Details for: PGE AL 5584-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

July 8, 2019

Advice 5584-E
(Pacific Gas and Electric Company ID U 39 M)

Public Utilities Commission of the State of California
Subject:

Establish Working Group 1 Material Modifications Balancing Account
and Revise the Public Policy Charge Balancing Account (R21 BA) in
Compliance with Decision 19-03-013 Ordering Paragraph 7

Purpose
Pacific Gas and Electric Company (“PG&E”) submits this advice letter pursuant to
Ordering Paragraph (“OP”) 7 of California Public Utilities Commission (“CPUC” or
“Commission”) Decision (“D.”) 19-03-013 (“Decision”) to establish a Rule 21 Balancing
Account (R21 BA) for Material Modification. This advice letter includes the specific
methodology PG&E will employ for the recovery of the interconnection portal
development expenses needed to implement D.19-03-013 related to Issue 3, Type 2
Material Modifications (i.e., modifications to interconnected customer Rule 21
generating facility) implemented with Process Option 2. It describes the authorized
expenses and fees that will be tracked. To that goal, PG&E also requests the new
Electric Preliminary Statement Part HY associated with the R21 BA to be established.
Background
In 2017, the Commission initiated a Rulemaking to explore and identify various means
to improve the interconnection process for Electric Rule 21 eligible generation
interconnections.1 Working Groups were established to address several collections of
issues that were laid out in the original scoping order. The first collection was
addressed in Working Group 1. After a series of meetings to discuss the identified
issues (“Issues”) in Working Group 1, various improvements were proposed. These
Issues were captured in the Working Group 1 Report (“Report”),2 which was issued in
March of 2018. Based on the recommendation in the Report, in March of the following

1

R 17-07-007 - Order Instituting Rulemaking to Consider Streamlining Interconnection of
Distributed Energy Resources and Improvements to Rule 21. (April 3, 2015).
2
Working Group 1 Final Report – Issued March 15, 2018.





