Details for: 4164-E (Part 1 of 1).pdf


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

February 11, 2020
ADVICE 4164-E
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
SUBJECT:

Southern California Edison Company’s Request for Adjustment
to Program Administrative and Marketing Budget Caps for
Disadvantaged Communities - Green Tariff and Community
Solar Green Tariff Programs for 2021

PURPOSE
Pursuant to Ordering Paragraph (OP) 2 of the California Public Utilities Commission's
(Commission's or CPUC's) Resolution E-4999 (the Resolution), Southern California
Edison Company (SCE) hereby requests an adjustment to the Program Administrative
and Marketing, Education and Outreach (ME&O) budget caps for the Disadvantaged
Community Green Tariff (DAC-GT) and Community Solar Green Tariff (CSGT)
programs.
BACKGROUND
On June 3, 2019, the Commission issued Resolution E-4999 approving, with
modifications, tariffs to implement the DAC-GT and CSGT programs. OP 2 of the
Resolution requires SCE to submit an annual program budget estimate and an annual
ME&O plan via a Tier 1 advice letter by February 1 of every year, starting in 2020, for
the next program year. Additionally, OP 2 states that SCE, “shall allocate no more than
10 percent of each program's budget in a given year for program administration and no
more than 4 percent of each program's budget in a given year for ME&O.”1 In
compliance with OP 2, on February 3, 2020, SCE submitted Advice 4155-E with budget
estimates for the DAC-GT and CSGT programs for 2021. SCE’s budget allocations for
Program Administration and ME&O exceed the 10 percent and 4 percent caps
established in the Resolution.

1

Resolution E-4999 OP 2, p. 67
P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





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ADVICE 4164-E (U 338-E) -2- February 11, 2020 The Resolution acknowledges that program implementation needs may change over time and allows the IOUs to submit a Tier 3 advice letter requesting an adjustment to the 10 percent administrative and 4 percent ME&O budget allocations with an accompanying rationale for why the adjustment is warranted.2 This advice letter requests these adjustments for SCE’s DAC-GT and CSGT programs. DISCUSSION I. UPDATED PROGRAM BUDGET ESTIMATES FOR 2021 Within Advice 4155-E, SCE proposed budget estimates in 2021 of $1,660,500 for the DAC-GT offering and $1,501,500 for the CSGT offering, for a total of $3,162,000 for the two programs. For DAC-GT, SCE estimates total Program Administration costs of $1,107,000 and total ME&O costs of $509,500, which are 67 percent and 31 percent, respectively, of the total DAC-GT budget. For CSGT, SCE estimates total Program Administration costs of $1,107,000 and total ME&O costs of $350,500, which are 74 percent and 23 percent, respectively, of the total CSGT budget. For both programs, SCE’s proposed budget amounts for Program Administration exceed the 10-percent cap and the proposed budget amounts for ME&O exceed the 4-percent cap. II. RATIONALE FOR ADJUSTMENT TO PROGRAM ADMINISTRATION AND ME&O BUDGET CAPS The Resolution clarifies that, “[a]t a minimum, the annual program budgets must include line items for any above market generation costs, the 20 percent bill discount, program administration, and ME&O.”3 The caps for Program Administration and ME&O are calculated as a percentage of the total across all four categories. Therefore, if the budget for above-market generation costs and the 20-percent bill discounts are low, or even zero, in a given year, the 10-percent cap for Program Administration and 4-percent cap for ME&O would also be low. This is the situation for SCE in 2021. As stated in Advice 4049-E, SCE anticipated conducting the first DAC solicitation during Q4 of 2019. Advice 4049-E was approved on December 30, 2019, as such, SCE’s first DAC solicitation will not begin until the end of February 2020. Because SCE does not anticipate having DAC-GT or CSGT projects online in 2021 due to permitting, construction, and interconnection processes and timelines, SCE does not estimate any above-market generating costs or 20-percent bill discount costs for either program in 2021 (SCE expects to begin incurring these costs in 2022), which means the caps for Program Administration and ME&O will be low, and driven by the Program Administration and ME&O costs themselves. 2 3 Id. Id.
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ADVICE 4164-E (U 338-E) -3- February 11, 2020 In addition, in the Resolution, the Commission recognized that startup costs for the DAC programs would be higher in the early years of the program and exempted the Program Administration and ME&O budget cap for 2019-2020.4 Given that SCE does not anticipate having dedicated DAC resources coming online in 2021, SCE’s 2021 budget includes some Program Administration and ME&O startup costs that would have been incurred in 2020 under SCE’s originally anticipated schedule. Specifically, SCE’s IT budget of $973,000 for both the DAC-GT and CSGT programs, which represents 90 percent of the total Program Administration budget, has been moved to 2021.5 Also, SCE’s 2021 budget includes Target Marketing and Website development efforts for the DAC-GT and CSGT, which represent 44 percent and 64 percent, respectively, of the total ME&O budget. CONCLUSION SCE’s 2021 proposed budget for DAC-GT and CSGT is largely driven by SCE’s expectation that dedicated program resources will not be available until 2022. The timing results in a 2021 budget without any Above-Market Generation or 20-Percent Bill Discount costs. As a result, SCE’s costs for the two programs in 2021 stem primarily from Program Administration and ME&O, some of which are startup costs, which the Commission recognized would be higher during the early years of the program. As such, SCE requests Commission approval for its 2021 budget to be exempt from the 10-percent Program Administration and 4-percent ME&O budget caps, as was the case for 2019-2020. TIER DESIGNATION Pursuant to OP 2 of Resolution E-4999, this advice letter is submitted with a Tier 3 designation. EFFECTIVE DATE This advice filing will become effective upon Commission approval. NOTICE Anyone wishing to protest 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. Protests should be submitted to: 4 5 Id. Advice 4155-E, p. 5.
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ADVICE 4164-E (U 338-E) -4- February 11, 2020 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, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: 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 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 There are no restrictions on who may submit a protest, but the protest 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 General Order (GO) 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and R.14-07-002 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 302-4039. 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.
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ADVICE 4164-E (U 338-E) -5- February 11, 2020 For questions, please contact David LeBlond at (626) 302-9443 or by electronic mail at David.LeBlond@sce.com. Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:ee:jm
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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: 3 Advice Letter (AL) #: Subject of AL: Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: 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: 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: (415) 929-5515 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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