Details for: PGE AL 5446-E.pdf


Click on the image for full size preview

Document data

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

December 19, 2018

Advice 5446-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California
Subject:

Request for Approval of Proposal and Cost Recovery for Increasing
Rule 24 Registration Capacity to 200,000 Locations

Purpose
Pacific Gas and Electric Company (PG&E) seeks approval from the California Public
Utilities Commission (Commission or CPUC) to recover costs to implement
enhancements to PG&E’s California Independent System Operator Corporation (CAISO)
location review systems and associated business processes to support the continuing
growth in the number of Electric Rule 24 (Rule 24) registrations. PG&E’s current
implementation step, referred to as the Beyond the Intermediate Implementation Step,
supports 75,000 Rule 24 registrations. For the next implementation step, PG&E is
proposing to expand its current capacity to support a total of 200,000 Rule 24
registrations, an incremental increase of 125,000 registrations above the Beyond the
Intermediate Implementation Step. This increased capability is necessary to support the
2019 Demand Response Auction Mechanism (DRAM) pilot, as well as to support
sustained growth in third-party direct participation.
Background
The Commission opened Rulemaking (R.) 07-01-041 in January 2007 to address several
specific issues related to the Commission’s efforts to develop effective demand response
(DR) programs for California’s investor-owned electric utilities (IOUs). On November 9,
2009, Phase IV of the Rulemaking was opened to address issues resulting from FERC
Order 719, which, in relevant part, required the CAISO to modify its tariffs to allow retail
customers to bid Demand Response (DR) directly into CAISO’s wholesale energy and
ancillary services markets, either on their own behalf or through aggregators. On June 3,
2010, the Commission issued Decision (D.) 10-06-002, subsequently modified by D.1012-060, establishing the initial conditions under which it would oversee bidding of retail
DR directly into the CAISO markets, consumer protection mechanisms, financial
settlements, and communications protocols. The Commission resolved these remaining
policy issues in D.12-11-025 and directed the IOUs to continue to work with stakeholders





- Page 1 -

Advice 5446-E -2- December 19, 2018 from the proceeding to refine a proposed tariff rule and related documents that would address roles, responsibilities, rights and obligations under the direct participation regime. PG&E submitted Advice 4298-E on October 10, 2013, on behalf of Southern California Edison Company (SCE), San Diego Gas & Electric Company (SDG&E), and itself, the three investor-owned utilities (IOUs), with the revised Rule 24 tariff1 and related documents.2 On March 26, 2015, the Commission issued D.15-03-042 and ordered the Initial Implementation Step of direct participation for DRPs in the CAISO wholesale energy market by January 1, 2016. This authorized PG&E to build systems and processes to support 10,000 Rule 24 registrations3 with $2.9 million to be used between 2015 and 2016 for the CAISO’s day-ahead energy market.4 This budget included IT systems and manual business processes built to the CAISO’s Demand Response Registration System (DRRS) as of Spring 2015, operations and maintenance (O&M), two full-time equivalents (FTE) between 2015 and 2016, and Kern USA LLC (“Kern”) contractor costs to support the intake of CISR-DRPs. In addition, PG&E later requested $0.7 million in cost recovery to support the extension of O&M through 2017 in its 2017 transition year filing served on February 1, 2016,5 which the Commission approved in D.16-06-029. In compliance with D.15-03-042,6 the IOUs served testimony on March 11, 2015, proposing budgets for ancillary and real-time energy services (AS/RTE) for the Initial Implementation Step of direct participation, and the Commission issued D.16-03-008 authorizing the IOUs’ budgets with modifications.7 PG&E was authorized cost recovery of approximately $1.8 million for hardware and service costs associated with 15-minute interval data for AS/RTE, including Silver Springs Network hardware and direct labor costs to install hardware, customer data and analytics hardware, Meter Data 1 2 3 4 5 6 7 The applicable rule is Electric Rule 24 for SCE and Electric Rule 32 for SDG&E. Henceforth, any reference to Rule 24 applies to Rule 24 for SCE and PG&E, and Rule 32 for SDG&E. The Commission approved Advice 4298-E in Resolution E-4630 on March 19, 2014, with modifications consistent with D.13-12-029. Each customer location, referred to as a Rule 24 registration, that participates in a third party DRP’s aggregation and bid into the CAISO wholesale market must be registered at the CAISO. Once an IOU receives authorization from a customer to release its data to a DRP or partnering DRPs via the completed Customer Information Service Request form for DRPs (CISR-DRP), IOUs are required to provide DRPs with customer usage data, which the DRPs and their scheduling coordinators use to develop settlement quality meter data (SQMD) in order to settle transactions with the CAISO. D.15-03-042, Ordering Paragraph (OP) 5 and OP 9. PG&E Transition Year Proposal, filed February 1, 2016, page 25. D.15-03-042, OP 7. D.16-03-008, page 17, also approved a ratio of 1 Rule 24 registration to 5 CISR-DRPs.
- Page 2 -