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Advice 5584-E -2- July 8, 2019 year (2019), D. 19-03-0133 ordered the implementation of various new policy related to the Issues. With regard to this Advice Letter, D.19-03-013, OP 7 directs: Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company (the Utilities) shall immediately begin to develop process option 2 from Ordering Paragraph 6. The Utilities are authorized to establish and record costs in a balancing account, funded by the interconnection fees. D.19-03-013, in Table 34 (reproduced below), lays out seven “cases” where modifications to existing (interconnected) generating facilities will be allowed. Per Ordering Paragraph 7, fees may be collected when Process Option 2 (as defined in the table header of Table 3) is used. For case 3 and 45, Ordering Paragraph 6 further clarifies when Process Option 2 will be used (as opposed to Process Option 4): 4 5 D. 19-03-013 - Decision Adopting Proposals From March 15, 2018 Working Group One Report - Date of Issuance 4/5/2019 D.19-03-013 p. 59 For Use Case 3, process option 2 shall be used for projects increasing capacity to less than 100 kilowatt (kW), pending the creation of certification schemes for inverter power controls (software/firmware) to limit export, and process option 4 shall be used for projects increasing capacity to at or greater than 100 kW. For projects of any size that are requesting an increase in capacity within 110 percent of their original generating capacity, process option 2 shall be used. (From D. 13-03-013, Ordering Paragraph 6, p. 58.) For Use Case 4, the use case will be based on a Commission determination on Working Group 2 proposals. If the Commission determines that operational profiles of systems should be used to determine system impacts, then process option 4 is adopted. If the Commission determines that a generator’s maximum output should be based on its rated capacity, then process option 2 is adopted. (Also from D. 13-03-013, Ordering Paragraph 6, p. 58.)
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Advice 5584-E -3- July 8, 2019 Table 3 from D.19-03-013. Table 3 Process Options Adopted for Modifications to Existing Facilities by Use Case • Process Option 1: No notification is required • Process Option 2: Notification is required but the customer can proceed with building the system and turning on the system without waiting for utility approval • Process Option 3: Abridged/Streamlined interconnection request is required and the customer must wait for utility approval to turn on the system (engineering review required) • Process Option 4: Normal interconnection request Case 1 2 3 4 5 6 7 Description Replacing equipment with exact same equipment type or performing upgrades to inverter firmware that do not affect grip interactions Replacing equipment “like-for-like”, where system output does not exceed what is listed in the original interconnection agreement and operating mode is not adjusted. Replacing equipment that may increase the nameplate capacity of the system, but which employ inverter power controls that limit the real power output to the inverter listed size in the original agreement. Adding storage capacity to an existing storage facility without changing inverter. Adding or replacing equipment such that system capacity increases and no inverter power controls are employed to limit the real power output to the inverter listed size in the original agreement. Adding storage to an existing generating facility that does not have storage. Changing inverter operating characteristics. Process Option 1 2 2/4 2/4 4 4 4
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Advice 5584-E -4- July 8, 2019 D.19-03-013 allows PG&E to collect a new Rule 21 fee for all the “cases” involving generating facility modifications using Process Option 2 as described in Table 3 above. This includes collecting a fee for material modifications to generating facilities on Schedules NEM, NEMV and NEMVMASH as well as Schedule NEMFC, notwithstanding PU Code Section 2827(g), PU Code Section 2827.10(e)(1). However, PG&E will not collect such fees from SASH6 customers, consistent with the NEM successor decision, D. 16-01-044.7 Establish the Rule 21 Balancing Account (R21 BA) to Record Actual Implementation Costs and Fee Collection As authorized by D.19-03-013, PG&E requests that the Commission permit PG&E to establish the R21 BA, a balancing account, to track the actual Process Option 2 implementation expenses and to track the collection of a new additional fee, until the collected fees offset the implementation expenses. The new additional fee will be collected as described in AL 5553-E. (AL 5553-E8 set this new fee to $0 for now. In a future Advice Letter after the PG&E online portal is upgraded, PG&E will establish a non-zero value for the new fee.) Implementation expenses include the cost of upgrading PG&E’s (online) portal, and back-end system, including development, testing, and project management, as well as the expenses of including a PayPal payment option (for collecting the new fee). The purpose of the balancing account ensures that fee recovery is limited to actual implementation expenses. PG&E does not expect to begin recovery of these expenses until its online application portal is revised to accommodate the changes, and to accept online payments. Tariff Revisions Please find attached to this advice letter, the new Electric Preliminary Statement Part HY: • 6 To create a new Rule 21 Balancing Account (R21 BA) to record the implementation expenses associated with the development of Process Option 2, to be funded by interconnection fees, as approved in D.19-03-013. SASH is Single Family Affordable Solar Housing; D. 16-01-044 – Issued February 5, 2016 - Decision Adopting Successor To Net Energy Metering Tariff – Conclusions of Law 6: “In order to promote consistency with the goals of the SASH program, customers eligible for SASH who interconnect under the NEM successor tariff should not pay any charge for interconnection.” 8 AL 5553-E, Modification to Electric Rule 21 Pursuant to the Working Group 1 Decision 19-03013 in Rulemaking 17-07-007, submitted June 4, 2019. 7
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Advice 5584-E -5- July 8, 2019 This advice letter will not increase any current rate or charge, cause the withdrawal of service, or conflict with any rate schedule or rule. Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than July 29, 2019, which is 21 days9 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: 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). 9 The 20-day protest period concludes on a weekend, therefore, PG&E is moving this date to the following business day.
