Details for: 3955-E-A (Part 1 of 1).pdf


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

April 5, 2019
ADVICE 3955-E-A
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
SUBJECT:

Supplement to Advice 3955-E, Establishment of the Tree
Mortality Non-Bypassable Charge Balancing Account, Design
of the Tree Mortality Non-Bypassable Charge, and Southern
California Edison Company’s Proposed Tree Mortality
Resource Adequacy Sales Framework

PURPOSE
The purpose of this supplemental advice letter is to remove any language in Advice
3955-E that states that Southern California Edison Company (SCE) will establish a
reservation price for the sale of Renewable Energy Credits (RECs).
These changes are made in accordance with Decision (D.)19-02-007, dated February
28, 2019, which required that the Investor Owned Utilities (IOUs)1 sell any RECs
resulting from BioRAM contracts or to value them at a value of $0 if the RECs could not
be sold.2 This advice letter supplements, in part, but changes only the substance of the
original Advice 3955-E as necessary to conform it with D.19-02-007.
DISCUSSION
On page 4 of Advice 3955-E, SCE provided a description of its process to establish the
value of the Tree Mortality RECs and Resource Adequacy (RA). After SCE submitted
Advice 3955-E, the California Public Utilities Commission (Commission) issued D.1902-007 that clarified that SCE would not be allowed to set a reservation price for the
sale of RECs generated by SCE’s BioRAM facilities during SCE’s BioRAM REC sale
auctions3.

1
2
3

The IOUs are: SCE, Pacific Gas and Electric Company (PG&E), and San Diego Gas &
Electric Company (SDG&E)
D.19-02-007, at pages 108-109
Id





