Details for: PGE Comments on Draft Resolution E-4998.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 14, 2019
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Subject:

Comments of Pacific Gas and Electric Company on Draft Resolution
E-4998

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) appreciates the opportunity to comment on
Draft Resolution E-4998 (the Draft Resolution) approving PG&E’s Modification to its
2014 Conformed Bundled Procurement Plan as described in Advice Letter (AL) 5473-E,
filed January 25, 2019.
PG&E’s Comment:
PG&E recommends and requests clarification to Ordering Paragraph 2(c) to address
the schedule of solicitations after 2019 under the multi-year framework adopted in D.1902-022. PG&E would like to revise Ordering Paragraph 2(c) to provide a time frame for
the schedule of solicitations which requires PG&E to annually publish its solicitation
schedules for the current and upcoming calendar years. PG&E believes that this time
frame for the schedule of solicitations will permit LSEs to plan accordingly for their
needs. With this clarification, PG&E will publish its solicitation schedule for 2019 and
2020 upon approval of the Draft Resolution. In 2020, pending resolution of Phase 2 of
(R.)17-06-026, the schedule of solicitations for 2020 and 2021 will be published, and so
on. Specifically, PG&E requests that Ordering Paragraph 2(c) be modified as follows:
Revise the RA solicitation schedule in Appendix S of the BPP, as applicable,
to account for the delayed effective date of this Resolution relative to certain
solicitation dates, to address solicitations after 2019, to account for Energy
Division’s provision of RA allocations (and credits) and for filing deadlines in
the RA program, and to incorporate sales of local RA capacity for delivery
periods covering all three years in the multiyear framework adopted in D.1902-022 by publishing solicitation schedules at least annually for the then current
and upcoming calendar years, pending resolution of Phase 2 of (R.)17-06-026.





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PG&E Comments on Draft Resolution E-4998 -2- May 14, 2019 Respectfully submitted, /S/ Erik Jacobson Director, Regulatory Relations Attachments Confidential Attachment A - PG&E Comments on Confidential Appendix A of Draft Resolution E-4998 Public Attachment B - Declaration of Vincent Loh seeking Confidential Treatment Pursuant to D.06-06-066, D.14-10-033, and Public Utilities Code §454.5(g) cc: Edward Randolph, Director, Energy Division Nick Dahlberg, Public Utilities Regulatory Analyst, Energy Division Michele Kito, Supervisor, Resource Adequacy and Procurement Oversight, Energy Division Service List R.16-02-007; Evelyn Kahl, Counsel, California Community Choice Association Julie Halligan, Program Manager, Public Advocates Office Kaj Peterson, Utilities Engineer, Public Advocates Office
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Comments on Draft Resolution E-4998 May 14, 2019 Confidential Attachment A PG&E Comments on Confidential Appendix A of Draft Resolution E-4998
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Comments on Draft Resolution E-4998 May 14, 2019 Attachment B Declaration of Vincent Loh seeking Confidential Treatment Pursuant to D.06-06-066, D.14-10-033, and Public Utilities Code §454.5(g)
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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA DECLARATION OF VINCENT LOH SEEKING CONFIDENTIAL TREAMENT FOR CERTAIN DATA AND INFORMATION CONTAINED IN PG&E'S COMMENTS ON DRAFT RESOLUTION E-4998 I, Vincent Loh, declare: 1. I am presently employed by Pacific Gas and Electric Company (PG&E) and have been an employee since 2003. I am a Senior Manager in the Portfolio Management group in the Energy Policy and Procurement organization and am responsible for leading commercial greenhouse gas policy and strategy. In carrying out these responsibilities, I have acquired knowledge of the California Air Resources Board's Cap and Trade Regulation and other programmatic measures to establish a market-based price for GHG emissions in order to manage PG&E's compliance with Cap and Trade Regulation, which became effective on January 1, 2012. 2. Based on my knowledge and experience, and in accordance with the Decisions 06-06-066, 08-04-023, 14-10-033, and relevant Commission rules, I make this declaration seeking confidential treatment for ce1iain data and information contained in PG&E's Comments on Draft Resolution E-4998 submitted on May 14, 2019. 3. Attached to this declaration is a matrix identifying the data and information for which PG&E is seeking confidential treatment. The matrix specifies that the material PG&E is seeking to protect constitutes confidential market sensitive data and information covered by Decisions 06-06-066, 08-04-023, 14-10-033, and/or relevant Commission rules. The matrix also specifies why confidential protection is justified. Fmiher, the data and infmmation: (1) is not already public; and (2) cannot be aggregated, redacted, summarized or otherwise protected in a way that allows partial disclosure. By this reference, I am incorporating into this declaration all of the explanatory text that is pe1iinent to my testimony in the attached matrix.
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I declare under penalty of peijury, under the laws of the State ofCalil'ornia, that the foregoing is true and coirect. Executed on May 14, 2019, at San Francisco, California. Qt. VINCENT LOH
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PACIFIC GAS AND ELECTRIC COMPANY (U 39 E) PG&E’S COMMENTS TO DRAFT RESOLUTION E-4998 May 14, 2019 IDENTIFICATION OF CONFIDENTIAL INFORMATION Redaction Reference Category from D.06-06066, Appendix 1, or Separate Confidentiality Order that Data Corresponds To Justification for Confidential Treatment Length of Time Date To Be Kept Confidential Document: PG&E’S Comments to Draft Resolution E-4998 PG&E’S Comments to Draft Resolution E-4998 redacted information on Pages 2, 3, and 4 D.14-10-033 Pub. Util. Code § 454.5(g) This information includes confidential greenhouse gas (GHG) compliance instrument procurement stategy and/or activities. The release of this commercially sensitive information could cause harm to PG&E’s customers and put PG&E at and unfair business advantage by the disclosure of a GHG procurement strategy. This information could be used by other market partciaptns to gain a commercial advantage. The disclosure of GHG information is prohibited according to Title 17 of the California Code of Regulations. Indefinite
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