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Advice 5584-E -6- July 8, 2019 Effective Date This advice letter is submitted with a Tier 1 designation. PG&E requests that this advice letter become effective on August 5, 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.17-07-007. 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) 7032021 or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter submittals can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List R.17-07-007
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ADVICE LETTER S UM M A RY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39 E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Annie Ho Phone #: (415) 973-8794 E-mail: PGETariffs@pge.com E-mail Disposition Notice to: AMHP@pge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Advice Letter (AL) #: 5561-E Tier Designation: 1 Subject of AL: Establish Working Group 1 Material Modifications Balancing Account and Revise the Public Policy Charge Balancing Account (R21 BA) in Compliance with Decision 19-03-013 Ordering Paragraph 7 Keywords (choose from CPUC listing): Compliance, Balancing Account AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.19-03-013 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 Yes No No 8/5/19 No. of tariff sheets: 3 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: Preliminary Statement Part HY Service affected and changes proposed 1: N/A Pending advice letters that revise the same tariff sheets: N/A Discuss in AL if more space is needed. 1 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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Attachment 1 Advice AMHP-BA r21-E Cal P.U.C. Sheet No. Title of Sheet Cancelling Cal P.U.C. Sheet No. 44711-E ELECTRIC PRELIMINARY STATEMENT PART HY RULE 21 BALANCING ACCOUNT (R21 BA) Sheet 1 44712-E ELECTRIC PRELIMINARY STATEMENT PART HY RULE 21 BALANCING ACCOUNT (R21 BA) Sheet 2 44713-E ELECTRIC TABLE OF CONTENTS Sheet 1 44679-E 44714-E ELECTRIC TABLE OF CONTENTS Sheet 17 44694-E Page 1 of 1
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Original U 39 Cal. P.U.C. Sheet No. 44711-E San Francisco, California ELECTRIC PRELIMINARY STATEMENT PART HY RULE 21 BALANCING ACCOUNT (R21 BA) Sheet 1 HY. RULE 21 BALANCING ACCOUNT (R21 BA) 1. PURPOSE: The purpose of the Rule 21 Balancing Account (R21 BA) is to track the costs associated with the development of Process Option 2 as authorized by Decision (D.) 19-03013. Ordering Paragraph (OP) 7 of D. 19-03-013 approves the establishment of the R21 BA to record the implementation expenses of upgrading PG&E’s (online) portal to update the existing application process for material modification, to be funded by a portion of customer interconnection fees collected based on the annual Net Energy Metering Costs filing. 2. APPLICABILITY: The R21 BA shall apply to all eligible customer-generators who elect to modify their existing facilities using Process Option 2 (i.e. Process Option 2: Notification is required but the customer can proceed with building the system and turning on the system without waiting for utility approval1) for the following cases: (1) replacing equipment “like-forlike”, where system output does not exceed what is listed in the original interconnection agreement and operating mode is not adjusted; (2) Replacing equipment that may increase the nameplate capacity of the system, but which employ inverter power controls that limit the real power output to the inverter listed size in the original agreement; 2 and (3) Adding storage capacity to an existing storage facility without changing inverter.3. 3. REVISION DATE: The balance in this account will be included in the Annual Electric True-up (AET) filing or through an advice letter filing as authorized by the Commission. 4. RATES: The R21 BA does not have a rate component. 5. ACCOUNTING PROCEDURE: The following entries (net of RF&U) will be made each month, or as applicable, as follows: a. A debit entry equal to PG&E’s incremental operating and maintenance (O&M) and administrative and general (A&G) expenses incurred associated with the development of Process Option 2. b. A debit entry equal to the capital-related costs incurred for depreciation, return on investment, federal and state income taxes, and property taxes associated with the costs of installed equipment. ________________ 1 Process Option 2 is defined in D. 19-03-013, in the Table 3 Heading. 2 For projects increasing capacity to less than 100 kilowatt (kW), pending the creation of certification schemes for inverter power controls (software/firmware) to limit export, and for projects of any size that are requesting an increase in capacity within 110 percent of their original generating capacity, process option 2 shall be used, both pursuant D. 13-03-013, Ordering Paragraph 6. 3 If the Commission determines that a generator’s maximum output should be based on its rated capacity. (N) (N) (N) (N) I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I (N) (Continued) Advice Decision 5584-E 19-03-013 Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution July 8, 2019 August 5, 2019
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Original U 39 Cal. P.U.C. Sheet No. 44712-E San Francisco, California ELECTRIC PRELIMINARY STATEMENT PART HY RULE 21 BALANCING ACCOUNT (R21 BA) Sheet 2 HY. RULE 21 BALANCING ACCOUNT (R21 BA) 5. ACCOUNTING PROCEDURE: (Cont’d.) c. A credit entry equal to the incremental portion of Rule 21 Interconnection Request fees determined specific for the recovery of costs to develop and implement process option 2. d. A debit or credit entry to transfer the balance to the Distribution Revenue Adjustment Mechanism (DRAM) or to any other regulatory balancing account as authorized by the Commission. e. An entry, as appropriate, each month equal to the interest on the average balance in this account at the beginning of the month and the balance after the above entries, at a rate equal to one-twelfth of the interest rate on the three-month Commercial Paper for the previous month, as reported in the Federal Reserve Statistical Release, H.15, or its successor. Advice Decision 5584-E 19-03-013 Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution (N) (N) (N) (N) I I I I I I I I I I I I I I I (N) July 8, 2019 August 5, 2019