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ADVICE 3955-E-A (U 338-E) -2- April 5, 2019 SCE provides herein Attachments A and B which revise page 4 of its Advice 3955-E that removes any reference to establishing a reservation price for BioRAM RECs in order to comply with D.19-02-007. SUMMARY OF APPENDICES Attachment A: Redline Replacement of Advice 3955-E, Page 4 Attachment B: Clean Replacement of Advice 3955-E, Page 4 TIER DESIGNATION Pursuant to Ordering Paragraph 12 of the Decision, this Advice Letter is submitted with a Tier 2 designation, which is the same Tier designation as the original advice letter, Advice 3955-E. EFFECTIVE DATE SCE respectfully requests that this Advice Letter be effective January 1, 2019, which is the same day as was requested by the original advice letter, Advice 3955-E. PROTESTS SCE asks that the Commission, pursuant to GO 96-B and General Rule 7.5.1, maintain the original protest period designated in Advice 3955-E and not reopen the protest period. The modifications included in this supplemental advice letter do not make substantive changes that would affect the overall evaluation of the advice letter. NOTICE In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and A.16-11-005 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) 302-4039. 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.
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ADVICE 3955-E-A (U 338-E) -3- April 5, 2019 For questions, please contact Desiree Wong at (626) 302-1421 or by electronic mail at Desiree.Wong@sce.com. Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:dw:jm Enclosures
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Attachment A
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ADVICE 3955-E-A (U 338-E) -4- April 5, 2019 the billed PPP revenues will be allocated to PPPAM, and 12.5% will be allocated to TMNBCBA.5 TM RA and REC Values Pursuant to the Decision, SCE will make available for sale the RECs and RA capacity from the TM Contracts. The revenues received from those sales will be directly credited to the TMNBCBA. As described in Section 4 below, SCE will submit a reservation price in every one of its future TM RA capacity solicitations. SCE will similarly submit a reservation price in every one of its future TM REC solicitations. As such, no RA or RECs will be “unsold” going forward because, under SCE’s proposed sales frameworks, SCE will have submitted a reservation price “bid” in each of its TM RA solicitations.6 There will thus be no $0 values recorded in the TMNBCBA for RA (because there will be no unsold RA), and no need to use benchmark values going forward. Pursuant to D.19-02-007, SCE will not submit a reservation price in its future TM REC solicitations. TM RECs that are offered for sale as PCC1 RECs but are not sold will not be used for compliance purposes by any load serving entity. Consistent with OP 3 of the Decision, the value of those unsold TM RECs will be $0, and $0 revenue will be credited to the TMNBCBA. The REC benchmark will be used, except as noted below for RECs generated prior to the date that energy and PCC1 RECs are first sold under the first REC sales contract.7 2. Approval and Cost Recovery of the TM Net Costs Incurred Prior to the Establishment of the TMNBCBA In this section, SCE sets forth for Energy Division review the operation of the BioMass memorandum account (BioMASSMA) and the BioRAM memorandum account (BioRAMMA),9 and approval of the costs recorded in those accounts as of December 31, 2018. SCE requests that Energy Division find that SCE has appropriately operated these memorandum accounts, and that its recorded 5 6 7 8 The same process has historically been used to allocate bundled service generation revenues to the Energy Resource Recovery Account (ERRA) and the generation subaccount of the Base Revenue Requirement Balancing Account (BRRBA). See Preliminary Statement ZZ. In other words, SCE will receive sales revenues for every future TM REC and RA capacity solicitation—either from a counterparty or from SCE’s bundled service customers. The TMNBCBA will include a one-time credit entry to account for the value of all RECs generated prior to the first sale of PCC1 RECs under the REC sales contract. SCE submitted AL 3497-E-A on November 10, 2016 to establish the BioMASSMA and BioRAMMA pursuant to Resolution E-4805. The Energy Division approved AL 3497-E-A on December 15, 2016. Contracts Rio Bravo Rocklin and Rio Bravo Fresno record in BioMASSMA. Contract Pacific Ultrapower Chinese Station records in BioRAMMA.
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ADVICE 3955-E-A (U 338-E) - 4A - April 5, 2019 entries are appropriate, correctly stated, and in compliance with Commission decisions. In accordance with OP 9b of the Decision, SCE will transfer the 2018 year-end balances in the BioRAMMA and BioMASSMA to the TMNBCBA upon approval of this Advice Letter. As described below, SCE will seek recovery of
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Attachment B
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ADVICE 3955-E-A (U 338-E) -4- April 5, 2019 the billed PPP revenues will be allocated to PPPAM, and 12.5% will be allocated to TMNBCBA.5 TM RA and REC Values Pursuant to the Decision, SCE will make available for sale the RECs and RA capacity from the TM Contracts. The revenues received from those sales will be directly credited to the TMNBCBA. As described in Section 4 below, SCE will submit a reservation price in every one of its future TM RA capacity solicitations. As such, no RA will be “unsold” going forward because, under SCE’s proposed sales frameworks, SCE will have submitted a reservation price “bid” in each of its TM RA solicitations.6 There will thus be no $0 values recorded in the TMNBCBA for RA (because there will be no unsold RA), and no need to use benchmark values going forward. Pursuant to D.19-02-007, SCE will not submit a reservation price in its future TM REC solicitations. TM RECs that are offered for sale as PCC1 RECs but are not sold will not be used for compliance purposes by any load serving entity. Consistent with OP 3 of the Decision, the value of those unsold TM RECs will be $0, and $0 revenue will be credited to the TMNBCBA. The REC benchmark will be used as noted below for RECs generated prior to the date that energy and PCC1 RECs are first sold under the first REC sales contract.7 2. Approval and Cost Recovery of the TM Net Costs Incurred Prior to the Establishment of the TMNBCBA In this section, SCE sets forth for Energy Division review the operation of the BioMass memorandum account (BioMASSMA) and the BioRAM memorandum account (BioRAMMA),8 and approval of the costs recorded in those accounts as of December 31, 2018. SCE requests that Energy Division find that SCE has appropriately operated these memorandum accounts, and that its recorded entries are appropriate, correctly stated, and in compliance with Commission decisions. In accordance with OP 9b of the Decision, SCE will transfer the 2018 5 6 7 8 The same process has historically been used to allocate bundled service generation revenues to the Energy Resource Recovery Account (ERRA) and the generation subaccount of the Base Revenue Requirement Balancing Account (BRRBA). See Preliminary Statement ZZ. In other words, SCE will receive sales revenues for every future TM RA capacity solicitation—either from a counterparty or from SCE’s bundled service customers. The TMNBCBA will include a one-time credit entry to account for the value of all RECs generated prior to the first sale of PCC1 RECs under the REC sales contract. SCE submitted AL 3497-E-A on November 10, 2016 to establish the BioMASSMA and BioRAMMA pursuant to Resolution E-4805. The Energy Division approved AL 3497-E-A on December 15, 2016. Contracts Rio Bravo Rocklin and Rio Bravo Fresno record in BioMASSMA. Contract Pacific Ultrapower Chinese Station records in BioRAMMA.
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ADVICE 3955-E-A (U 338-E) - 4A - April 5, 2019 year-end balances in the BioRAMMA and BioMASSMA to the TMNBCBA upon approval of this Advice Letter. As described below, SCE will seek recovery of
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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) #: 3955-E-A Subject of AL: Supplement to Advice 3955-E, Mortality Non-Bypassable Charge, and Southern California Edison Company's Proposed Tree Mortality Resource Adequacy Sales Framework (No protest period) 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 19-02-007 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: 1/1/19 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: 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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