Details for: PGE AL 4212-G-A_5756-E-A.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

February 21, 2020

Advice 4212-G-A/5756-E-A
(Pacific Gas and Electric Company ID U 39 M)

Public Utilities Commission of the State of California

Supplemental: Statewide ESA Policy and Procedures Manual Waiver
for Contractor to Distribute CARB Batteries to Qualifying ESA

The purpose of this Tier 1 advice letter is to inform the Commission about clean battery
storage units that will be provided to qualifying Energy Savings Assistance (ESA)
customers at no cost to either the ESA customers or the ESA Program. PG&E is
supplementing the original advice letter to correct an inadvertent error in the final
paragraph which left an incomplete sentence. PG&E submits this supplemental advice
letter with the sole purpose to make the sentence whole. This supplemental advice letter
replaces the original advice letter, AL 4212-G/5756-E, in its entirety.
In Quarter 4, 2019, the California Air Resources Board (CARB) approached PG&E about
an ESA leveraging opportunity. CARB is leveling a penalty on a manufacturer that
shipped diesel generators into CA. This manufacturer, as their fine, must now ship into
California $1.8M worth of clean battery storage units earmarked for vulnerable customers.
CARB contacted PG&E to ask if this manufacturer could leverage the ESA Program to
provide these units to PG&E vulnerable low income customers at low overhead costs. No
costs would be borne by the ESA Program.
PG&E’s ESA service provider has agreed to distribute and install these batteries to
eligible ESA customers at a low overhead cost, allowing maximum funding to be directed
at providing more clean battery storage units to customers.
Battery storage unit installation would occur while the ESA implementers are already in
customer homes doing measure assessments for the customer’s ESA participation. This
battery installation work will be completed at no cost to the ESA Program, and PG&E ESA
Program Managers will not manage this work. In the event there are claims of any kind


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Advice 4212-G-A/5756-E-A -2- February 21, 2020 against PG&E related to battery storage unit work performed by the ESA Service Provider for the battery storage units themselves, the Service Provider will indemnify, defend, and hold PGE harmless pursuant to the terms of this agreement. To leverage installation of these CARB penalty battery storage units, PG&E is providing a limited waiver to its Service Provider overriding the Statewide ESA Policy & Procedures Manual (P&P Manual) prohibitions against performing and billing non-ESA work while providing ESA. The P&P Manual’s Section 3.3.3 on “Other Work” reads: 3.3.3 Other Work Only work directly associated with providing ESA Program authorized services to participating customers may be billed to the ESA Program. The Service Provider is prohibited from selling other services to the customer or charging the customer for any other service.24 ____________________ 24 This provision does not preclude the possibility of requiring a co-payment for the installation of one or more measures, if approved by the utility. (Statewide ESA 2017-2020 Cycle P&P Manual, Final, revised October 2019, p.26) On January 22, 2020, PG&E discussed this P&P Manual restriction against performing and billing non-ESA work with Energy Division (ED) staff. PG&E discussed whether it needed to provide a contract waiver to its Service Provider enabling them to perform this non-ESA service. ED agreed with PG&E’s assessment that providing the CARB penalty battery storage units at no cost to the customer or the ESA Program does not conflict with P&P Manual Section 3.3.3. PG&E agreed to file a Tier 1 Advice Letter. PG&E includes a contract waiver allowing its Service Provider to provide the ARB penalty battery storage units while performing ESA in-home assessments since the P&P Manual’s Section 3.3.3 prohibits selling additional services to customers or billing them to the ESA Program, and the battery storage units are being provided at no cost to either the customer or the ESA Program. The original intent of this prohibition against performing other (non-ESA) work was to prevent contractors from selling additional services to “captive” low income customers while they were in their homes for the ESA Program. However the leveraging opportunity described herein would not be billed to the ESA Program, and does not involve selling additional services to customers who will receive the batteries at no cost. PG&E is pleased to help support this effort since it provides emergency preparedness benefits at no cost to vulnerable customers impacted by extended power outage interruptions. Low income customers provided battery storage units will experience reduced impact during extended power interruptions.
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Advice 4212-G-A/5756-E-A -3- February 21, 2020 Protests Pursuant to CPUC General Order 96-B, Section 7.5.1, PG&E hereby requests the protest period be waived. Effective Date Pursuant to General Order 96-B, Energy Industry Rule 5.1, this advice letter is submitted with a Tier 1 designation, which is the same Tier designation as requested in Advice Letter 4212-G/5756-E. This advice letter will become effective concurrent with original Advice Letter 4212-G/5756-E, which is February 6, 2020. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service list for A.19-11-003, A.19-11-004, A.19-11-005, A.19-11-006, and A.19-11007. Address changes to the General Order 96-B service list should be directed to PG&E at email address For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter submittals can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations cc: Service Lists A.19-11-003, A.19-11-004, A.19-11-005, A.19-11-006, and A.19-11007
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39 M) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Kimberly Loo Phone #: (415)973-4587 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 4212-G-A/5756-E-A Subject of AL: Supplemental: Statewide ESA Policy and Procedures Manual Waiver for Contractor to Distribute CARB Batteries to Qualifying ESA Customers 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: No 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: 2/6/20 No. of tariff sheets: 0 Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A 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: N/A Service affected and changes proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 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: Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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PG&E Gas and Electric Advice Submittal List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Cameron-Daniel, P.C. Casner, Steve Cenergy Power Center for Biological Diversity Chevron Pipeline and Power City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Engineers and Scientists of California Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF IGS Energy International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Peninsula Clean Energy Pioneer Community Energy Praxair Redwood Coast Energy Authority Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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