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Cancelling U 39 Revised Revised Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 44713-E 44679-E San Francisco, California ELECTRIC TABLE OF CONTENTS Sheet 1 TABLE OF CONTENTS SCHEDULE CAL P.U.C. SHEET NO. TITLE OF SHEET Title Page ............................................................................................................................... 44711-E Rate Schedules ......................................... 44680,44681,44682,44683,44684,44685,43935,44177-E Preliminary Statements ........................... 44686,44687,42856*,43670,41723,40591,44040,44714-E Rules ................................................................................................................ 43022,43023,43210-E Maps, Contracts and Deviations ............................................................................................ 37960-E Sample Forms ... 40925*,37631,41151*,41573*, 37632,41152*,41153,37769,44035,40671,37169-E (T) (T) (Continued) Advice Decision 5584-E 19-03-013 Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution July 8, 2019 August 5, 2019
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Cancelling U 39 Revised Revised Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 44714-E 44694-E San Francisco, California ELECTRIC TABLE OF CONTENTS PART Sheet 17 CAL P.U.C. SHEET NO. TITLE OF SHEET Preliminary Statements (Cont’d) Part GA Part GB Part GC Part GD Part GE Part GF Part GH Part GI Part GJ Part GK Part GL Part GM Part GN Part GO Part GP Part GQ Part GR Part GS Part GT Part GU Part GV Part GY Part GZ Part HA Part HB Part HC Part HD Part HE Part HF Part HG Part HH Part HI Part HK Part HL Part HM Part HQ Part HR Part HT Part HU Part HX Part HY Greenhouse Gas Expense Memorandum Account .............................................. 32419,32420-E Greenhouse Gas Revenue Balancing Account .................................................... 35256,40560-E California Energy Systems for the 21st Century Balancing Account ................................ 40561-E Smart Grid Pilot Deployment Project Balancing Account ......................... 32540,32541, 32542-E Statewide Marketing, Education and Outreach Expenditure Balancing Account ............ 37728-E Customer Data Access Balancing Account – Electric ..................................................... 33136-E Mobile Home Park Balancing Account - Electric .................................................. 41091,41092-E Energy Data Center Memorandum Account – Electric.................................................... 33940-E Major Emergency Balancing Account (MEBA) ................................................................ 40563-E SmartMeterTM Opt-Out Program Balancing Account - Electric (SOPBA-E)35625,35626,35627-E Hydro Licensing Balancing Account (HLBA) ................................................................... 40564-E Nuclear Regulatory Commission Rulemaking Balancing Account (NRCRBA) ............... 40565-E San Francisco Incandescent Streetlight Replacement Account ...................................... 34364-E Disconnection Memorandum Account - Electric (DMA-E) ............................................... 34604-E Green Tariff Shared Renewables Memorandum Account (GTSRMA) ..... 40566,40567, 40567-E Energy Efficiency Financing Balancing Account – Electric (EEFMA-E) .... 35292,35293,35294-E Green Tariff Shared Renewables Balancing Account (GTSRBA) ............. 40569,40570,35377-E Residential Rate Reform Memorandum Account (RRRMA) ................................ 40571,40572-E Assembly Bill 802 Memorandum Account - Electric ........................................................ 40573-E Z-Factor Memorandum Account (ZFMA-E) ..................................................................... 40574-E Distribution Interconnection Memorandum Account (DIMA) ........................................... 40575-E Electric Vehicle Program Balancing Account (EVPBA) ................................................... 40576-E Distributed Energy Resources Distribution Deferral Account ................... 43656,43657,43658-E Avoided Cost Calculator Memorandum Account ............................................................. 40000-E Distribution Resources Plan Demonstration Balancing Account ..................................... 40577-E Rule 20A Balancing Account ........................................................................................... 41736-E Tax Memorandum Account (TMA-E) ............................................................................... 41088-E Executive Compensation Memorandum Account (ECMA-E) ............................... 40699,40700-E Distribution Resources Plan Tools Memorandum Account (DRPTMA) ............... 42139,42140-E Emergency Consumer Protections Memorandum Account - Electric (WCPMA-E) ....................... ................................................................................................................. 43007,44214, 44215-E Transportation Electrification Balancing Account (TEBA)……44688,44689,44690,44691, ....................................................................................................... 42579,42580,42581,44692-E Solar On Multifamily Affordable Housing Balancing Account (SOMAHBA) .................... 41781-E Diablo Canyon Retirement Balancing Account .................................................. 42161, 43668-E Wildfire Expense Memorandum Account (WEMA-E) ......................................... 42604, 42605-E Public Policy Charge Balancing Account (PPCBA) .................................. 44051,44037,44052-E Fire Risk Mitigation Memorandum Account (FRMMA) ................................................... 43314-E Net Energy Metering (NEM) Balancing Account (NEMBA) ............................................. 43317-E Officer Compensation Memorandum Account (OCMA-E) .................................... 43629,43630-E San Joaquin Valley Disadvantaged Communities Pilot Balancing Account .................... 44053-E Wildfire Plan Memorandum Account (WPMA) ............................................................... 44450-E Rule 21 Interconnection Balancing Account (R21 BA)…………………………………44711,44712-E (N) (Continued) Advice Decision 5584-E 19-03-013 Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution July 8, 2019 August 5, 2019
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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 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 Pioneer Community Energy Praxair Redwood Coast Energy Authority 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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