Details for: PGE Reply to Protest_AL 4119-G_5588-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

August 12, 2019

California Public Utilities Commission - Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102

Pacific Gas and Electric Company’s Reply to the Protest of Advice
4119-G/5588-E (July 15, 2019 – Supplemental Request for Energy
Efficiency Program Enhancements to Assist Wildfire Impacted

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) hereby replies to a protest dated August 5,
2019 from The Public Advocates Office (Cal Advocates) to Advice Letter (AL) 4119G/5588-E regarding adjustments to the Advanced Energy Rebuild (AER) offering for
customers who are rebuilding wildfire-destroyed homes.
A. PG&E’s requested changes to the AER offering requires customers to
rebuild beyond 2019 Title 24 building code.
PG&E acknowledges that the language in AL 4119-G/5588-E requires clarification. Cal
Advocates has interpreted PG&E’s requested changes to the AER offering to mean that
customers rebuilding to 2019 code as part of the AER offering might be receiving
incentives to build to 2019 code, rather than to exceed 2019 code. This interpretation is
not PG&E’s intent.
Table 1, provided in AL 4119-G/5588-E, clarifies that the goal of AL 4119-G/5588-E is
to adjust the participant design requirements “to allow applicant designs to exceed
either 2016 or 2019 Title 24 building code, depending on building permit issued.”
[Emphasis added]
Although the threshold above 2019 code (2-4%) is significantly smaller than the 20%
threshold proposed for program participants building to 2016 code, the offering will still
assist customers in achieving energy savings beyond 2019 code. Therefore, this


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PG&E’s Reply to Protest of Advice Letter 4119-G/ 5588-E -2- August 12, 2019 program would be appropriately funded using energy efficiency (EE) balancing account funds. Of the $3.77 million of annual funding originally approved in AL 3928-G-A/5219-E-A, only $1.33 million has been spent as of July 31, 2019, with a current total of 103 enrolled projects participating. PG&E acknowledges that the current incentive levels, when accompanied by savings only a small amount above code, likely yields a costineffective program. However, PG&E believes this will not materially affect PG&E’s overall EE portfolio given the small amount of participation and the limited-time nature and scope of the offering. PG&E is not requesting additional EE balancing account funds to support this effort beyond those already allocated – funds will continue to be offered on a first-come, firstserved basis until exhausted. B. PG&E’s requested changes to the AER offering will result in claimable energy savings. Cal Advocates’ statement that the adjusted AER offering, as proposed in Advice 4119G/5588-E, will not result in claimable energy savings is incorrect. On July 16, 2019, PG&E clarified to Cal Advocates that customers participating in the AER offering who are rebuilding homes or businesses to 2019 code could be reasonably expected to build at least 2-4% above 2019 code as a result of program participation. PG&E also notes that 2-4% above 2019 code would be a minimum savings threshold for AER participation for customers rebuilding with 2019 code permits. Program implementers are expected to work with customers to encourage the most energy efficient rebuild possible. As seen in participating projects building under 2016 code permits, many have exceeded the 2016 code by over 20%. 1 PG&E believes that through working with program implementers and energy advisors as part of program participation, participating customers building under 2019 permits would be supported to go above the 2-4% threshold established in Advice 4119-G/5588-E. C. Tracking costs to implement the program in a memorandum account is unnecessary because the costs should be tracked in the EE balancing account. As noted above, the AER offering as described in Advice 4119-G/5588-E does provide claimable energy savings and is appropriately funded within the energy efficiency portfolio. Therefore, it is unnecessary to track costs in a memorandum account associated with specific wildfires. 1 Attachment A (Annual Program Uptake Summary Memo) of AL 4115-G/5578-E.
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PG&E’s Reply to Protest of Advice Letter 4119-G/ 5588-E -3- August 12, 2019 PG&E respectfully requests that the Commission approve Advice 4119-G/5588-E as filed. /S/ Erik Jacobson Director, Regulatory Relations cc: Michael Campbell, Public Advocates Office,
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