Details for: PGE Comments on Draft Resolution E-5053.pdf


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Erik Jacobson
Director
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

February 21, 2020
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Subject:

Comments of Pacific Gas and Electric Company on Draft Resolution
E-5053

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) appreciates the opportunity to comment on
Draft Resolution E-5053 (the Draft Resolution) approving modifications proposed by
PG&E to administrative procedures implementing time-of-use (TOU) period
grandfathering for eligible behind-the-meter solar customers, as described in Advice
Letter (AL) 5476-E, filed January 31, 2019.
PG&E’s Comment:

A. The Commission Should Allow Filing a Tier 1 advice letter, instead of
the requested Tier 2
Due to the Commission’s stated approval of Proposal A 1, and that the basis of the
requested additional advice letter is to provide communication details in order to
enact Proposal A, PG&E believes a Tier 1 advice letter is appropriate and sufficient
and requests Commission consideration of changing the tier designation for the
advice letter.
PG&E is happy to provide additional detail of the expected communication with
customers, however we believe that due to the simplicity of the message and the
commonality of communication media choices (such as direct mail, on-bill
messaging and website FAQs), it is PG&E’s opinion that this requirement could
1

Proposal A is outlined in AL 5476-E and its approval is stated in Resolution E-5053





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PG&E Comments on Draft Resolution E-5053 -2- February 21, 2020 even be fulfilled outside of the advice letter process, or if necessary, as a Tier 1 Advice Letter. B. The Commission should allow an extension of the filing deadline by an additional 15 business days, changing the deadline from March 6th, 2020 to March 27th, 2020. The E-5053 Draft Resolution is due for vote on February 27th, 2020, and states that PG&E must file a Tier 2 Advice Letter exactly 6 business days later, on March 6th, 2020. It is PG&E’s opinion that this is not a reasonable amount of time to draft, review, approve, and submit an Advice Letter given our limited resources, the internal review process for such filings and many additional priorities which are largely derived from Commission decisions or requests. Regardless of whether Comment A, listed above, is accepted, PG&E believes that 20 business days is a more appropriate amount of time to accomplish what is being requested. Our Comment B is a request to move the deadline of March 6th, 2020 to March 27th, 2020. Moving the deadline to March 27th will not have any negative effect on the customers that would be affected by this Resolution. C. PG&E’s expected customer communication In advance of this request PG&E is preparing a written notification that is planned to be mailed directly to customers. This written notification contains a description of grandfathering, list of actions that impact eligibility, next steps, and the customer’s specific grandfathering expiration date. We are also preparing an onbill notice to notify the customer of their grandfathering timing. We are also in the process of updating our website FAQ page to provide further information on grandfathering and customer outreach expectations.
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PG&E Comments on Draft Resolution E-5053 -3- February 21, 2020 Respectfully submitted, /S/ Erik Jacobson Director, Regulatory Relations cc: Edward Randolph, Director, Energy Division Energy Division Tariff Unit Bridget Sieren-Smith, Energy Division Paul Phillips, Energy Division Service Lists: General Order 96-B, R.15-12-012, R.12-06-013, R.14-07-002, R.12-11-005, and A.16-06-013
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