Advice 5446-E -3- December 19, 2018 Management Systems (MDMS) changes, project delivery resources, capital overheads, and allowance for funds used during construction (AFUDC).8 Decision 15-03-042 also ordered the IOUs to file comments within seven months describing volumes beyond the Initial Implementation Step, referred to as the Intermediate Implementation step.9 In addition, as the Commission stated that targets set in the Decision “should be dynamic ceilings that will rise over time and should not be reached,” IOUs were ordered to inform the Commission within 6 months if it expected to exceed the number of registrations in their respective Initial Implementation Steps.10 The IOUs provided comments on the expansion of the Initial Implementation Step on November 30, 2015, and on December 8, 2015, PG&E filed a notice with the Commission that it could potentially exceed its 10,000 Rule 24 Initial Implementation Step registrations. Administrative Law Judge (ALJ) Hymes issued a ruling on January 22, 2016, to hold a prehearing conference on February 6, 2016, and directed PG&E to submit its Intermediate Implementation Step testimony, which it filed on February 29, 2016. PG&E included residential meter reprogramming costs for both the Initial and Intermediate Implementation steps in its February 29, 2016 testimony. A workshop was held on March 7, 2016, and on March 11, 2016, ALJ Hymes issued a ruling requesting that the IOUs file opening briefs on an Intermediate Implementation step. PG&E filed its opening brief on April 1, 2016, on its request for cost recovery for a total of 40,000 registrations (200,000 CISR-DRPs), an incremental increase of 30,000 registrations (150,000 CISR-DRPs) from the Initial Implementation Step for both dayahead energy and AS/RTE. PG&E requested approximately $5.7 million in expense over 2016-2017 and $50,000 in capital. The incremental work needed to support the Intermediate Implementation step included 5 FTEs in 2016 and 6 FTEs in 2017; Kern contractor costs to support CISR-DRP intake; data storage of CISR-DRP images; IT build for the new DRRS application programming interface (API); IT enhancements to support additional registrations; and hardware and service costs associated with 15-minute interval data, expense, and business O&M for AS/RTE. PG&E also included the scope of work associated with residential meter reprogramming and customer notification letters for both the Initial and Intermediate Implementation steps.11 The Commission approved a budget for PG&E of $5.4 million in D.16-06-008 for Intermediate Implementation, which included a slight cost reduction associated with the rejection of PG&E’s request to send 8 9 10 11 PG&E proposed meter reprogramming to more granular levels, but did not request recovery of meter reprogramming costs until its February 29, 2016, testimony on Intermediate Implementation. However, the Commission decision on AS/RTE for the Initial Implementation Step, D.16-03-008, page 1, only allowed meter reprogramming to 15-minute intervals, and rejected reprogramming further to 5-minute intervals. The project was completed by March 17, 2017. D.15-03-042 OP 15. D.15-03-042, page 36. PG&E Demand Response Rule 24 Intermediate Implementation Step and Cost Recovery Phase 2 Testimony, filed February 29, 2016.
- Page 3 -

