provide an A-6 generation glidepath for solar customers that are eligible for
grandfathered treatment pursuant to D.17-01-006 and take service under the Renewable
Energy Self Generation (RES-BCT) schedule. The Counties argue:
(1) PG&E proposes to create a “shadow” rate for A-6 with equal cent additions that
captures revenue requirement changes that occur after March 1, 2017. The
Counties instead interpret Ordering Paragraph 40 of D.18-08-013 to mean that the
6.2% discount in 2023 applies directly to the A-6 rates in effect on March 1, 2017,
without revenue requirement modifications.
(2) The Counties request confirmation that the 3.1% reduction to rates in 2020, the
4.1% reduction in 2021, the 5.2% reduction in 2022, and the 6.2% reduction in
2023 are derived from the TOU Settlement Agreement glidepath for legacy NEM
customers.
Response:
(1) Although PG&E disagrees with the Counties’ interpretation of OP 40, PG&E is not
opposed to the Counties’ request to make the generation rates in Table 1 of AL
5379-E be the compensation rates for Legacy RES-BCT customers without
modification based on changes in revenue requirement.
(2) PG&E confirms that the percentage discounts in the glidepath from 2020 to 2023
are derived from the discounts given to legacy NEM customers in the TOU
Settlement Agreement.





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PG&E’s Reply to Protest of Advice Letter 5379-E -2- October 4, 2018 Ordering Paragraph 40 only applies to the generation credit for legacy A-6 RES-BCT customers. The rate for load served under Rate Schedule A-6, including for legacy customers, will change based on changes in revenue requirement, as provided in the Settlement approved by D.18-08-013. PG&E respectfully requests that the Commission approve Advice 5379-E with the modification proposed by the Counties above. /S/ Erik Jacobson Director, Regulatory Relations cc: Ann L. Trowbridge, Day Carter & Murphy LLP, atrowbridge@daycartermurphy.com Service List A.16-06-013 and R.15-12-012
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