Details for: 4048-E (Part 1 of 1).pdf


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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

August 1, 2019
ADVICE 4048-E
(Southern California Edison Company U 338-E)
ADVICE 5605-E
(Pacific Gas and Electric Company U 39-E)
ADVICE 3408-E
(San Diego Gas & Electric Company U 902-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
Update to Community Choice Aggregate and Energy Service
Provider Load Data and Utility Investment and Procurement
Information

SUBJECT:

PURPOSE
Pursuant to Ordering Paragraph (OP) 5 of California Public Utilities Commission (CPUC
or Commission) Decision (D.)17-04-039, San Diego Gas & Electric Company (SDG&E),
Southern California Edison Company (SCE), and Pacific Gas and Electric Company
(PG&E), (collectively, the Joint Utilities) respectfully submit this advice letter to update
Tables 3 through 6 based on the most current Community Choice Aggregator (CCA)
and Energy Service Provider (ESP) load data and utility investment and procurement
information.
BACKGROUND
On October 21, 2013, the Commission issued D.13-10-040 to establish the Energy
Storage Procurement Framework and Design Program (Energy Storage Program).
The Energy Storage Program set a procurement target of 1,325 megawatts (MW) of
energy storage projects for the investor-owned utilities (IOUs) to procure through a
series of solicitations from 2014 to 2020.1 All storage projects must be online no later
than 2024.2
1
2

D.13-10-040, Appendix A, p.1.
Id.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





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ADVICE 4048-E (U 338-E) -2- August 1, 2019 Additionally, the Energy Storage Program set a procurement target for all CCAs and ESPs to procure energy storage resources equivalent to one percent of their 2020 load, with all storage projects being online no later than 2024.3 On January 5, 2016, the CPUC issued a Scoping Memo and Ruling in Track 2 of the Energy Storage Order Instituting Rulemaking (OIR) seeking parties’ comments on the revision of energy storage procurements targets.4 The Alliance for Retail Energy Markets and Direct Access Customer Coalition (AReM/DACC) argued that some CCA/ESP procurement obligations can exceed a utility’s, and proposed to prohibit future cost recovery through non-bypassable charges and credit ESPs with any excess storage for procurement that is above what the IOUs are obligated to procure.5 In D.17-04-039, the Commission ruled that revisions to cost recovery of storage procurement were beyond the scope of the proceeding, but that it was in scope to consider revisions to the CCA/ESP storage procurement targets. The Commission reviewed the extent to which the combined one percent procurement obligation and non-bypassable charges assigned to CCAs/ESPs compares with the utility procurement obligations, as a percentage of utility load. In the instance that a CCA/ESP procurement obligation exceeds that of the utility, the Commission adopted an automatic limiter that proportionately reduces each CCAs/ESPs one percent procurement obligation by the amount that the load serving entity’s (LSE) own procurement plus its customers’ share of non-bypassable charges exceeds the utility obligation by a percentage of load.6 Comparing IOU and CCA/ESP storage procurement obligations as a percentage of load is done using Tables 3 through 6 of D.17-04-039. Ordering Paragraph 5 of D.17-04-039 requires the IOUs to update Tables 3 through 6 on an annual basis beginning August 1, 2017 through 2020. On August 1, 2017, the Joint Utilities submitted Advice 5119-E et al. to update Tables 3 through 6, originally included in D.17-04-039. Commission Resolution E-4892 addressing Advice 5119-E et al. directed the IOUs to submit a supplemental advice letter to make corrections to Tables 4 through 6. On January 16, 2018, the Joint Utilities submitted Advice 3640-E-A et. al to make these corrections. On February 5, 2018, AReM/DACC submitted a timely protest on the Joint 3 4 5 6 Id. at 46. R.15-03-011 – “Assigned Commissioner and Assigned Administrative Law Judge’s Scoping Memo and Ruling Seeking Party Comments.” p.5-6. D.17-04-039, p. 22-23. Id. at 27.
