Details for: PGE AL 5448-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

December 21, 2018

Advice 5448-E
(Pacific Gas and Electric Company ID U 39 E)
Public Utilities Commission of the State of California
Subject:

Update to Pacific Gas and Electric Company’s Bundled Procurement
Plan – Greenhouse Gas Procurement Limits

Introduction
Pacific Gas and Electric Company (“PG&E”) hereby submits to the California Public
Utilities Commission (“Commission” or “CPUC”) this advice letter to update greenhouse
gas (“GHG”) procurement limits in PG&E’s approved Bundled Procurement Plan (“BPP”).
Background
PG&E’s BPP establishes the utilities’ procurement authority on behalf of bundled
customers, consistent with Public Utilities Code section 454.5, which obviates the need
for an after-the-fact reasonableness review by Commission as long as the resulting utility
procurement decisions are consistent with the approved plan. In Decision (D.) 15-10031, the Commission adopted the investor-owned utilities’ proposed BPPs with
modifications and required PG&E to submit a conformed copy of its BPP, which was
submitted on December 10, 2015.1 Since then, PG&E has updated the BPP as needed
when market conditions or electric portfolio changes necessitate modifying the BPP.
PG&E’s BPP establishes electrical capacity procurement limits and ratable rates that
apply to electric capacity transactions with deliveries beyond the prompt calendar year.2
The BPP indicates that PG&E will file an “annual (or more frequent, if necessary) update
to its electrical capacity, electric energy, natural gas, and greenhouse gas procurement
limit and ratable rates in Appendix C in a Tier 1 advice letter”.3 During the years in which
PG&E does not file an updated conformed bundled procurement plan, PG&E will submit
changes to the BPP procurement limits and ratable rates via Tier 1 advice letter.

On June 15, 2016, the Commission approved PG&E’s Conformed BPP submitted in Advice
Letter 4750-E consistent with D.15-10-031 and D.16-01-015.
2
BPP, Sheet Nos. 65-67.
3
BPP, Sheet No. 37.
1





