Details for: 3999-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)

Electric Service Provider Financial Security Requirement
Reports for May 2019

In compliance with Decision (D.)13-01-021, Southern California Edison Company (SCE)
hereby submits reports to update the financial security amounts for Electric Service
Providers (ESPs). Attached hereto are the updated financial security requirement for
ESPs reports (Attachment A), the ESP assumptions report (Attachment B), and the
associated confidentiality declarations (Attachment C).
This advice letter provides the California Public Utilities Commission (Commission) with
the updated ESP finanical security amount as required by Ordering Paragraph (OP) 6 of
In OP 10 of D.13-01-021, as corrected by D.13-04-001 and D.13-02-017, the
Commission adopted the methods1 for calculating ESP financial security and re-entry
fee amounts to cover incremental procurement cost requirements for Direct Access
(DA) customers who are involuntarily returned to SCE service. The financial security
and re-entry fee requirements are applicable to ESPs who provide service to DA
customers with demands of less than 20 kilowatts (kW) and who are not affiliated with a
larger customer who has demand of 20 kW or more.
Advice 2903-E was filed on May 24, 2013, to establish the ESP financial security
requirement. OP 6 of D.13-01-021 ordered the Investor-Owned Utilities (IOUs)2 to

See D.13-01-021, Appendix 1.
SCE, Pacific Gas and Electric Company, and San Diego Gas & Electric Company

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

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


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ADVICE 3999-E (U 338-E) -2- May 10, 2019 update by the 10th of May and November of each year the applicable ESP financial security amount via a Tier 2 Advice Letter. Per D.13-01-021, the required financial security amount for each ESP is the higher amount of the calculation set forth in Attachment A3 or the deposit required in D.99-05-034 for ESP registration pursuant to Public Utilities Code Section 394(b)(9). The Energy Division determines which amount is higher and ensures the appropriate financial security amount is secured from each ESP. 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 Attachments A and B to this advice letter contain confidential material that is subject to the protections adopted in D.16-08-024, D.17-09-023 and D.06-06-066. Attachments A and B are 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, D.17-09-023 and D.06-06-066. This declaration is submitted as Attachment C to this advice letter. Any confidential data relating to an ESP is removed from the public version of this advice letter. SCE is providing by electronic means to each ESP a copy of its relevant confidential financial security requirement data. TIER DESIGNATION Pursuant to D.13-01-021, OP 6, this advice letter is submitted with a Tier 2 designation. 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: 3 Individual ESP calculation results are confidential, and are therefore omitted from the public version of this advice letter submission.
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ADVICE 3999-E (U 338-E) -3- May 10, 2019 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.07-05-025 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
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ADVICE 3999-E (U 338-E) -4- May 10, 2019 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) #: 3999-E Subject of AL: Electric Service Provider 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 13-01-021 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 C 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 ESP [OMITTED IN THE PUBLIC VERSION OF THIS ADVICE FILING]
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ATTACHMENT B Details the assumptions used in the calculations for the updated financial security amount for each ESP [OMITTED IN THE PUBLIC VERSION OF THIS ADVICE FILING]
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ATTACHMENT C Confidentiality Declaration
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DECLARATION OF NATALIA VVOODVVARD REGARDING THE CONFIDENTIALITY OF CERTAIN DATA 1, Natalia Woodward, declare and state: I. I am Director at Soutlicm Edison (SCE). Dan Wood, Vice President and Treasurer. delegated authority to me to sign this I have responsibility for and reviewing the Energy Service Provider (ESP) Financial Security Requirement (FSR) calculation updates for May 2019. 2. I am making this declaration in accordance with the instructions set forth in Decision D.06-06-066 (as modified by D.07-O5-032). which governs the submission of marketvsensitivc to the oinniission, and Decisions 1608-024 and 17-09-O23, which govern the submission ofall other confidential documents to the Conimission. 3. I have personal knowledge ofthe 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 and belief. £ll1Ll as to those matters, I believe them to be true. 4. Listed helow are the data for which SCE is seeking confidential protection and the basis for SCE‘s request and the categories oftlie .\/latrix of Allowed Confidential Treatment Investor Owned Utility Data (Matrix Category) appended to D.06-06-066 to which these data Limitations on Confidentiality Spscififii /A. Lomfion of i Description of Canfidential Dam Information that is i Confidential Attachment A Average On- and Off-Peak CONFDDENTLAL Forward Price: DA Sccurity Miiy Prices I Adders Inputs. Basis for SCE’s Confidentiality Claim The Average On- and Off! Peak Prices are proprietary to Platts and available only through a paid with Plans ESPI, IZSP2. ESP3, ESP4, esrs, ESP6, lESP7
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Location of Confidential Data Attachment CONFIDENTLAL ESP Assumptions May 201 9.xlsx Fwd Prices Data shaded in grey Description of Information that is Confidential Basis for SCE’s Confidentiality Claim Attachment A CONFIDENTIAL DA Security May 20l9.xlsm Prices Adders Inputs, ESP] FSP2, ESP1 ESP4. ESP5, FSP6, BS1-‘7 Attachment CONFIDFNTIAL l- SP Assumptions May 20l9.x11x ESP Load Dntn shaded 111 011- and Oil~Peal-1 ESP-Specific Forecast emand 06-06-066 as modified by 07-05-032), Matrix Appendix Categories lIl.Fl 211111 lll.C (which protects similar ESP data) Limitatiimsflonu Confidentiality ecified in Matrix Front three years of forecast data is cmitidcntial. I declare under penalty of perjury under the laws of the State ofCalifom1a that the foregoing is true and correct. Executed on May 8, 2019 at Roscmcad, Califomiat
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