Advice 5446-E -4- December 19, 2018 customers a verification letter regarding their CISR-DRP authorization. PG&E requested $12,931,000 of on-going O&M costs for 2018-2022 to cover the 40,000 authorized Rule 24 registrations in A.17-01-012, and the Commission approved this request in D.17-12003. Decision 16-06-008 also approved a mechanism for the IOUs to recover costs up to their previous Rule 24 authorized costs to date ($10.39 million for PG&E) to increase the number of registrations beyond the Intermediate Implementation Step, but not to reach Mass Market Implementation.12 The IOUs could request additional funding via a Tier 3 advice letter process as long as it occurred prior to a final decision in the 2018 DR application process, and the IOUs notified the service list of A.14-06-001 et al. of the proposed AL prior to filing such AL and discussed the contents of the AL in a meeting with the service list of A.14-06-001 et al. On January 3, 2017, PG&E filed a Petition for Modification (PFM) of D.16-06-008 to seek funding flexibility to limit delays or barriers to the growth of direct participation, among other topics. On June 15, 2017, the Commission issued D.17-06-005, allowing the IOUs to submit Tier 3 advice letters to request Commission approval for cost recovery of additional improvements in Rule 24 implementation up to the budget cap, including, but not limited to, Mass Market Implementation. The funding could also be requested after a final decision in the 2018 DR application process. For PG&E, the budget cap was determined to be $10.39 million.13 Concurrently with the PFM process, the Commission ordered the IOUs to “ensure that the availability of customer registrations does not limit 2018-2019 DRAM pilot procurement – the number of customer registrations should be dynamic.”14 The Commission then ordered the IOUs in OP 5 to submit an advice letter by February 7, 2017, using the process described in OP 13 of D.16-06-008, if needed, to aggressively increase customer registrations in 2018-2019. PG&E submitted Advice 5014-E to seek Commission approval of a proposal and budgets for increasing the number of Rule 24 registrations to 75,000 registrations, named the Beyond the Intermediate Implementation Step, which represented an incremental 35,000 registrations. This request included $1.914 million in funding for an additional FTE between 2017 and 2022, Kern contractor costs, and IT enhancements, which were approved in Resolution E-4837. On April 27, 2017, in response to Petitions for Modifications (PFM) filed by Comverge, Inc., CPower, EnerNOC, Inc., and EnergyHub (collectively, the “Joint DR Parties”) and OhmConnect, the Commission determined that business opportunities for DRPs could be 12 13 14 D.16-06-008, OP 13. D.17-06-005, OP 4. Resolution E-4817, OP 3.
- Page 4 -

Advice 5446-E -5- December 19, 2018 limited under the corresponding $27 million budget approved for the 2018-2019 DRAM RFO.15 As a result, the Commission ordered the IOUs and asked other parties to respond to a series of questions pertaining to an additional pilot auction in 2018 for 2019 deliveries.16 On October 26, 2017, the Commission issued D.17-10-017, and determined that it is reasonable to require PG&E, SCE, and SDG&E to conduct an additional 2018 auction for contract deliveries in 2019 (2019 DRAM RFO).17 PG&E procured 63 additional megawatts (MW) in the subsequent 2019 DRAM RFO pilot. PG&E issued a notice on December 4, 2018, to the R.13-09-011 and A.14-06-001 et al service lists. The notice stated that PG&E will be filing this advice letter, and that in compliance with OP 7 of the resolution, a meeting would be held on December 11, 2018, to discuss the contents of the advice letter prior to filing. PG&E held a call on December 11, 2018, to discuss the specifics of the proposed advice letter with the parties and Commission staff, and this advice letter is submitted in accordance with this order. Proposal to Increase Rule 24 Registration Capacity to 200,000 Locations As of December 13, 2018, PG&E is managing approximately 58,000 Rule 24 registrations out of the 75,000 registration capacity available today. PG&E expects that the current implementation step of 75,000 registrations will be reached during Q1 2019. PG&E believes that in order to ensure that the registration capacity does not limit or impede the success of the 2019 DRAM, it must begin development of enhancements necessary to support greater volumes of Rule 24 registrations. While PG&E’s existing systems will be able to accommodate a moderate level of registration volumes exceeding the current 75,000 registration step, enhancements to PG&E systems and business processes are necessary to keep pace with the anticipated steady increase in Rule 24 CAISO registrations. PG&E believes 200,000 Rule 24 registrations represents a reasonable target level to support the DRAM deliveries in 2019 and a continued increase in direct participation in the CAISO wholesale market. PG&E notes that at the time of the submittal of this advice letter, the Commission has not yet determined the future of a permanent auction mechanism, but anticipates a decision will be made in mid-2019.18 While this decision may indicate an expansion of the DRAM that may necessitate a broader expansion of Rule 24 capacities beyond this proposal to Mass Market Implementation, PG&E considers a 200,000 Rule 24 registration level an appropriate intermediary step. PG&E proposes a limited scope of work designed to specifically address key bottlenecks in 15 16 17 18 Petition of the Joint DR Parties for Modification of D.16-06-029 was filed February 3, 2017, in R.13-09-011. Petition for Modification of OhmConnect of D.16-09-056 was filed December 30, 2016, in R.13-09-011. D.17-04-045, OP 6. D.17-10-017 also ordered the IOUs to serve the notice previously established for A.14-06-001 et al. to the R.13-09-011 service list, as A.14-06-001 et al. is now closed. D.18-11-029, pp. 83-84.
- Page 5 -

