Details for: PGE AL 5556-E.pdf

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Erik Jacobson
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

June 7, 2019

Advice 5556-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

Review Tree Mortality Costs Recorded to the Memorandum Accounts
for February – May 2019

The purpose of this advice letter is to submit entries made to Pacific Gas and Electric
Company’s (PG&E) Biomass Renewable Auction Mechanism (BioRAM) Memorandum
Account (BioRAMMA) and Senate Bill 859 Biomass Memorandum Account
(BioMASSMA) for the months February – May, 2019, consistent with PG&E’s request in
Advice Letter (AL) 5478-E to submit incremental monthly memo account entries made
after January 2019 to the California Public Utilities Commission (Commission or CPUC)
for review through a Tier 1 Advice Letter.1 In addition, this advice letter provides the final
net costs that will be transferred from the BioRAMMA and BioMASSMA to the new Tree
Mortality Non-bypassable Charge Balancing Account (TMNBCBA) during PG&E’s June
2019 accounting close. 2
PG&E submitted AL 5478-E on February 19, 2019, requesting, among other things, that
the Commission approve a new TMNBCBA and approve the transfer amounts recorded
to the existing BioRAMMA and BioMASSMA to the TMNBCBA once it completed the
review and approval of the memo account entries.
On May 23, 2019, the Commission approved PG&E’s request in AL 5478-E which
included the review and approval of costs recorded to the BioRAMMA and BioMASSMA


Advice Letter 5478-E was approved on May 23, 2019 with an effective date of March 21,
Advice Letter 5478-E, page 5, PG&E proposed to submit the additional memo account
monthly entries along with the final net costs to be transferred to the TMNBCBA in a Tier 1
advice letter, 15 days after the approval of 5478-E.


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Advice 5556-E -2- June 7, 2019 through January 2019.3 As PG&E indicated in its advice letter, there would be additional monthly entries to the memo accounts after January that would be transferred to the new TMNBCBA and that PG&E would submit these memo account monthly entries and the final net costs to be transferred to the TMNBCBA in a Tier 1 advice letter within 15 days of the approval of AL 5478-E. BioRAMMA and BioMASSMA Entries for February – May 2019 The BioMASSMA and BioRAMMA memo account entries for the months February – May of 2019 are shown in detailed subledgers and supporting workpapers for both the BioMASSMA and the BioRAMMA, which are included as confidential Appendix A to the Advice Letter. A summary table of the entries recorded in the memo accounts between February and May of 2019 is shown in Table 1 and Table 2 below. TABLE 1 BIORAM MEMO ACCOUNT ENTRIES FEBRUARY 1, 2019 – MAY 31, 2019 Activity thru Jan-19* Description BioRAMMA Monthly Activity $ 10,283,838 Interest Feb-19 $ 225,094 Mar-19 $ 608,317 Apr-19 $ 752,063 May-19 $ 875,159 155,511 22,423 22,806 24,265 25,795 10,439,349 10,439,349 10,686,866 11,317,989 12,094,317 BioRAMMA Ending Balance $ 10,439,349 $ 10,686,866 * Activity through January 2019 was presented in Advice Letter 5478-E $ 11,317,989 $ 12,094,317 $ 12,995,271 Apr-19 May-19 287,006 $ 2,103,748 $ 2,363,789 BioRAMMA Beginning Balance TABLE 2 BIOMASS MEMO ACCOUNT ENTRIES FEBRUARY 1, 2019 – MAY 31, 2019 Activity thru Jan-19* Feb-19 $ 31,168,582 $ 1,750,272 404,106 68,952 69,586 72,211 76,377 31,572,689 33,391,913 33,748,505 35,924,464 BioMASSMA Ending Balance $ 31,572,689 $ 33,391,913 * Activity through January 2019 was presented in Advice Letter 5478-E $ 33,748,505 $ 35,924,464 $ 38,364,630 Description BioMASSMA Monthly Activity Interest BioMASSMA Beginning Balance 3 Advice Letter 5478-E pages 4 and 5. - Mar-19 $
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Advice 5556-E -3- June 7, 2019 The net costs that will be transferred to the TMNBCBA during the June business close is the sum of the two memo account balances, which is $56.36 million. Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than June 27, 2019, which is 20 days after the date of this submittal. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: 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: 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).
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Advice 5556-E -4- June 7, 2019 Effective Date Pursuant to General Order (GO) 96-B, Rule 5.1, this advice letter is submitted with a Tier 1 designation. PG&E requests that this Tier 1 advice letter become effective upon date of submittal, which is June 7, 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 A.16-11-005. Address changes to the General Order 96-B service list should be directed to PG&E at email address For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter submittals can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations Attachment Confidential Appendix A – BioRAMMA and BioMASSMA Workpapers cc: Service List A.16-11-005
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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: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 5556-E Subject of AL: Review Tree Mortality Costs Recorded to the Memorandum Accounts for February – 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 #: 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 Confidentiality Declaration and Matrix Donna Barry,, (415)973-5707 Yes ✔ No 6/7/19 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: 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: 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: 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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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA DECLARATION OF DONNA L. BARRY SEEKING CONFIDENTIAL TREATMENT FOR CERTAIN DATA AND INFORMATION CONTAINED IN PG&E’S IMPLEMENTATION OF DECISION 18-12-003 (ADVICE LETTER 5556-E) I, Donna Barry, declare: 1. I am a Regulatory Principal in the Revenue Requirements Department within the Regulatory Affairs organization at Pacific Gas and Electric Company (PG&E). In this position, my responsibilities include development of cost recovery proposals, analyses in support of testimony and various reports filed at the Commission. In carrying out these responsibilities, I have acquired knowledge of the generation-related transactions types purchased for PG&E’s electric portfolio, which are recorded to the BioRAM Memorandum Account and Biomass Memorandum Account. This declaration is based on my personal knowledge of PG&E’s practices and my understanding of the Commission’s decisions protecting the confidentiality of market-sensitive information. 2. Based on my knowledge and experience, and in accordance with Decision (D.) 08-04-023, issued in Rulemaking 05-06-040, I make this declaration seeking confidential treatment of Appendix A contained in PG&E’s Advice Letter 5556-E submitted in compliance with the disposition of Advice Letter 5478-E on May 23, 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 data and information covered by Decision 06-06-066. The matrix also specifies why confidential protection is justified. Further, the data and information: (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 pertinent to my testimony in the attached matrix.
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I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed on June 7, 2019 at San Francisco, California. /s/ DONNA L. BARRY
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PACIFIC GAS AND ELECTRIC COMPANY (U 39 E) ADVICE LETTER 5556-E JUNE 7, 2019 IDENTIFICATION OF CONFIDENTIAL INFORMATION Redaction Reference Confidential Appendix A Category from D.06-06066, Appendix 1, or Separate Confidentiality Order that Data Corresponds To Item VII.G (Bilateral Contract Terms and Conditions – Renewable Resource Contracts under RPS program) Item VII.G (Monthly Procurement Costs recorded in ERRA) Justification for Confidential Treatment This appendix reveals contract terms and conditions (i.e., detail pricing information) and recorded procurement costs that is market sensitive information, which if publicly disclosed could put PG&E at a competitive disadvantage with regard to other market participants and could detrimentally impact PG&E customers. The data cannot be aggregated in a way that allows for partial disclosure. Length of Time Date To Be Kept Confidential Three years
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Advice 5556-E June 7, 2019 Confidential Appendix A BioRAMMA and BioMASSMA Workpapers
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PG&E Gas and Electric Advice Submittal 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 Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions Engineers and Scientists of California 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 Peninsula Clean Energy 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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