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Advice 5448-E -2- December 21, 2018 Discussion In this advice letter, PG&E adjusts the previously approved GHG procurement limits since Advice Letter 5198-E was submitted in December 2017, but is not proposing any additional updates to its approved procurement limits and ratable rates at this time. Confidential Attachments A and B of this advice letter include redlined and clean versions of the revised GHG tables appearing in Section C (“GHG Procurement Limits”) of Appendix C of the BPP. In accordance with D.07-12-052, all proposed updates to the BPP are to be made via an advice letter and shall include red-lined pages of the BPP as well as clean replacement pages.4 Confidentiality In support of this Advice Letter, PG&E submits Confidential Attachments A, B, and C in the manner directed by D.14-10-033 and D.08-04-023 to demonstrate the confidentiality of the material and to invoke the protection of confidential utility information provided under D.14-10-033 and General Order 66-C and Public Utilities Code Section 454.5(g). A separate Declaration Seeking Confidential Treatment is being submitted concurrently with this Advice Letter. Attachments Confidential Attachment A Proposed Edits to GHG Procurement Limits, BPP Sheets 80, 81, 84 (Redline) Confidential Attachment B Proposed Edits to GHG Procurement Limits, BPP Sheets 80, 81, 84 (Clean) Confidential Attachment C Confidential Workpapers - GHG Procurement Limits Attachment D Declaration of Kimberly Chang Seeking Confidential Treatment Pursuant to Public Utilities Code §454.5(g) and D.14-10-033 Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or Email, no later than January 10, 2019, which is 20 days after the date of this filing. Protests must be submitted to: 4 D.07-12-052 at pp. 184-185.
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Advice 5448-E -3- December 21, 2018 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 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 1 advice filing become effective on December 21, 2018. 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 R.16-02-007. 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
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Advice 5448-E -4- December 21, 2018 PGETariffs@pge.com. Advice letter filings can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List R.16-02-007
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39E) Utility type: ELC GAS PLC ✔ HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Yvonne Yang Phone #: (415)973-2094 E-mail: PGETariffs@pge.com E-mail Disposition Notice to: Yvonne.Yang@pge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 5448-E Subject of AL: Update to Pacific Gas and Electric Company’s Bundled Procurement Plan – Greenhouse Gas Procurement Limits 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 #: D.15-10-031 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 No Please see attachment D Chang, Kimberly, KWCC@pge.com, (415)972-5472 Yes ✔ No 12/21/18 No. of tariff sheets: N/A 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: 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: 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
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Advice 5448-E December 21, 2018 Confidential Attachment A Proposed Edits to GHG Procurement Limits, BPP Sheets 80, 81, 84 (Redline)
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Advice 5448-E December 21, 2018 Confidential Attachment B Proposed Edits to GHG Procurement Limits, BPP Sheets 80, 81, 84 (Clean)
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Advice 5448-E December 21, 2018 Confidential Attachment C Confidential Workpapers - GHG Procurement Limits
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Advice 5448-E December 21, 2018 Attachment D Declaration of Kimberly Chang Seeking Confidential Treatment Pursuant to Public Utilities Code §454.5(g) and D.14-10-033
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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA DECLARATION OF KIMBERLY CHANG SEEKING CONFIDENTIAL TREATMENT FOR CERTAIN DATA AND INFORMATION CONTAINED IN PG&E'S ADVICE LETTER 5448 -E I, Kimberly Chang, declare: 1. I am a Manager in the Commercial Policy, Planning and Compliance Depmiment within the Energy Policy and Procurement Organization at Pacific Gas and Electric Company (PG&E). In this position, my responsibilities include leading commercial Greenhouse Gas compliance activities. This declaration is based on my personal knowledge of PG&E's procurement methods and practices, greenhouse gas compliance instrument procurement practices, and my understanding of the Commission's decisions protecting the confidentiality of market-sensitive information concerning electric procurement of an investor-owned utility. 2. Based on my knowledge and experience, and in accordance with the "Administrative Law Judge's Ruling Clarifying Interim Procedures For Complying With Decision ("D") 06-06-066," issued in Rulemaking 05-06-040 on August 22, 2006, and D.14-10033, I make this declaration seeking confidential treatment for Advice Letter 5445 -E which provides an update to PG&E's greenhouse gas ("OHO") Procurement Plan limits. 3. Attached to this declaration is a matrix identifying the data and information for which PG&E is seeking confidential treatment. The matrix specifies that the material PG&E is seeking to protect constitutes data and information covered by D.14-10-033 and by General Order (GO) 66-C, Section 2.2b, which would place PG&E in an unfair business disadvantage if disclosed; and Public Utilities Code Section 454.5(g), which would reveal market sensitive information. The matrix also specifies why confidential protection is justified. Finally, the matrix specifies that: (1) the information is not already public; and (2) the data cannot be aggregated, redacted, summarized or otherwise protected in a way that allows partial disclosure.
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By this reference, I am incorporating into this declaration all of the explanatory text that is pertinent to my testimony in the attached matrix. I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed on December 18, 2017 at San Francisco, California. KIMBERLY CHANG
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PACIFIC GAS AND ELECTRIC COMPANY’S (U 39 E) ADVICE LETTER 5448-E December 21, 2018 IDENTIFICATION OF CONFIDENTIAL INFORMATION Redaction Reference Advice 5448-E, Attachment A Advice 5448-E, Attachment B Advice 5448-E, Attachment C Category from D.06-06066, Appendix 1, or Separate Confidentiality Order That Data Corresponds To D.14-10-033, Attachment A General Order 66-C D.14-10-033, Attachment A General Order 66-C D.14-10-033, Attachment A General Order 66-C Justification for Confidential Treatment Length of Time Data To Be Kept Confidential Information concerning GHG compliance instrument procurement strategy and/or activities. The release of this commercially sensitive information could cause harm to PG&E’s customers and put PG&E at an unfair business advantage by the disclosure of a GHG procurement strategy. This information could be used by other market participants to gain a commercial advantage. In addition, this information may reveal whether or not PG&E participated in California Air Resources Board (“CARB”) auctions and PG&E’s net open position for GHG compliance. Indefinite Information concerning GHG compliance instrument procurement strategy and/or activities. The release of this commercially sensitive information could cause harm to PG&E’s customers and put PG&E at an unfair business advantage by the disclosure of a GHG procurement strategy. This information could be used by other market participants to gain a commercial advantage. In addition, this information may reveal whether or not PG&E participated in California Air Resources Board (“CARB”) auctions and PG&E’s net open position for GHG compliance. Indefinite Information concerning GHG compliance instrument procurement strategy and/or activities. The release of this commercially sensitive information could cause harm to PG&E’s customers and put PG&E at an unfair business advantage by the disclosure of a GHG procurement strategy. This information could be used by other market participants to gain a commercial advantage. In addition, this information may reveal whether or not PG&E participated in California Air Resources Board (“CARB”) auctions and PG&E’s net open position for GHG compliance. Indefinite
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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
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