Advice 5446-E -6- December 19, 2018 existing Rule 24 location review systems and associated business processes, which ensures compliance with the service levels required by Rule 24.19 Scope and Budget PG&E seeks authorization in this advice letter to recover costs to enhance its existing systems to process increasing volumes of CAISO locations submitted by DRPs into the CAISO Demand Response Registration System (DRRS) for review by PG&E in its UDC and LSE review roles. PG&E’s location review process is a fully automated process that runs seven days a week. In order to maintain PG&E’s automated capability supporting registration reviews beyond 75,000 registrations, PG&E will need to enhance and optimize the existing IT systems and processes used for: • Retrieving CAISO location data from the CAISO DRRS via API, • Storing and archiving CAISO location data in database tables, • Conducting CAISO location reviews as the UDC and LSE, and • Returning CAISO location review results/findings to the CAISO DRRS via API. Additionally, PG&E will update the dual participation check process that it applies as part of its UDC/LSE review per Section C.2.d of Rule 24. Table 1 describes the scope and associated budget for each of the main tasks included in this project. 19 For instance, see Section C.1.b of Rule 24, which refers to timeliness and due diligence, and Section C.1.c describing PG&E’s obligations associated to the review of DRP customer service agreements in the CAISO’s Relevant Systems.
- Page 6 -

Advice 5446-E -7- December 19, 2018 Line No. Description 1 IT Tasks 2 Modify existing systems and processes to support increased volume of Rule 24 CAISO locations from approximately 75,000 to 200,000 locations including updates to the dual participation check process 3 Project Delivery 4 Testing 5 Incremental IT O&M (First Year) 6 Total IT Project and IT O&M 7 Business Tasks 8 Business Project Costs (Project Management (PM)/ Business Analysis (BA)) 9 Total Business 10 Total IT Project, IT O&M, and Business Tasks Cost $438,000 $31,000 $37,000 $44,000 $550,000 $60,000 $60,000 $610,000 Key Assumptions • Build on top of existing systems and infrastructure • Expect an approximate 2:1 ratio of Rule 24 authorizations per each registered CAISO location. • Add capabilities to support retrieving larger numbers of locations from CAISO via API services made available by CAISO. • CAISO will support testing by PG&E in CAISO’s MAP Stage environment • Assumes a 20% cost contingency In addition to implementing enhancements to PG&E’s CAISO Location review systems and processes as described above, PG&E is also planning to implement a set of enhancements to internal systems and tools supporting other aspect of Rule 24 program administration to improve and optimize existing capabilities and to scale with the increase in Rule 24 authorizations associated with the growing volume of CAISO Locations. PG&E is planning to implement enhancements in the following areas: • Update Rule 24 database tables to capture additional details pertaining to CAISO locations and CISR-DRP Form data. • Improve the user interface and functionality for the system used to identify, research and populate missing Rule 24 data elements. • Update the CISR-DRP Form intake process to improve the logic for identifying duplicate CISR form submittals and to improve CISR-DRP form error handling. • Automate the distribution of weekly reports that PG&E prepares for DRPs and other Load Serving Entities. The distribution of the reports is currently performed manually by PG&E’s Rule 24 team using an FTP client application. Table 2 below presents the scope and budget to support the implementation of these additional enhancements.
- Page 7 -

