Details for: PGE AL 5542-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

May 10, 2019

Advice 5542-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

Subject:

Submittal of Community Choice Aggregator (CCA) Financial Security
Requirements in Compliance with D.18-05-022

Pacific Gas and Electric Company (PG&E) hereby submits its calculation of the
financial security requirements for the Community Choice Aggregators (CCAs) serving
customers within its service territory.
Purpose
In compliance with Ordering Paragraph (OP) 6 of Decision (D.) 18-05-022, this advice
submittal is to provide the California Public Utilities Commission (CPUC or Commission)
with the calculated financial security requirements for Community Choice Aggregators
serving customers within its service territory.
Background
On May 31, 2018, the Commission issued D.18-05-022 which established a
methodology to derive incremental procurement costs for the financial security
requirement and re-entry fees for an involuntary return of Community Choice
Aggregation Service customers.
On August 6, 2018, PG&E submitted Advice 5350-E with its initial calculation of the
FSR amount for each CCA serving customers in PG&E’s service area. Advice 5350-E
was approved by the Commission on September 14, 2018 with an effective date of
September 13, 2018.
In Advice 5354-E submitted on August 15, 2018, PG&E requested approval to revise
PG&E Electric Rule 23, Community Choice Aggregation Service, to incorporate the
reentry fees and financial security requirements and calculation methodology into
PG&E’s Community Choice Aggregation Service tariffs. On September 4, 2018, the
Alliance the Alliance for Retail Energy Markets (AReM) submitted a protest to Advice