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ADVICE 4048-E (U 338-E) -3- August 1, 2019 Utilities’ Advice 3640-E-A et. al.7 AReM/DACC contended that the Joint Utilities did not calculate the automatic limiter and adjusted energy storage procurement obligations of the ESPs correctly and argued that the Joint Utilities should have combined the ESP obligation across IOUs.8 On February 12, 2018, the Joint Utilities submitted a timely reply.9 The Joint Utilities responded that D.17-04-039 did not adopt a new statewide target and it did not allow ESPs and CCAs in one IOU’s service territory to benefit from the allocation of procurement in another IOU’s service territory. Each ESP and CCA is bound by the one percent procurement target, and the procurement target is only reduced if that LSE’s own procurement plus its customers’ share of nonbypassable charges exceeds the host utility’s obligation as a percentage of load.10 The CPUC issued a disposition letter on February 21, 2018 approving AL 3640-E-A et al. in its entirety, effective January 16, 2018. The CPUC’s disposition letter determined that the IOUs correctly applied the automatic limiter and clarified that each individual ESP and CCA must calculate its procurement obligation based on its own procurement and its customers’ share of nonbypassable charges.11 On August 1, 2018, the Joint Utilities submitted Advice 3833-E et. al., to update Tables 3 throught 6. On August 21, 2018, AReM/DACC and Marin Clean Energy (MCE) submitted comments to the joint advice letter. AReM/DACC’s comments agreed with the IOU’s calculations. MCE’s comments stated that there was a slight miscalculation of CCA load data in PG&E’s service territory and recommended that PG&E be required to adjust its calculation of CCA load share from 209 MW to 207 MW. MCE also stated in its comments that SDG&E’s calculation of CCA share should be adjusted to take into account the storage costs recovered through non-bypassable charges for SDG&E and reflect that the automatic limiter had been triggered.12 On August 28, PG&E timely submitted a reply to the MCE comments. In its comments, PG&E maintained that the 209 MW of CCA load share in its territory is accurate. On December 5, 2018, the CPUC issued a disposition letter approving the Joint IOUs’ advice letters in their entirety. The Energy Division found the IOUs’ calculations to be reasonable and did not require any further action from the IOUs. The Energy Division 7 8 9 10 11 12 Comments of AReM/DACC on SCE’s Advice Letter 3640-EA, PG&E’s Advice Letter 5119E-A, and SDG&E’s Advice Letter 3103-E-A Updating Energy Storage Obligations, February 12, 2018. Id. at 2-3. Joint Reply to Comments on Joint Supplement SDG&E Letter 3103-E-A, PG&E Advice Letter 5119-E-A, and SCE Advice Letter 3640-E-A, February 12, 2018. Id. at 2. CPUC Staff Disposition Letter, February 21, 2018, p. 3. CPUC Staff Disposition Letter, December 5, 2018, p. 2.
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ADVICE 4048-E (U 338-E) -4- August 1, 2019 noted that the automatic limiter had been triggered for ESPs and CCAs in the service territories of all three IOUs and the 1% storage procurement obligation was eliminated. Updated Tables Table 3: ENERGY STORAGE COST RECOVERY (Data as of July 2019) SERVICE TERRITORY Storage MW recovered or approved for recovery via non-bypassable charges (to date)13 Future (known additional) MW expected to be recovered via non-bypassable charges17 Total MW expected to be recovered via non-bypassable charges 13 14 15 16 17 18 19 PG&E SCE SDG&E 49.81814 396.0715 164.1216 587.518 19519 0 637.318 591.07 164.12 This information reflects Cost Allocation Mechanism (CAM) and distribution charge recovery, and only those contracts that have been approved for recovery to date. 6 MW via distribution charge + 43.32 MW of customer-sited SGIP/PLS projects (Distribution Charge. D.13-10-040 (CPUC June 2019 Update)) + 0.5 MW for Browns Valley (A.16-03-001; D.16-09-007). 13.92 MW via distribution charge + 60.31 MW of SGIP/PLS July 2019 update (does not account for DA / CCA counting rule application for SGIP as per D.16-01-032) + 22 MW of Aliso Canyon Energy Storage (ACES) projects (Resolution E-4804 - 5 MW of original 27 MW authorization was cancelled) + 254.84 MW in West LA Basin via SCE 2013 LCR RFO to replace SONGS capacity (D.15-11-041) + 20 ACES Design Build Transfer (Resolution E4791) + ACES Enhanced Gas Turbines (A.17-03-020) + 5 MW from SCE’s PRP RFO 2 (A.16-11-002). 6.15 MW via distribution rates + 36.97 MW of SGIP/PLS + 37.5 MW of ACES storage projects (Resolution E-4798) + 83.5 MW Track IV LCR (D.18-05-24). D.17-04-039 does not include a requirement of a forecast of non-bypassable charges, as Decision notes that doing so would be too speculative or of limited value; however, the IOUs include both storage expected to be recovered through CAM and distribution charges, to include forecasted MWs that are consistent with the IOU applications filed in the 2018 Energy Storage Procurement and Investment Plans. 20 MW for Llagas (A.17-12-003) + 567.5 MW for four projects pursuant to Resolution E4909 (AL 5322-E). 100 MW via 2018 LCR RFP (A.19-04-016) + 95 MW via ACES 2 RFO (SCE AL 4002-E).