Advice 5446-E -8- December 19, 2018 Line No. Description 1 IT Tasks 2 Implement enhancements to Rule 24 database, CISR intake process, and data exceptions handling system 3 Automate file transfers via Electronic Secure File Transfer tool 4 Project Delivery 5 Testing 6 Incremental IT O&M (First Year) 7 Total IT Project and IT O&M 8 Business Tasks 9 Business Project Costs (PM/BA) 10 Total Business 11 Total IT Project, IT O&M, and Business Tasks Cost $80,000 $20,000 $25,000 $50,000 $25,000 $200,000 $80,000 $80,000 $280,000 Key Assumptions • Build on top of existing systems and infrastructure • Assumes 25% cost contingency Meter Reprogramming In D.16-03-008, the Commission approved IOU proposals and budgets to support third party direct participation in the CAISO AS/RTE market within the Initial Implementation Step. This decision20 also approved a settlement between Comverge, Inc., EnergyHub, Inc., OhmConnect, Inc., and PG&E regarding fees for reprogramming residential meters from one hour intervals to 15 minute intervals, which is necessary to support AS/RTE market participation.21 Specifically, PG&E agreed not to charge residential customers for over-the-air meter reprogramming if the customer is successfully enrolled at the CAISO for direct participation and within the Initial Implementation Step of 10,000, if PG&E is the meter service provider (MSP) and meter data management agent (MDMA).22 Following this decision, PG&E requested a budget of approximately $1.26 million to support this residential meter reprogramming for the Initial Implementation step and an extension of the treatment of fees to the Intermediate Implementation step. Citing that automation has reduced costs for over-the-air residential meter reprogramming, PG&E further extended its commitment to not charging DRPs for over-the-air meter reprogramming for the residential customers within the Beyond the Intermediate Implementation Step of 75,000 registrations.23 The CPUC approved PG&E’s approach for supporting free residential 20 21 22 23 D.16-03-008, OP 1. Residential customers typically have meters programmed to collect data at 60-minute intervals. Their meters would need to be reprogrammed to 15-minute intervals, which can be divided into 3 equal 5-minute intervals to create the interval data necessary for CAISO AS/RTE market participation. When PG&E is the meter service provider (MSP) and the MDMA, PG&E is responsible for reprogramming such meters, and for verifying, estimating, and editing (VEE) the monthly usage data to make it revenue quality meter data (RQMD). PG&E Advice 5014-E, page 6, submitted February 7, 2017.
- Page 8 -

Advice 5446-E -9- December 19, 2018 meter reprogramming in Resolution E-4837. At this time, PG&E believes that existing funding authorizations continue to be sufficient to support over-the-air meter reprograming for the residential customers within the 200,000 level of registrations, where PG&E is the MSP and MDMA, to be performed only after the customer location has been successfully registered with the CAISO. Therefore, PG&E seeks Commission authorization to continue to utilize existing cost recovery originally approved for residential meter reprogramming within the Intermediate Implementation step for this 200,000 registration capacity. The attached red-line of Schedule E-DRP reflects this proposal and should be approved. Once a decision has been made on the future of DRAM, PG&E will evaluate Rule 24 and meter data management systems and processes and determine an appropriate longerterm path for residential meter reprogramming services that it performs to support direct participation. Specifically, PG&E plans to assess the costs for data storage, transmission, and data management associated with data collection at the shorter 15 minute intervals. Once such costs have been fully analyzed, PG&E will propose an update to the fee schedule contained within Electric Schedule E-DRP, section 2.f. Cost Recovery Pursuant to OP 28, and Table 3 of the Resolution, PG&E submits this Tier 3 advice letter seeking cost recovery of a total of $890,000 to fund PG&E’s projects as described herein from the $10.39 million budget cap approved in D.16-06-008, as modified by D.17-06005, OP 13. PG&E requests flexibility between capital and expense categorization to reduce implementation delays. Additionally, PG&E requests flexibility to shift funds between the two project budgets presented in this Advice Letter, as well as authority to utilize the funding in 2019 and through 2020, if necessary, to avoid any delays in project completion once the project work has begun. PG&E plans to use Generally Acceptable Accounting Principles and internal software capitalization principles where applicable under Commission rules. PG&E also requests authorization to extend the $1.26 million of funding authorized in D.16-06-008 to support over-the-air residential meter reprogramming within the 200,000 registration level. PG&E has already requested $1.914 million to support up to 75,000 Rule 24 registrations,24 $1.971 million to support costs to modify the CISR-DRP Form and expand the Rule 24 data set,25 and $430,600 to fund the performance metrics project.26 Though the Commission has not yet approved the cost recovery for the performance metrics project, adequate funds remain to support the incremental funding requested in this advice letter under this $10.39 million cap if the Commission approves the advice letters as submitted. 24 25 26 PG&E submitted Advice 5014-E, and the Commission approved it in Resolution E-4837. PG&E submitted Advice 5165-E, and the Commission approved it in Resolution E-4912. PG&E submitted Advice 5190-E and supplemented it with Advice 5190-E-A. These advice letters are pending approval.
- Page 9 -