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Advice 5542-E -2- May 10, 2019 5354-E objecting that D.18-05-022 “does not involve direct access (“DA”) customers or suppliers” and identified four revisions which “have a, perhaps inadvertent effect on direct access that should be remedied….”1 California Community Choice Association (CalCCA) also submitted a protest on September 4, 2018, raising a number of objections, including the “deletion of “certain provisions relating to the rights of DAeligible customers (“DA Provisions”).”2 On October 2, 2018, PG&E submitted Advice 5354-E-A to request further revisions to PG&E’s Electric Rule 23, Community Choice Aggregation Service, to resolve AReM and CalCCA’s Protest of Advice 5354-E. OP 8 of D.18-05-022 states: The amount of the applicable financial security requirement is to be updated twice each year, with a 10% deadband, consistent with the method adopted for electric service providers in Decision 13-01-021. Consistent with OP 6 of D.13-01-021, the investor owned utilities are required to update the applicable financial security amounts by the 10 th of May and November of each year and to submit them in a Tier 2 Advice Letter. Attachment B contains a table showing, by CCA, the calculated financial security amount based upon the methodology adopted in D.18-05-022 and submitted for Commission approval in Advice 5354-E and Advice 5354-E-A. If the Commission directs otherwise, PG&E will recalculate the FSR amounts consistent with the Commission’s direction and submit the updated FSR amounts for Commission approval. The table has been redacted of any confidential CCA information. An unredacted version with the relevant supporting data and calculation of each respective CCA’s financial security amount is included in Confidential Attachment C. A declaration supporting confidential treatment is found in Attachment A. Concurrent with submitting this advice letter to the Energy Division, PG&E will serve by electronic means on each applicable CCA a copy of this advice letter, with the relevant supporting data, redacted of any third party proprietary information, and the calculation of each respective CCA’s FSR amount provided confidentially only to that specific CCA. The version of this advice letter posted at www.pge.com is redacted. Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or E-mail, no later than May 30, 2019, which is 20 days after the date of this filing. Protests must be submitted to: 1 Alliance for Retail Energy Markets Protest Of Pacific Gas & Electric Advice Letter 5354-E, dated September 4, 2018, p. 1 2 California Community Choice Association Protest Of Pacific Gas & Electric Advice Letter 5354-E, dated September 4, 2018, p. 6
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Advice 5542-E -3- May 10, 2019 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 Pursuant to OP 6 of D.13-01-021, this advice letter is submitted with a Tier 2 designation. PG&E requests that this Tier 2 advice letter become effective June 9, 2019, which is 30 calendar days after the date of submittal.
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Advice 5542-E -4- May 10, 2019 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.03-10-003. 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 PGETariffs@pge.com. Advice letter filings can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations cc: Service List R.03-10-003 Attachments: Public Attachment A – Declaration of David Gutierrez Supporting Confidential Treatment Public Attachment B – Summary of CCA Financial Security Requirements Confidential Attachment C - Summary of CCA Financial Security Requirements and Underlying Calculations
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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: QXY1@pge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 5542-E Subject of AL: Submittal of Community Choice Aggregator (CCA) Financial Security Requirements in Compliance with D.18-05-022 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.18-05-022 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 See attached declaration that identifies the confidential informati David Gutierrez, (415) 257-3285 Yes ✔ No 6/9/19 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: N/A 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 5542-E May 10, 2019 Public Attachment A Declaration of David Gutierrez Supporting Confidential Treatment
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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA DECLARATION SUPPORTING CONFIDENTIAL DESIGNATION ON BEHALF OF PACIFIC GAS AND ELECTRIC COMPANY (U 39 E) 1. I, David Gutierrez, am a Senior Manager in Community Vitality for Pacific Gas and Electric Company (“PG&E”), a California corporation. Deb Affonsa, the Vice President, Customer Service, of PG&E, delegated authority to me to sign this declaration. My business office is located at: Pacific Gas and Electric Company 245 Market Street San Francisco, CA 94105 2. PG&E will produce the information identified in paragraph 3 of this Declaration to the California Public Utilities Commission (“CPUC”) or departments within or contractors retained by the CPUC in response to a CPUC audit, data request, proceeding, or other CPUC request. Name or Docket No. of CPUC Proceeding (if applicable): R.03-10-003 3. Title and description of document(s): Advice Letter 5542-E, Community Choice Aggregator’ (CCA) Finanical Security Requirement s and the Underlying Calculations. 4. These documents contain confidential information that, based on my information and belief, has not been publicly disclosed. These documents have been marked as confidential, and the basis for confidential treatment and where the confidential information is located on the documents are identified on the following chart: PG&E Confidentiality Declaration (Rev 01/02/2018) 1
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Check X Basis for Confidential Treatment Customer-specific data, which may include demand, loads, names, addresses, and billing data (Protected under PUC § 8380; Civ. Code §§ 1798 et seq.; Govt. Code § 6254; Public Util. Code § 8380; Decisions (D.) 14-05-016, 04-08-055, 06-12-029) Where Confidential Information is located on the documents Attachment C: CCA Load Forecast On-Peak (MWh), OffPeak (MWh), Monthly Peak Demand (MW), Forecast CCA Number of Service Accounts (SA) included in Calculations and Final Calculation Amounts. Personal information that identifies or describes an individual (including employees), which may include home address or phone number; SSN, driver’s license, or passport numbers; education; financial matters; medical or employment history (not including PG&E job titles); and statements attributed to the individual (Protected under Civ. Code §§ 1798 et seq.; Govt. Code § 6254; 42 U.S.C. § 1320d-6; and General Order (G.O.) 77M) Physical facility, cyber-security sensitive, or critical energy infrastructure data, including without limitation critical energy infrastructure information (CEII) as defined by the regulations of the Federal Energy Regulatory Commission at 18 C.F.R. § 388.113 (Protected under Govt. Code § 6254(k), (ab); 6 U.S.C. § 131; 6 CFR § 29.2) X Proprietary and trade secret information or other intellectual property and protected market sensitive/competitive data (Protected under Civ. Code §§3426 et seq.; Govt. Code §§ 6254, et seq., e.g., 6254(e), 6254(k), 6254.15; Govt. Code § 6276.44; Evid. Code §1060; D.11-01-036) Corporate financial records (Protected under Govt. Code §§ 6254(k), 6254.15) Third-Party information subject to non-disclosure or confidentiality agreements or obligations PG&E Confidentiality Declaration (Rev 01/02/2018) 2 Attachment C: ICE Average Off-Peak and On-Peak Forward Price Information included in Calcalutions and Final Calculation Amounts.
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(Protected under Govt. Code § 6254(k); see, e.g., CPUC D.11-01-036), ESP Service Agreement Form 79-948 Section 11 Other categories where disclosure would be against the public interest (Govt. Code § 6255(a)) _________________________________________________ _________________________________________________ _________________________________________________ 5. The importance of maintaining the confidentiality of this information outweighs any public interest in disclosure of this information. This information should be exempt from the public disclosure requirements under the Public Records Act and should be withheld from disclosure. 6. I declare under penalty of perjury that the foregoing is true, correct, and complete to the best of my knowledge. 7. Executed on this 10th day of May, 2019 at San Francisco, California. /s/ David Gutierrez__________________ David Gutierrez Senior Manager, Community Vitality Pacific Gas and Electric Company PG&E Confidentiality Declaration (Rev 01/02/2018) 3
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Advice 5542-E May 10, 2019 Public Attachment B Summary of CCA Financial Security Requirements
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ATTACHMENT B Summary of CCA Financial Security Requirements Public Version CCA FINANCIAL SECURITY REQUIREMENT Pacific Gas and Electric Company Advice 5542-E May 10, 2019 Community Choice Aggregator City of King City Clean Power SF East Bay Community Energy Marin Clean Energy Monterey Bay Community Power Peninsula Clean Energy Pioneer Community Energy Redwood Coast Energy Authority San Jose Clean Energy Silicon Valley Clean Energy Sonoma Clean Power Valley Clean Energy Total Financial Security
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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. P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Cameron-Daniel, P.C. 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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