Details for: 3998-E (Part 1 of 1).pdf

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

May 10, 2019
(U 338-E)

Community Choice Aggregator Financial Security Requirement
Reports for May 2019

In compliance with Decision (D.)18-05-022, Southern California Edison Company (SCE)
hereby submits reports to update the financial security amounts for Community Choice
Aggregators (CCAs). Attached hereto are the reports updating the financial security
requirement for each active CCA in SCE’s territory (Attachment A) and the associated
confidentiality declaration (Attachment B).
This advice letter provides the updated CCA finanical security amounts calculated
pursuant to the CCA financial security requirements (FSR) 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 suspended September 13, 2018.
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 Public Utilities Code
Section 394.25(e). A minimum CCA financial security amount of $147,000 was also
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 D.18-05-022. SCE also affirmed in Advice 3839-E that “[t]he CCA financial security
amounts will be recalculated on the regular bi-annual schedule adopted in D.18-05-022

See D.18-05-022, Ordering Paragraph (OP) 9.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

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


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ADVICE 3998-E (U 338-E) -2- May 10, 2019 and submitted with the Commission starting in November 2018.” The Commission approved Advice 3839-E on September 14, 2018. Additionally, SCE submitted Advice 3840-E on August 15, 2018. Advice 3840-E revised SCE’s 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. The Commission suspended the Advice 3840-E on September 13, 2018. On November 13, 2018, SCE submitted Advice 3889-E providing its bi-annual CCA Financial Security Report update. Advice 3889-E was suspended by the Commission on December 13, 2018. The CCA financial security amounts shown in this advice letter were calculated consistent with the revisions to SCE’s Rule 23 in Advice 3840-E, which implements D.18-05-022.2 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, D.17-09-023 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.06-06066. 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 each CCA 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.
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ADVICE 3998-E (U 338-E) -3- May 10, 2019 EFFECTIVE DATE This advice letter will become effective on June 9, 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, R.03-10-003, R.12-06-013,
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ADVICE 3998-E (U 338-E) -4- May 10, 2019 R.17-06-026, R.16-02-007, and R.17-09-020 service lists. 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 Masooma Tirmazi at (626) 302-1769 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:mt: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) #: 3998-E Subject of AL: Community Choice Aggregator Financial Security Requirement Reports for May 2019 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 via email or (626) 302-1524 Resolution required? Yes No Requested effective date: 6/9/19 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 NATALIA WOODWARD REGARDING THE CONFIDENTIALITY OF CERTAIN DATA 1. Natalia Woodward declare and state: 1. I am a Director at Soutlicrn California Edison Company (SCE). Dun Wood, Vice President and Treasurer, has delegated inc authority to sign this declaration. Ilizive responsibility for and reviewing the Community Choice Aggregation (CCA) Financial Security Requirement (FSR) calculation updates. 2. am making this declaration in accordance with the set forth in Decision D06-06-O66 (as modified by D.07—05-O32). which guvems the submission of confidential. market-sensitive procurement information to the Commission, and Decisions l6-08-024 and 17-09-023. which govern the submission ofall other confidential documents to the Cornmissinn. 3. have personal knowledge ofthc facts and representations herein and, ilicallcd upon to testify, could and would do :0. except for those expressly stated to be based upon infonnation and belief, and as to those matters, I believe them to be true. 4. Listed below are the data for which SCE is seeking confidential protection and the basis for SCE‘s request. Location of Description of Basis for SCE’s Confidential Data Information that Confidentiality Claim is Confidential Confidential CCA Average On- and The Average On- and Off- Off- Peak Forward Peak Prices are proprietary Slicet Ma 2019 Prices from to ICE and available onl ecitied in Matrix N/A. M’
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Location nf (in (if Basis for S(,‘E’i Confidential Data information that Confidentiality Claim is Confidential Filing A CCA FSR Intercontinental ED Versiun Exulizingc (ICE) Vltiiniitiatiuns on ecifigiirin Matrix through a paid subscription with ICE Data shaded in grey. SCb has nbtamed ilie written consent oflCl: to provide its proprietary‘ price data in the CPUC snlelyfoi purpmes (ii i verifying the of the CCA FSR calculation and its compliance with i 18-03-022. ICE‘s I consent is effective I i through 3019, after which SCE must renew its is ties! to [CE. H» 06 06 066 as modified Front three years of C(ll1ii(L|]l|:ti (‘CA 07 Sheet May 2019 Filing CCA FSR Energy and Peak lll.B and ED Version Demand. (which protects similar ESP data) Data iliaded in .9r9-13,6-, I declare under penalty (1fpel]lJI‘_V under the laws oftlie State ofCalifornia that the 2), Matrix forecast data is foregoing, is true and current. Executed on May 08, 2019 at Roscnicad, Calilbmia. '\,ev/1&2 {A QR: Liu I». Woodward
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