Advice 5446-E - 10 - December 19, 2018 Conclusion and Relief Requested PG&E requests approval for this project totaling $890,000 so that PG&E’s systems and automated processes can keep pace with the continued growth in the number of CAISO registrations. While PG&E’s systems can accommodate a moderate level of registrations exceeding the current 75,000 registration (CAISO location) capacity from the Beyond the Intermediate Step, PG&E urges the Commission to provide timely approval of this advice letter so that detailed design and development work can begin as soon as possible. This submittal would not increase any current rate or charge, cause the withdrawal of service, or conflict with any rate schedule or rule. Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than January 8, 2019, which is 20 days after the date of this submittal. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: EDTariffUnit@cpuc.ca.gov Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: PGETariffs@pge.com
- Page 10 -

Advice 5446-E - 11 - December 19, 2018 Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date PG&E requests that this tier 3 advice submittal become effective upon Commission approval. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service list for A.14-06-001 et al and R.13-09-011. Address changes to the General Order 96-B service list should be directed to PG&E at email address PGETariffs@pge.com. For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter submittals can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List A.14-06-001 et al Service List R.13-09-011 Katherine Stockton, Energy Division
- Page 11 -

ADVICE LETTER S UM M A RY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39 E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Annie Ho Phone #: (415) 973-8794 E-mail: PGETariffs@pge.com E-mail Disposition Notice to: AMHP@pge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Advice Letter (AL) #: 5446-E Tier Designation: 3 Subject of AL: Request for Approval of Proposal and Cost Recovery for Increasing Rule 24 Registration Capacity to 200,000 Locations Keywords (choose from CPUC listing): Compliance, Rules AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.16-06-008, D.17-06-005 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: Yes Yes No No No. of tariff sheets: 3 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: Electric Schedule E-DRP Service affected and changes proposed 1: N/A Pending advice letters that revise the same tariff sheets: N/A Discuss in AL if more space is needed. 1 Clear Form
- Page 12 -

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: EDTariffUnit@cpuc.ca.gov Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: PGETariffs@pge.com Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
- Page 13 -

Attachment 1 Advice 5446-E Cal P.U.C. Sheet No. Title of Sheet Cancelling Cal P.U.C. Sheet No. 43626-E ELECTRIC SCHEDULE E-DRP DEMAND RESPONSE PROVIDER SERVICES Sheet 2 37017-E 43627-E ELECTRIC TABLE OF CONTENTS Sheet 1 43321-E 43628-E ELECTRIC TABLE OF CONTENTS Sheet 6 42949-E Page 1 of 1
- Page 14 -

Cancelling U 39 Revised Revised Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 43626-E 37017-E San Francisco, California ELECTRIC SCHEDULE E-DRP DEMAND RESPONSE PROVIDER SERVICES 2. RATES: (Cont’d.) Sheet 2 Per-Event Metering Service Charges (Cont’d.) f. Meter Programming (Remote), per meter ........................ $41.90 This charge is incurred when PG&E reprograms a SmartMeter remotely. PG&E will not charge for over-the-air reprogramming to 15 minute intervals for meters serving retail residential customers locations that are registered through Rule 24 as part of the active 200,000 customer locations in the Initial, Intermediate, Next Step Beyond the Intermediate, and 200,000 Registration Level of Implementation steps established in D.16-03-008, D.16-06-008, and Resolution E-4837, subject to the available budget authorized in D.1606-008, Resolution E-4837, and the resolution approving Advice 5446-E, where PG&E is the Meter Data Management Agent and the Meter Service Provider. g. (T) I I I I (T) Meter Battery Change, per meter ..................................... $58.01 This charge is incurred when PG&E replaces the interval meter battery. h. Metering Inspection, per meter ....................................... $106.36 This charge is incurred each time PG&E inspects the interval metering facility beyond what is required by its normal business practices. i. Metering Services Hourly Labor Rate ............................. $125.69 Metering services performed by PG&E which are not covered by the above service charges or any other PG&E fees or contracts will be charged this hourly rate, plus the Metering Service Base Charge described above, plus materials costs. Application of Per-Event Metering Service Charges: When PG&E performs any of the above services, the Metering Service Base Charge and applicable service charge(s) apply. For example, if an interval meter malfunction requires repair and testing of the meter, the requesting party would incur the Metering Service Base Charge, Unscheduled Metering Maintenance Charge, and the Meter Test Charge. The Metering Service Base Charge does not apply to PG&E’s remote programming of its’ SmartMeter. Once the requesting party has communicated to PG&E that the interval meter site is ready for interval meter installation, if the interval meter site is not prepared at the time PG&E attempts to perform the interval meter installation, the requesting party will be charged the Metering Service Base Charge and the Metering Inspection Charge. If conditions at the customer’s meter site require an exceptional amount of material and/or time to perform meter services, the requesting party will be charged for the additional material cost and the hourly rate for the additional time. Advice Decision 5446-E Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution December 19, 2018
- Page 15 -

