Details for: PGE Comments on Draft Resolution E-5028.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

September 10, 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-5028 (the Draft Resolution) addressing PG&E’s requests and
comments as described in Advice Letter (AL) 3920-G/5206-E, filed December 22, 2017.
PG&E’s Comments:



PG&E commends the Commission for adopting several of the suggested changes
for removing barriers to adoption of the Enhanced Community Renewables (ECR)
program. In particular, PG&E believes that moving the community interest
requirement to the start of construction and moving the residential load
requirement to commercial operation date will remove barriers to program
Regarding Ordering Paragraph (OP) 4(e) to allow participating customers to adjust
their subscription levels twice per year: PG&E has no documented interest from
customers to adjust their subscription level. We believe the costs to participants
outweigh the benefits of making this adjustment to the IT and billing portions of
GTSR for PG&E and would like to request the Commission to make this
adjustment optional.
Regarding OP 4(h) to allow Net Energy Metering (NEM) customers to participate
in Green Tariff Shard Renewables (GTSR): In the almost 4 years that PG&E’s
GTSR programs have been operational, PG&E has received fewer than 5 inquiries
to its knowledge from NEM customers seeking to participate in GTSR. In addition,
due to the complex nature of billing NEM customers and the extent to which
changes to GTSR affect other aspects of PG&E's billing system, the IT cost to
implement this is estimated at $2.3 million. Spreading this cost among the
approximately 3,000 PG&E Solar Choice customers would result in an additional


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PG&E Comments on Draft Resolution E-5028 • • -2- September 10, 2019 cost burden of $766 per customer and would likely result in participant attrition. For these reasons PG&E would like to request that the Commission make NEM customer inclusion in GTSR optional. Regarding OP 6 and 8 to consolidate GTSR reports, filings, and rate changes; PG&E would like to thank the Commission for reducing the administrative burden of the GTSR program. Regarding the ECR Procurement Timeline, the Draft Resolution restates that Decision 16-05-006 does not specify any requirement for solicitations or frequency of solicitations after 2018. PG&E interprets that the Draft Resolution does not require an ECR solicitation in 2019, but instead requires solicitations to resume in 2020. Timing and frequency for solicitations in 2020 will be pending approval of a year-round procurement process that will be developed with stakeholders in a workshop held in conjunction with the next GTSR annual forum. Advisory Board Changes Finally, PG&E notes that in conformance with OP 15 of D.15-01-051, it promptly established an external Advisory Group in 2015 to advise on the GTSR program. PG&E has held advisory board meetings on a quarterly basis since April 2015, fully noticed to its advisory board participants from the environmental, consumer, low-income advocates, communities of color, labor and other relevant stakeholder communities. While PG&E did not have enough time under the program or basis to request a change to this procedure when it filed AL 3920-G/5206-E in December of 2017, PG&E has now had the benefit of 4-years of experience with the EAB to document that, after strong initial interest, it has seen a decline of participation in this Forum such that the most recently held advisory board meeting in June 2019 had zero advisory board participants. PG&E directs the Commission to Appendix A of these comments for a complete list of participation numbers from every EAB meeting since PG&E began monthly reporting to the Commission in January 2016. PG&E notes that page 88 of D.15-01-051, in discussing PG&E’s advisory group and San Diego Gas & Electric and Southern California Edison’s advising network, states “If, after the first year of the GTSR Program, it appears that either approach is not working, the Commission may change the community advising requirements via ruling in this docket.” PG&E respectfully requests that the Commission use the opportunity of this Resolution to remove the requirement for PG&E’s continuing advisory group meetings. PG&E has and will continue to meet with stakeholders on an ongoing basis to improve the GTSR program and remain abreast of issues important to relevant stakeholder groups. PG&E believes that its actions over the last 4 years demonstrate this point. However, requiring regular advisory board meetings which have demonstrably low value to participants is costly to the program and inefficient.
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PG&E Comments on Draft Resolution E-5028 -3- September 10, 2019 Errata PG&E notes two minor errata items that it believes need to be corrected in the Final Resolution: 1. Page 24 references a Tier 2 Advice Letter to be filed after the GTSR Annual Program Forum, to implement a GHG methodology. Page 26 references a Tier 3 Advice Letter to be filed after the same Program Forum to discuss the details of a year-round procurement process. Ordering Paragraph (OP) 5 references a Tier 2 Advice Letter for both purposes. PG&E believes that the language on page 26 was intended to say Tier 2. 2. Page 31, 3rd paragraph, states “PG&E and SCE are also granted permission to use the GTSR Forecast to seek changes to their GTSR rates going forward, with the same notification requirement.” PG&E believes the Commission intended to use the word “ERRA” in place of GTSR. Respectfully submitted, /S/ Erik Jacobson Director, Regulatory Relations cc: Edward Randolph, Director, Energy Division Cherie Chan, Public Utilities Regulatory Analyst, Energy Division Paul Phillips, Program Supervisor, Retail Rates, Energy Division Service List (s): A. 12-01-008, A.12-04-020; A. 14-01-007
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PG&E Comments on Draft Resolution E-5028 -4- Appendix A September 10, 2019
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PG&E Comments on Draft Resolution E-5028 -5- September 10, 2019 Number of Participants1 in PG&E’s External Advisory Board Meetings 2016 Q1 Q2 Q3 Q4 2017 Q1 Q2 Q3 Q4 2018 Q1 Q2 Q3 Q4 2019 Q1 Q2 1 Non-PG&E, non-CPUC # of Attendees 9 2 4 2 3 3 1 4 5 5 2 3 1 0
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