Details for: 3931-E (Part 1 of 1).pdf

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

January 2, 2019
(U 338-E)

Financial Security Requirement Update for Clean Power
Alliance Phase 3

In compliance with Decision (D.)18-05-022, Southern California Edison Company (SCE)
hereby submits a report to update the financial security amount for Clean Power
Alliance (CPA), a Community Choice Aggregator (CCA), to reflect a new phase (i.e.,
phase 3) of its mass enrollment, which is scheduled to occur on February 1, 2019.
Attached hereto is the report revising the financial security requirement for CPA
(Attachment A) and the associated confidentiality declaration (Attachment B).
This advice letter provides the updated CCA finanical security amount for CPA
calculated pursuant to the CCA financial security requirements adopted in D.18-05-022
and implemented in SCE’s Rule 23 as modified in Advice 3840-E, which was submitted
August 15, 2018, and is pending Commission approval.
On June 7, 2018, the Commission issued D.18-05-022, establishing the methods for
calculating re-entry fees and financial security amounts and otherwise implementing the
financial security requirements applicable to CCAs pursuant to Section 394.25(e). A
minimum CCA financial security amount of $147,000 was also established.1 On August
15, 2018, SCE submitted Advice 3839-E providing each active CCA within SCE’s
territory with the calculation for its respective financial security amount, pursuant to


See D.18-05-022, OP 9.
Advice 3839-E was approved by the Commission on September 14, 2018.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

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


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ADVICE 3931-E (U 338-E) -2- January 2, 2019 Additionally, SCE submitted Advice 3840-E on August 15, 2018, revising SCE Schedule CCA-SF, Community Choice Aggregation Service Fees, and Rule 23, Community Choice Aggregation, to implement the financial security requirements and re-entry fees applicable to CCA programs in compliance with D.18-05-022. SCE’s updates to Rule 23 established that for a new phase of an existing CCA’s service, “SCE will submit the initial financial security calculation and amount in a Tier 2 advice letter filing for CPUC Energy Division’s approval thirty (30) days prior to the start date of the new CCA’s or new phase’s Mass Enrollment.”3 The CCA financial security amounts shown in this advice letter include the new phase of CPA’s service, which is to occur on February 1, 2019, and the existing load that CPA currently serves. The updated security amount was calculated consistent with the revisions to SCE’s Rule 23 in Advice 3840-E, which implements D.18-05-022.4 This advice letter will not increase any rate or change, cause the withdrawal of service, or conflict with any other schedule or rule. CONFIDENTIALITY PROTECTION Attachment A to this advice letter contains confidential material that is subject to the protections adopted in D.16-08-024 and D.06-06-066. Attachment A is submitted to the Commission confidentially with a declaration from a subject matter expert with delegated authority from an officer pursuant to D.16-08-024 and D.06-06-066. This declaration is submitted as Attachment B to this advice letter. Attachment A is removed from the public version of this advice letter. SCE is providing by electronic means to CPA a copy of its relevant confidential financial security requirement data. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.2, this advice letter is submitted with a Tier 2 designation. 3 In response, the California Community Choice Association (CalCCA) submitted a protest on September 4, 2018, and the Commission suspended the Advice 3840-E on September 13, 2018.
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ADVICE 3931-E (U 338-E) -3- January 2, 2019 EFFECTIVE DATE This advice letter will become effective on February 1, 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: 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: 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: 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 GO 96-B, SCE is serving copies of this Advice Letter to the interested parties on SCE’s GO 96-B and R.03-10-003 service lists.
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ADVICE 3931-E (U 338-E) -4- January 2, 2019 Address change requests to the GO 96-B service list should be directed by electronic mail to or (626) 302-4039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at 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 For questions, please contact Melodee Black at (626) 302-4728 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:mb:jm Enclosures
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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: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 3931-E Subject of AL: Financial Security Requirement Update for Clean Power Alliance Phase 3 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 18-05-022 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: See Attachment B 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: Janet Combs at or telephone (626) 302-1524 Resolution required? Yes No Requested effective date: 2/1/19 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: 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: 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: 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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ATTACHMENT A Details the updated calculations for the financial security amount for each CCA [OMITTED IN THE PUBLIC VERSION OF THIS ADVICE FILING]
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ATTACHMENT B Confidentiality Declaration
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DECLARATION OF JOANNE TRAN REGARDING THE CONFIDENTIALITY OF CERTAIN DATA 1, Joanne Tran, declare and state: 1. I am Director at Southem California Edison (SCE). Tres Petmeclcy, Senior Vice President and Officer, delegated authority to inc to sign this declaration. have responsibility for and reviewing the CPA Financial Security Requirement calculation updates. 2. I am making this declaration in accoidancc with the instructions set forth in Decision D.06~06-066 (as modified by D.O7-05-032). which governs the submission of confidential, market-sensitive procurement information to the Commission, and Decisions l6-()8~O24 and 17-09-O23, which govem the submission of all other confidential documents to the Commission. 3. Ihave personal knowledge of the facts and representations herein and, if called upon to testify, could and would do so, except for those facts expressly stated to be based upon inforrnalion and belief. and as to those matters, I believe them to be true. 4. Listed below are the data for wliich SCH is seeking confidential protection and the basis tor SCE's confidentiality request. Description of Limitations on A fo i Information “mt ii Confidentiality Ww A__ jpccificd in Matrix CCA I-'SR bl) Average and Off» The Average 011- and Off- Peak N/A Version Peak Prices Erom Prices are proprietary to ICE and Data shaded in _i;n:_v available only through a paid subscription with ICE. Intercontinental Exchange (ICE) SCE has obtained the written consent of ICE to provide its proprietary price data to the CPUC solely for purposes of verifying the accuracy of the CCA FSR calculation and its compliance with 7227. consent is
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Description of Limitations on Location of Basis for SCE’s Cionfidcntial Data Infgxiigglifia? 15 Confidentiality Claim SE effective through 2019, after A__ SCE must il lD ICE. _l CCA FSR ED CCA-Specil Forecast D.06~06-066 as modified by Front three years of Ver§io]1 and Off-Peak D.07~05~032), Mau-ix Appendix forecast data is Energy and Peak Demand Categories and (which confidential. Dam shaded protects similar ESP data). I Mo, ldeclarc under penalty ofpexjury under the laws of the State of California that the foregoing is true and correct. Executed on January 2, 2019 at Rosemead. California. Joann an
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