Cancelling U 39 Revised Revised Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 43627-E 43321-E San Francisco, California ELECTRIC TABLE OF CONTENTS Sheet 1 TABLE OF CONTENTS SCHEDULE CAL P.U.C. SHEET NO. TITLE OF SHEET Title Page ............................................................................................................................... 43627-E Rate Schedules ............................ 42793,42794*,42795,43271,43628,42798,40921,43322,41965-E Preliminary Statements ........................................ 41966,35423,41796,37737,34373,37727,43021-E Rules ................................................................................................................ 43022,43023,43210-E Maps, Contracts and Deviations ............................................................................................ 37960-E Sample Forms ... 40925*,37631,41151*,41573*, 37632,41152*,41153,37769,41786,36059,37169-E (T) (T) (Continued) Advice Decision 5446-E Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution December 19, 2018
- Page 16 -

Cancelling U 39 Revised Revised Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 43628-E 42949-E San Francisco, California ELECTRIC TABLE OF CONTENTS SCHEDULE Sheet 6 CAL P.U.C. SHEET NO. TITLE OF SHEET Rate Schedules Other S E-CHP E-CHPS E-CHPSA E-DCG E-DEPART E-DRP E-ECR E-GT E-NMDL E-NWDL E-LORMS E-SDL E-STORE E-TMDL NEM NEM2 NEMFC NEMBIO NEMCCSF NEMV NEM2V Standby Service ................40243,40244,40245,41954,40247,40248,40249,40250,40251,40252, ............................................... 40253,40254,40255,40654,41955,40258,40259,40260,40261-E Combined Heat and Power PPA .......................................... 30809,30810,30811,30812, 30813-E Combined Heat and Power Simplified PPA .....................................30814,30815,30816, 30817-E Combined Heat And Power Simplified 500 kW PPA .. 30825,30826,31679,31680,31681,31682-E DCG Departing Customer Generation, CG ................................................... 36593,36594,37148, ........................................................... 37794,3251436595,36596,23252,23253,28405,23255-E Departing Customers ....................................................................................................... 28859-E Demand Response Provider Services................................................................... 35430,43626-E (T) Enhanced Community Renewables (ECR) Program ..................................... 40854,35739,40855, .................................................................................................................35741,35742,35743-E Green Tariff (GT) Program .................................................... 40858,40633,40859,37964,37965-E New Municipal Departing Load ....................... 27453,32097,32098,32099, 29557,29558-,29559, ........................................................................................... 29560,29561,29562,29563,29564-E New WAPA Departing Load ............................................................... 28581,28582,28862,28863, .......................................................................................... 27448,27449,27450,27451, 27452-E Limited Optional Remote Metering Services .................................................................... 20194-E Split-Wheeling Departing Load ................................................ 28588,28589,28867,28868,27459, .......................................................................................... 27460,27461,27462,27463, 27464-E Station Service For Storage Devices..................................... 40238,40239,40240,40241,40242-E Transferred Municipal Departing Load .......................................................... 27465,28869,28870, ............................................... 35227,28961,30659,28608,25887,25888,25889,25890,25891-E Net Energy Metering Service ............................................................ 35635*,36352,36353,35636, .............................. 33901*,35637*,35638*,33904*,36562,36563,36564,35753,33909*,33910*, ....................33911*,33912*,33913*,35643,33915*,35276,35644,36599,35704,35705,36354-E Net Energy Metering Service ................. 42929,37796,42930,37798,37799,42931,42932,42933, .......................................42934,42435,42436,42437,37807,42938,37809,37810,42939,37812, .......................................37813,42940,37815,37816,42941,37818,37819,42942,42943,42944, .................................................................................................................42945,42946,42947-E Net Energy Metering Service For Fuel Cell Customer-Generators .... 37770,38187,37772,37773, ................................................................................ 37774,37775,32446,32447,37824,38231-E Net Energy Metering Service for Biogas Customer-Generators .................... 30791,27254,27255, ................................................................................ 26140,27256,26142,27257,26144,37823-E Net Energy Metering Service for City and County of San Francisco ........................ 28176,28177, ........................................................................................................................... 28178,28179-E Virtual Net Metering for a Multi-Tenant or Multi-Meter Property Served at the Same Service Delivery Point............................. 42055,42056,42057,31549,32806, .......................................31551,33921,31553,42058,42059,31556,31557,31558,31559,31560, .......................................................... 42060,36566,32807,42061,31565,42062,33216,42063-E Virtual Net Energy Metering Service ............................ 42044,37826,37827,37828,42045,37890, ............................................................ 37831,37832,42046,42047,37835,37836,37837,37838, ........................................................ 42048,37840,42049,37842,37843,37844,37845,42050*-E (Continued) Advice Decision 5446-E Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution December 19, 2018
- Page 17 -