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ADVICE 4048-E (U 338-E) -5- August 1, 2019 Table 4: DIRECT ACCESS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of July 2019) SERVICE TERRITORY PG&E SCE SDG&E Applicable ESP load (GWh)20 DA MW share of non-bypassable charges21 1% ESP procurement obligation (GWh) 1% ESP procurement obligation (MW)22 9,520 96 11,710 89 3,459 25 95 17 117 21 35 6 Table 5: COMMUNITY CHOICE AGGREGATORS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of July 2019) SERVICE TERRITORY PG&E SCE SDG&E Applicable CCA load (GWh)23 CCA MW share of non-bypassable charges27 1% CCA procurement obligation (GWh) 1% CCA procurement obligation (MW) 20 21 22 23 24 25 26 27 36,31624 282 19,09025 137 6426 0.6 363 65 191 34 0.6 0.1 2020 Direct Access load forecast data available at: 2018 IEPR Load Forecast https://efiling.energy.ca.gov/GetDocument.aspx?tn=222582. 2018 IEPR Corrected LSE and BA Tables Mid Baseline – Mid AAEE Form 1.1c. Direct Access (DA) ESPs are responsible for non-bypassable charges based on load share for CAM and distribution rates. This does not include PCIA for storage. ESPs comprise 15.1 percent of load share, based on the latest Direct Access Implementation Activities Report, published April 15, 2019, accessible at: http://www.cpuc.ca.gov/General.aspx?id=6598. Assumes 64 percent capacity factor (CF) for ESPs and CCAs as referenced in D.17-04039, FN 35. MW = 1000*GWh/(CF/8760). 2020 CCA load forecast data available at: 2018 IEPR Load Forecast. https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=17-IEPR-03. Revised LSE and BA Tables Mid Baseline – Mid AAEE. Form 1.1(c). 2020 CCA load forecast data available at: https://efiling.energy.ca.gov/GetDocument.aspx?tn=222582. 2018 IEPR Corrected LSE and BA Tables Mid Baseline – Mid AAEE Form 1.1c. 2020 CCA load forecast, less publicly available data for CPA Phases 1 to 4, plus data from implementation plans of Baldwin Park, City of Commerce, CPA phases 1 to 5, DCE, Hanford, Palmdale, Pomona, and WCE. 2020 CCA load forecast data available at: https://efiling.energy.ca.gov/GetDocument.aspx?tn=226462&DocumentContentId=57239 Corrected LSE and BA Tables Mid Baseline Low AAEE AAPV Form 1.1c. Currently active CCAs comprise 44.2 percent of forecasted 2020 load in PG&E territory; 23.2% of forecasted 2020 load in SCE territory; 0.35% of forecasted 2020 load in SDG&E territory. Percentages are derived from 2018 IEPR Load Forecast. Available at https://efiling.energy.ca.gov/GetDocument.aspx?tn=222582. 2018 IEPR Corrected LSE and BA Tables Mid Baseline – Mid AAEE Form 1.1c.
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ADVICE 4048-E (U 338-E) -6- August 1, 2019 Table 6: COMPARISON OF UTILITY, DIRECT ACCESS, AND COMMUNITY CHOICE AGGREGATORS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of July 2019) SERVICE PG&E SCE SDG&E TERRITORY Storage obligation 580 MW 580 MW 165 MW as % of total 2020 ~2.7%29 ~4.1%30 ~ 3.2%28 load forecastStorage Target of 1325 MW Storage obligations 746 MW 746 MW 331 MW as % total of 2020 ~ 4.1% ~3.5% ~8.3% load forecast – Storage Target of 1825 MW31 Automatic Limiter Unadjusted Adjusted Unadjusted32 Adjusted33 Unadjusted34 Adjusted35 Adjustment ESP Current 113 MW 54 MW 110 MW 56MW 31 MW 25 MW Share: 1% ~ 6.7 % ~3.2% ~5.3% ~2.7% ~5.0% ~4.1% procurement obligation + nonbypassable charge (MW / % of load) CCA Current 347 MW 208 MW 171 MW 95 MW 0.69 MW 0.47 MW Share: 1% ~ 5.3 % ~3.2% ~5.0% ~2.7 % ~6.0% ~4.1% procurement obligation + nonbypassable charge (MW / % of load) 28 29 30 31 32 33 34 35 PG&E Load derived from 2018 IEPR Load Forecast, Revised LSE and BA Tables Mid Baseline – Mid AAEE. Form 1.5(b). PG&E Service Area Greater Bay Area + PG&E Service Area Non Bay Area + PG&E Service Area ZP26. SCE Load Updated – 21,403 MW. Source: IEPR LSE and BA Tables Mid Baseline Mid AAEE Form 1.5b SCE TAC less, CDWR and Pasadena, less the sum of new 2020 CCA MW based on publicly available implementation plans (note: total does not include CPA phase 5 or WCE as the information was not provided in the plans) SDG&E Load Updated – 4,010 MW. Source: 2018 IEPR LSE and BA Tables Mid Baseline Mid AAEE Form 1.5b = SDG&E Service Area. Includes procurement under AB 2868. ESP / CCA Current Share, without application of Automatic Limiter. ESP / CCA Current Share, with application of Automatic Limiter. ESP / CCA Current Share, without application of Automatic Limiter. ESP / CCA Current Share, with application of Automatic Limiter.
