Details for: PGE Comments on Draft Resolution E-5026_Redacted.pdf

Click on the image for full size preview

Document data

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

September 9, 2019
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Comments of Pacific Gas and Electric Company on Draft Resolution

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) appreciates the opportunity to comment on
Draft Resolution E-5026 (the Draft Resolution) approving a temporary update to PG&E’s
2014 Conformed Bundled Procurement Plan, Appendix S, as described in Advice Letter
(AL) 5589-E, filed July 17, 2019.
PG&E’s Comment:
As described in Attachment A, PG&E proposes minor editorial changes to a portion of
the Confidential Appendix A to the Draft Resolution.
Respectfully submitted,
Erik Jacobson
Director, Regulatory Relations

Edward Randolph, Director, Energy Division
Michele Kito, Energy Division
Nick Dahlberg, Energy Division
Service List for R.16-02-007


- Page 1 -

PG&E Comments on Draft Resolution E-5026 Attachment A CONFIDENTIAL PROTECTED MATERIAL SUBMITTED UNDER DECISION 06-06-066 AND PUB. UTIL. CODE SECTION 454.5(g) PG&E proposes the following minor editorial changes to clarify the potential outcome as referenced in Confidential Appendix A, Draft Resolution E-5026, as a result of PG&E’s temporary change to the System Monthly Sales Amount calculation in Appendix S of PG&E’s 2014 Conformed Bundled Procurement Plan:
- Page 2 -

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA DECLARATION OF ROBERT GOMEZ SEEKING CONFIDENTIAL TREATMENT FOR CERTAIN DATA AND INFORMATION CONTAINED IN PG&E’S COMMENTS ON DRAFT RESOLUTION E-5026 I, Robert Gomez, declare: 1. I am a Manager in the Portfolio Management department in the Energy Policy and Procurement organization at Pacific Gas and Electric Company (PG&E). In this position, my responsibilities include overseeing Commercial Planning activities, including the mid-term load forecast and position management at PG&E. 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 the Decisions 06-06-066, 08-04-023, and relevant Commission rules, I make this declaration seeking confidential treatment for certain data and information contained in PG&E’s Comments on Draft Resolution E-5026. 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 D.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. I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed on September 9, 2019 at San Francisco, California.
- Page 3 -

- Page 4 -

PACIFIC GAS AND ELECTRIC COMPANY (U 39 E) COMMENTS ON DRAFT RESOLUTION E-5026 SEPTEMBER 9, 2019 IDENTIFICATION OF CONFIDENTIAL INFORMATION Redaction Reference Confidential Attachment A Category from D.06-06-066, Appendix 1, or Separate Confidentiality Order That Data Corresponds To Justification for Confidential Treatment Length of Time Data To Be Kept Confidential Pub. Util. Code§454.5(g) This information includes PG&E’s confidential sales framework. Any discussion of PG&E’s sales strategies is market sensitive, because it will impact market participants’ bidding behavior for market products. Disclosure of this information could cause harm to PG&E’s customers and put PG&E at an unfair business advantage through non-competitive sales results. Indefinite
- Page 5 -