Advice 5446-E December 19, 2018 Attachment 2 Redline Tariff
- Page 18 -

Cancelling U 39 Revised Original Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. San Francisco, California ELECTRIC SCHEDULE E-DRP DEMAND RESPONSE PROVIDER SERVICES RATES: (Cont’d.) 37017-E 35431-E 2. Sheet 2 Per-Event Metering Service Charges (Cont’d.) f. Meter Programming (Remote), per meter ........................ $41.90 This charge is incurred when PG&E reprograms a SmartMeter remotely. PG&E will not charge for over-the-air reprogramming to 15 minute intervals for meters serving retail residential customers locations that are registered through Rule 24 as part of the active 40200,000 customer locations in the Initial, and Intermediate, Next Step Beyond the Intermediate, and 200,000 Registration Level of Implementation steps established in D.16-03-008, and D.16-06-008, and Resolution E-4837, subject to the available budget authorized in D.16-06-008, Resolution E-4837, and the resolution approving Advice 5446-E, where PG&E is the Meter Data Management Agent and the Meter Service Provider. g. Meter Battery Change, per meter ..................................... $58.01 This charge is incurred when PG&E replaces the interval meter battery. h. Metering Inspection, per meter ....................................... $106.36 This charge is incurred each time PG&E inspects the interval metering facility beyond what is required by its normal business practices. i. Metering Services Hourly Labor Rate............................. $125.69 Metering services performed by PG&E which are not covered by the above service charges or any other PG&E fees or contracts will be charged this hourly rate, plus the Metering Service Base Charge described above, plus materials costs. Application of Per-Event Metering Service Charges: When PG&E performs any of the above services, the Metering Service Base Charge and applicable service charge(s) apply. For example, if an interval meter malfunction requires repair and testing of the meter, the requesting party would incur the Metering Service Base Charge, Unscheduled Metering Maintenance Charge, and the Meter Test Charge. The Metering Service Base Charge does not apply to PG&E’s remote programming of its’ SmartMeter. Once the requesting party has communicated to PG&E that the interval meter site is ready for interval meter installation, if the interval meter site is not prepared at the time PG&E attempts to perform the interval meter installation, the requesting party will be charged the Metering Service Base Charge and the Metering Inspection Charge. If conditions at the customer’s meter site require an exceptional amount of material and/or time to perform meter services, the requesting party will be charged for the additional material cost and the hourly rate for the additional time. Advice Decision 4820-E-A D.16-03-008, 1606-008 Issued by Steven Malnight Senior Vice President Regulatory Affairs Date Filed Effective Resolution July 14, 2016 July 14, 2016
- Page 19 -

PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. Braun Blaising Smith Wynne P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Casner, Steve Cenergy Power Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
- Page 20 -