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ADVICE 4048-E (U 338-E) -7- August 1, 2019 EXPLANATION OF UPDATES Table 3 has been updated to reflect the most current, publicly available Energy Storage Cost Recovery Data. Table 4 has been updated to reflect the most current, publicly available Direct Access Storage Procurement Cost Obligations. Table 5 has been updated to reflect the most recent, publicly available CCA and ESP load data, as of the date of this advice letter. Table 6 has been updated with the latest ESP and CCA information available to the Joint Utilities. For PG&E, because the ESP and CCA procurement obligations exceed PG&E’s storage obligation as a percentage of load of PG&E (i.e., greater than 3.2% - relative to Storage Target of 580 MW), the automatic limiter has been triggered for PG&E for the ESP and CCA current shares. As such, PG&E has applied the automatic limiter to the ESP and CCA shares in Table 6. PG&E shows both the unadjusted MW / % (i.e., before application of limiter), and adjusted (i.e., after application of limiter) values for comparison purposes. For SCE, because the ESP and CCA procurement obligations exceed SCE’s storage obligation as a percentage of load of SCE (i.e., greater than 2.7% - relative to Storage Target of 580 MW), the automatic limiter has been triggered for SCE for the ESP and CCA current shares. As such, SCE has applied the automatic limiter to the ESP and CCA shares in Table 6. SCE shows both the unadjusted MW / % (i.e., before application of limiter), and adjusted (i.e., after application of limiter) values for comparison purposes. For SDG&E, because the ESP and CCA procurement obligations for SDG&E exceed SDG&E’s storage obligation (i.e., ESP procurement obligation is greater than 4.1% relative to Storage Target of 165 MW), the automatic limiter has been triggered for SDG&E for the ESP and CCA current share. As such, SDG&E has applied the automatic limiter to the ESP and CCA share in Table 6. SDG&E shows both the unadjusted MW / % (i.e., before application of limiter), and adjusted (i.e., after application of limiter) values for comparison purposes. No cost information is required for this advice letter. This advice letter will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule.
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ADVICE 4048-E (U 338-E) -8- August 1, 2019 TIER DESIGNATION This advice letter is subject to Energy Division disposition and is classified as Tier 1 (effective pending disposition) pursuant to GO 96-B, Energy Industry Rule 5.1 and OP 9. EFFECTIVE DATE SCE respectfully requests that this advice letter become effective on August 1, 2019, which is the date of this advice letter. NOTICE Anyone wishing to provide a response to 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. Responses should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, responses and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: For SCE 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: AdviceTariffManager@sce.com
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ADVICE 4048-E (U 338-E) -9- August 1, 2019 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: Karyn.Gansecki@sce.com For SDG&E Attn: Megan Caulson Regulatory Tariff Manager San Diego Gas & Electric Company 8330 Century Park Ct., CP31F San Diego, CA 92123-1548 E-mail: MCaulson@SDGE.com For PG&E 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, CA 94177 Facsimile: (415) 973-3582 E-mail: PGETariffs@pge.com There are no restrictions on who may submit a response, but the response 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 shown on the attached GO 96-B and R.15-03-011 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com, SDG&ETariffs@semprautilities.com, PGETariffs@pge.com, or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Process_Office@cpuc.ca.gov. 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 https://www.sce.com/wps/portal/home/regulatory/advice-letters. To view other SDG&E advice letters submitted with the Commission, visit SDG&E’s web
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ADVICE 4048-E (U 338-E) - 10 - August 1, 2019 site at http://www.sdge.com/rates-regulations/tariff-information/advice-letters. To view other PG&E advice letters submitted with the Commission, visit PG&E’s web site at http://www.pge.com/tariffs/. For questions directed at SCE, please contact David Balandran at (626) 302-6734 or by electronic mail at David.Balandran@sce.com. For questions directed at SDG&E, please contact Megan Caulson at (858) 654-1748 or by electronic mail at mcaulson@semprautilities.com. For questions directed at PG&E, please contact Kingsley Cheng at (415) 973-5265 or by electronic mail at K2c0@pge.com and PGETariffs@pge.com. Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:dmb:cm 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: AdviceTariffManager@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 4048-E Subject of AL: Update to Community Choice Aggregate and Energy Service Provider Load Data and Utility Investment and Procurement Information Keywords (choose from CPUC listing): Compliance Procurement AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 17-04-039 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: 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: Resolution required? Yes No Requested effective date: 8/1/19 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: EDTariffUnit@cpuc.ca.gov 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: advicetariffmanager@sce.com 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: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: karyn.gansecki@sce.com 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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