Details for: 3581-E-A (Part 1 of 1).pdf


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

December 21, 2018
ADVICE 3581-E-A
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
Supplemental Filing to Modify Advice 3581-E, Southern
California Edison Company’s Dead Band Tolerance Range
Proposal for Determining When Changes to TOU Periods
Should Occur More Frequently Than Five-Year Intervals

SUBJECT:

In compliance with Ordering Paragraphs (OPs) 2 and 4 of Resolution E-4948 (or the
Resolution), Southern California Edison Company (SCE) hereby submits this
supplemental advice letter to reflect the modifications to its proposed time-of-use (TOU)
period dead band tolerance range methodology adopted in the Resolution.
This advice letter supplements in part and will not change the integrity of the original
Advice 3581-E, except as described below.
PURPOSE
The purpose of this advice letter is to modify the dead band tolerance range
methodology originally proposed by SCE in Advice 3581-E with the changes adopted by
the California Public Utilities Commission (Commission or CPUC) in the Resolution.
BACKGROUND
On March 30, 2017, in compliance with OP 4 of Decision (D.)17-01-006 (or the
Decision),1 SCE filed Advice 3581-E to describe its proposed dead band tolerance
range methodology2 for determining if and when more frequent updates are needed to
SCE’s base TOU periods sooner than the minimum five-years or two General Rate
Case (GRC) cycles adopted in the Decision.

1
2

Decision Adopting Policy Guidelines To Assess Time Periods For Future Time-Of-Use
Rates And Energy Resource Contract Payments, in Rulemaking (R.)15-12-012.
In the Decision (p. 47), the Commission explains that a “dead band tolerance range should
be developed within which deviations between adopted forecasts and updated actual data
would not be significant enough to warrant a revision in TOU periods.”

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





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ADVICE 3581-E-A (U 338-E) -2- December 21, 2018 In Advice 3581-E, SCE proposed to establish a dead band tolerance range based on the results of a (a) top-20 and top-100 highest-cost hour assessment and a (b) lowest 20- and lowest 100-cost hour assessment. • • If the results show that less than 75 percent of the top 20 and the top 100 highest cost hours fall within the current on-peak period, the dead band tolerance range is exceeded, and SCE will address whether to update the TOU periods, even if five years have not yet passed since the previous change. Similarly, if less than 75 percent of the lowest 20 and lowest 100 cost hours fall within the current off-peak (or super-off-peak) period, the dead band tolerance range is exceeded, and SCE will propose at that time how to move forward. DISCUSSION The Resolution adopts SCE’s proposed dead band tolerance range methodology, with three modifications.3 First, the Resolution orders SCE to use the 100-hour criterion only, not the 20-hour criterion. Second, for the top 100 high-cost hour assessment, both the summer on-peak and summer mid-peak periods are to be used – not just the summer on-peak period. Third, the Resolution requires that SCE use a 7.5 percent differential as the trigger. Specifically, the dead band tolerance range will be considered exceeded when there is a decline of at least 7.5 percent in the number of top 100 high-cost hours that fall within the summer on-peak and mid-peak periods, or a decline of at least 7.5 percent in the number of top 100 low-cost hours that fall within the winter super-off-peak period. Finally, the Resolution specifies that transmission and distribution marginal costs must be included in the calculation of the dead band tolerance range analysis if used by the Commission to determine TOU periods. Therefore, based on the modifications ordered in the Resolution, the adopted dead band range methodology for SCE is expressed as follows: SCE establishes a dead band tolerance range based on the results of a (a) top-100 highest-cost hour assessment and a (b) lowest 100-cost hour assessment. • • 3 If the results show a decline of at least 7.5 percent in the number of top 100 high-cost hours that fall within the summer on-peak and mid-peak periods, the dead band tolerance range is exceeded, and SCE will address whether to update the TOU periods, even if five years have not yet passed since the previous change; and/or, If there is a decline of at least 7.5 percent in the number of top 100 low-cost hours that fall within the winter super-off-peak period, the dead band tolerance range is exceeded, and SCE will address whether to update the TOU periods, even if five years have not yet passed since the previous change. Resolution, OP 2. See also pp. 12-13.
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ADVICE 3581-E-A (U 338-E) • -3- December 21, 2018 Transmission and distribution marginal costs are included in the calculation of this analysis, if used by the CPUC to determine TOU periods. TIER DESIGNATION Pursuant to OP 4 of the Resolution, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice letter will become effective on January 20, 2019, the 30th calendar day after the date submitted. NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: AdviceTariffManager@sce.com
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ADVICE 3581-E-A (U 338-E) -4- December 21, 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: Karyn.Gansecki@sce.com There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of General Order (GO) 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, R.15-12012, A.16-09-003, A.17-06-030 and A.17-12-012 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters. For questions, please contact Erin Pulgar at (626) 302-2509 or by electronic mail at Erin.Pulgar@sce.com. Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:ep:jm
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: Darrah.Morgan@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 3581-E-A Subject of AL: Supplemental Filing to Modify Advice 3581-E, Southern California Edison Company’s Dead Band Tolerance Range Proposal for Determining when Changes to TOU Periods Should Occur More Frequently than Five-Year Intervals, in Compliance with Decision 17-01-006 Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 17-01-006 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: 1/20/19 No. of tariff sheets: 0 Estimated system annual revenue effect (%): Estimated system average rate effect (%): 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: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 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: EDTariffUnit@cpuc.ca.gov Name: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: advicetariffmanager@sce.com Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: (415) 929-5515 Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: karyn.gansecki@sce.com Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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