Details for: PGE AL 4228-G_5790-E.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

March 23, 2020

ADVICE 4228-G/5790-E
(Pacific Gas and Electric Company ID U 39 M)

Public Utilities Commission of the State of California

Post-retirement Benefits Other than Pensions (PBOPs) for the
period from 2017 to 2019

Pacific Gas and Electric Company (PG&E) hereby submits this advice submittal in
compliance with the requirement in Decision (D.) 95-12-055 in PG&E’s 1996
General Rate Case (GRC), Application (A.) 94-12-005, to provide a reconciliation
of the revenue requirement associated with contributions to the PBOPs and Long
Term Disability (LTD) trusts. Although the decisions in PG&E’s intervening GRCs
through the 2011 GRC continued to require these reconciliations, D.17-05-013 in
PG&E’s 2017 GRC did not restate this requirement. Contributions to the trusts
matched the amounts adopted in D.17-05-013 for 2017, 2018 and 2019.
Accordingly, no adjustment to PG&E’s revenue requirements during 2017 to 2019
is necessary.
This submittal is made in compliance with D.95-12-055 (OP 8, as modified by
D.96-05-010) in PG&E’s 1996 GRC (A.94-12-005), decisions in PG&E’s
intervening GRCs, and D.92-12-015 regarding ratemaking for PBOPs
contributions. In the Settlement of the 2007 GRC, the Office of Ratepayer
Advocates (ORA) and PG&E agreed to a consolidated approach for the adopted
contribution amounts for PBOPs and LTD. For example, if the amount adopted for
the contribution to the PBOP medical plan trust could not be contributed to the
plan’s trust on a tax deductible basis, the amount could be contributed to the LTD
trust (up to the maximum tax deductible amount). This approach has continued
through the 2017 GRC cycle.
The following table shows that the contributions to the PBOPs medical and life
and LTD trusts matched the amounts adopted in the 2017 GRC for the years
2017 to 2019:
2017 GRC Cycle (2017 - 2019)


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Advice 4228-G/5790-E 2 March 23, 2020 PBOPs Medical and Life and LTD Trust Contributions (including Medicare Part D)[a], [b], [c], [d] (Millions of Dollars) Line 1 2 3 4 Plan PBOP-Med PBOP-Life Long Term Disability (LTD) Sub-Total 5 6 7 8 Medicare Part D Subsidy PBOP-Med LTD Sub-Total 9 2017 20.1 3.6 31.9 55.6 2018 24.5 30.8 55.3 2019 22.7 2.1 30.6 55.5 Total 67.3 5.8 93.3 166.4 5.0 0.3 5.3 3.7 .2 3.9 2.0 .1 2.1 10.7 .6 11.3 Total Contributions to Trusts 60.9 59.2 57.6 177.7 10 Adopted 55.5 55.5 55.5 166.4 11 Difference 5.4 3.8 2.1 11.3 [a] Totals do not add due to rounding [b] All Trust contributions were tax deductible. [c] Due to an administrative error, $0.3 million of the 2019 contribution was made in 2020. [d] The net over contribution is due to the Medicare Part D subsidy received from Centers for Medicare and Medicaid Services (CMS) which PG&E and the labor unions agreed would be credited to retirees and, therefore, are additional contributions to the PBOPs medical and LTD trusts. Since the amounts contributed to the trusts matched the amount adopted in the 2017 GRC decision, no adjustment to PG&E’s revenue requirement is necessary. This submittal will not affect any other rate or charge, cause the withdrawal of service, or conflict with any other rate schedule or rule. Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than April 13, 2020, which is 21 days1 after the date of this submittal. Protests must be submitted to: 1 The 20-day protest period concludes on a weekend, therefore, PG&E is moving this date to the following business day.
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Advice 4228-G/5790-E 3 March 23, 2020 CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date Pursuant to General Order (GO) 96-B, Rule 5.2, this advice letter is submitted with a Tier 2 designation. PG&E requests that this Tier 2 advice submittal become effective on regular notice, April 22, 2020, which is 30 calendar days after the date of submittal. 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
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Advice 4228-G/5790-E 4 March 23, 2020 and the parties on the service list for A.15-09-001. 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 List for A.15-09-001
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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: Annie Ho Phone #: (415) 973-8794 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: 2 Advice Letter (AL) #: 4228-G/5790-E Subject of AL: Post-retirement Benefits Other than Pensions (PBOPs) for the period from 2017 to 2019 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 #: D.95-12-055 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: 4/22/20 No. of tariff sheets: N/A 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 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 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. Los Angeles County Integrated Waste Management Task Force MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Peninsula Clean Energy Pioneer Community Energy 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 Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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