Details for: SCE Reply to Public Advocates Office Protest to Advice 4114-E.pdf

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

December 19, 2019
CPUC, Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Response of Southern California Edison Company to the Public
Advocates Office Protest of SCE’s Advice Letter 4114-E

Dear Energy Tariff Division Unit:
Southern California Edison (SCE) hereby responds to the Public Advocates Office
(CalAdvocates) December 11, 2019 Protest of SCE’s Advice Letter 4114-E
(CalAdvocates Protest).
On November 22, 2019, SCE submitted Advice Letter (Advice) 4114-E, requesting to
reallocate existing Self-Generation Incentive Program (SGIP) funds from the LargeScale Energy Storage Budget to the Residential Energy Storage Budget. CalAdvocates
submitted a protest to Advice 4114-E on December 11, 2019, stating that the
Commission should also require any projects assessing these increased funds to meet
the greenhouse gas (GHG) reduction requirements for New Residential Projects set
forth in Decision (D.)19-08-001.
CalAdvocates does not oppose the transfer of funds to the residential energy storage
projects; however, requests that the Commission deem any currently or newly waitlisted
projects as New Residential Projects under the rules in D.19-08-001, stating that
allowing waitlisted projects to remain part of the Legacy Project portfolio risks continuing
customer subsidization of GHG-increasing SGIP storage projects, which counters both
the Public Utilities (PU) Code Section 379.6(b)(1) and the Commission’s GHG reduction
goals for SGIP.1


See CalAdvocates Protest, p. 3.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645 FAX (626) 302-6396


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Energy Division Tariff Unit Page 2 December 19, 2019 SCE’s RESPONSE TO CALADVOCATES PROTEST SCE’s Request Is Not Counter to PU Code or the Commission’s GHG Reduction Goals California PUC 379.6(a)(1) states “It is the intent of the Legislature that the selfgeneration incentive program increase deployment of distributed generation and energy storage systems to facilitate the integration of those resources into the electrical grid, improve efficiency and reliability of the distribution and transmission system, and reduce emissions of greenhouse gases, peak demand, and ratepayer costs.” The CPUC further restricts eligibility into SGIP to distributed energy resources that achieve reductions in the emission GHGs in PUC 379.1(b)(1): “eligibility for incentives under the selfgeneration incentive program shall be limited to distributed energy resources that the commission, in consultation with the State Air Resources Board, determines will achieve reductions in emissions of greenhouse gases pursuant to the California Global Warming Solutions Act of 2006.” The Commission established SGIP guiding principles in D.11-09-015 that included support of technologies that produce fewer GHG emissions than they avoid from the grid.2 GHG reductions have been, and continue to be, a requirement of all projects funded with SGIP incentives. D.19-08-001 approved new GHG emission reduction eligibility requirements for SGIP to ensure that residential storage projects are aligned with discharge characteristics that will likely result in a reduction in GHG emissions and did not alter the statutory requirement that all technologies funded through SGIP must reduce GHG emissions. In accordance with D.19-08-001, these requirements were to be made effective as of April 1, 2020; however, in its most recent Decision, the Commission gave authority to the Program Administrators (PAs) to accept residential equity and equity resiliency applications and to implement new residential GHG eligibility criteria starting January 1, 2020, and up to April 1, 2020.3 As such, SCE’s request is in alignment with the PU code, and the Commissions GHG Reductions Goals. SCE’s Request to Reallocate Funds Meets Small Residential and Resiliency Needs CalAdvocates’ recommendation should be rejected because it has the potential to delay processing waitlisted and new applications. SCE requires additional funding to meet the expected increased demand for the small residential energy storage for the period of December 2019 through April 2020. D.19-08-001 mandates are not yet implemented, therefore “new” applications prior to April 1, 2020 (or the date D.19-08-001 is implemented) would not be required to abide to the new GHG reduction requirements. 2 3 See D.11-09-015, p. 8. See D.19-09-027, Ordering Paragraph 4.
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Energy Division Tariff Unit Page 3 December 19, 2019 Further, SCE’s request to reallocate funds will result in resiliency benefits which will potentially alleviate impacts of Public Safety Power Shutoff (PSPS) events due to dangerous weather conditions. Delaying processing waitlisted and new applications with these funds undermines the urgency of the applicants seeking resiliency during future PSPS events. SCE Will Adopt New GHG Eligibility Requirements as Early as Possible While the CPUC should reject CalAdvocates’ request to require projects to meet the GHG-emission-reduction rules that will apply to New Residential Projects as a condition of receiving the newly available funds,4 SCE finds it is reasonable to implement the new GHG eligibility and compliance requirements for all residential customers as early as possible. Given that OP4 of D.19-09-027 is not specific to Residential Equity and Equity Resiliency, it allows the PAs the authority to implement the GHG changes for all new residential customers and it would be reasonable also escalate the date of the new GHG rules for non-equity residential customers to the date determined by the PAs to be the earliest possible date of implementation. In addition, to further reduce GHG impacts, residential projects that are deemed legacy projects are required to sign an affidavit that they are 1) on a TOU tariff, dynamic tariff, or agree to integrate load through the California Independent System Operator’s Proxy Demand Response, or equivalent tariff; or 2) agrees to discharge the energy storage system in an amount equivalent to 52 complete cycles per year with discharges occurring during peak hours or peak day events of the applicable IOU service territory. While D.19-08-001 encourages developers to validate that these legacy residential customers enroll on SGIP-approved rates (with a peak time after 4:00 PM), the legacy customers who rely on TOU rates, or discharging characteristics during peak times, are likely to transition to the new approved TOU rates as they are rolled out in each of the PA’s service territory. 4 Id., p. 4.
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Energy Division Tariff Unit Page 4 December 19, 2019 CONCLUSION SCE respectfully requests the Commission to approve its request to reallocate SGIP funds from the Large-Scale Energy Storage Budget to the Residential Energy Storage Budget to meet current demand and alleviate impacts of PSPS events, with the understanding that the PAs should implement the modified incentives as soon as possible before the April 1, 2020 target start date. Sincerely, /s/ Gary A. Stern. Gary A. Stern, Ph.D. GAS:el/nh:cm cc: Edward Randolph, Director, CPUC Energy Division Franz Cheng, CPUC Energy Division Michael Campbell, Public Advocates Office Shannon O’Rourke, CPUC Energy Division Nora Hawkins, CPUC Energy Division Asal Esfahani, CPUC Energy Division Service List for R.12-11-005
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