Details for: SDG&E Advice Letter 2867-G.pdf


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Clay Faber - Director
Regulatory Affairs
8330 Century Park Court
San Diego, CA 92123
cfaber@sdge.com

May 20, 2020
ADVICE LETTER 2867-G
(U902-G)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
SUBJECT:
027

Updated Greenhouse Gas Balancing Account Pursuant to Decision 20-03-

San Diego Gas & Electric Company (SDG&E) hereby submits this advice letter for approval to
the California Public Utilities Commission (Commission) revisions to its Gas Preliminary
Statement Section IV Balancing Accounts, as shown on Attachment A.
PURPOSE
The purpose of this Advice Letter (AL) is to update SDG&E’s Greenhouse Gas Balancing
Account (GHGBA) to reflect SDG&E’s remittance of the Technology and Equipment for Clean
Heating (TECH) Initiative and the Building Initiative for Low-Emissions Development (BUILD)
funding to Southern California Edison (SCE) pursuant to Senate Bill (SB) 1477, Resolution
(Res.) G-3565, and Decision (D.) 20-03-027.
BACKGROUND
SB 1477 required the Commission to develop and supervise the administration of the TECH and
BUILD Program, these pilot programs are designed to develop market experience for the
purpose of decarbonizing California’s residential buildings. SB 1477 further required that the
Commission, for Fiscal Year (FY) 2019–20 to 2022–23, inclusive, allocate $50,000,000 annually
across the four gas utilities1 to fund the TECH Initiative and the BUILD Program.2 The source of
program funding is the proceeds, including any accrued interest, received by gas utilities from
the direct allocation of GHG emissions allowances from the market-based compliance
mechanism overseen by the California Air Resources Board (CARB), also known as the Capand-Trade Program.
Pursuant to Res. G-3565, SDG&E submitted AL 2843-G3 that reduced the annual forecast of
funding available to customers for the Climate Credit refund by the authorized annual funding

Four gas corporations currently participate in California’s Cap-and-Trade program: Southern California
Gas Company, Pacific Gas & Electric Company, San Diego Gas & Electric Company, and Southwest Gas
Corporation
2Per Res. G-3565 and D.20-03-027, SDG&E was allocated $3,385,000 (6.77%) annually
3
AL 2843-G was submitted by SDG&E on February 18, 2020. AL 2843-G was approved by the
Commission on March 18, 2020.
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Public Utilities Commission 2 May 20, 2020 obligation of $3.385 million associated with the TECH Initiative and BUILD Program (collectively, “SB 1477 Compliance Costs”). On April 6, 2020, D.20-03-027 was issued which established a framework for Commission oversight of SB 1477 and the TECH Initiative and BUILD pilot programs. DISCUSSION Ordering Paragraph (OP) 4 of D. 20-03-027 assigned SCE to be the contracting agent responsible for (a) managing the solicitation for the third-party implementer of the TECH Initiative; and (b) disbursing funds to both the TECH Initiative implementer and the BUILD Program administrator. Further, OP 7 and 8 of D. 20-03-027 direct SDG&E and the other gas utilities to remit their respective SB 1477 Compliance Costs directly to SCE, the Contracting agent. Pursuant to OP 7, the gas utilities “…shall on or before June 1, 2020, disburse to the contracting agent the entire first year funding set aside as directed by Resolution G-3565”. Additionally, pursuant to OP 8, the gas utilities “… shall, beginning September 1, 2020, remit their respective "SB 1477 Compliance Costs" directly to the contracting agent on a quarterly basis in four equal installments per fiscal year. Remittances shall be made on or before March 1, June 1, September 1, and December 1. Funding obligations shall cease following the remittances made on June 1, 2023 unless otherwise directed by a subsequent decision of the Commission. Therefore and pursuant to the SB 1477 Compliance Costs to be sent directly to SCE per D.2003-027, SDG&E includes as Attachment A an update to its GHGBA to reflect SDG&E’s remittance of the SB 1477 Compliance Costs for the TECH and BUILD pilot programs to SCE and an update to the accounting procedures. EFFECTIVE DATE SDG&E believes this submittal is subject to Energy Division disposition and should be classified as Tier 1 (effective pending disposition) pursuant to General Order (GO) 96-B. SDG&E respectfully requests that this submittal be effective on May 20, 2020, which is the date filed. PROTEST Anyone may protest this Advice Letter to the Commission. The protest must state the grounds upon which it is based, including such items as financial and service impact, and should be submitted expeditiously. The protest must be made in writing and must be received no later than June 9, 2020 which is 20 days after the date this Advice Letter was submitted with the Commission. There is no restriction on who may submit a protest. The address for mailing or delivering a protest to the Commission is: CPUC Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102
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Public Utilities Commission 3 May 20, 2020 Copies of the protest should also be sent via e-mail to the attention of the Energy Division at EDTariffUnit@cpuc.ca.gov. A copy of the protest should also be sent via e-mail to the address shown below on the same date it is mailed or delivered to the Commission. Attn: Megan Caulson Regulatory Tariff Manager E-mail: MCaulson@sdge.com NOTICE A copy of this Advice Letter is being sent to SDG&E’s GO 96-B service list and the Commission’s service lists in R.14-03-003 and R.19-01-011, by providing them a copy hereof either electronically or via the U.S. mail, properly stamped and addressed. Address changes should be directed to SDG&E Tariffs by email to SDGETariffs@sdge.com. /s/ Clay Faber _______________________________ CLAY FABER Director – Regulatory Affairs
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: San Diego Gas & Electric Company (U902- G) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Brittany Malowney Phone #: (858) 637-3714 E-mail: BMalowney@sdge.com E-mail Disposition Notice to: BMalowney@sdge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 2867-G Subject of AL: Updated Greenhouse Gas Balancing Account Pursuant to Decision 20-03-027 Keywords (choose from CPUC listing): AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D. 20-03-027 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: N/A Summarize differences between the AL and the prior withdrawn or rejected AL: N/A 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: 5/20/20 No. of tariff sheets: 2 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: GREENHOUSE GAS BALANCING ACCOUNT (GHGBA) 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: EDTariffUnit@cpuc.ca.gov Name: Megan Caulson Title: Regulatory Tariff Manager Utility Name: San Diego Gas & Electric Company Address: 8330 Century Park Court; CP 31D 92123 City: San Diego State: California Telephone (xxx) xxx-xxxx: (858) 654-1748 Facsimile (xxx) xxx-xxxx: Email: MCaulson@sdge.com Name: SDG&E Tariff Department Title: Utility Name: San Diego Gas & Electric Company Address: 8330 Century Park Court; CP 31D 92123 City: San Diego State: California Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: SDGETariffs@sdge.com Clear Form
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cc: (w/enclosures) General Order No. 96-B ADVICE LETTER SUBMITTAL MAILING LIST Public Utilities Commission Clean Energy Renewable Fuels, LLC Office of Ratepayer Advocates (ORA) P. DeVille R. Pocta Clean Power Research T. Schmid Energy Division M. Ghadessi G. Novotny M. Salinas Davis Wright Tremaine LLP L. Tan J. Pau R. Ciupagea Douglass & Liddell Tariff Unit D. Douglass CA Energy Commission D. Liddell B. Penning Ellison Schneider Harris & Donlan LLP B. Helft E. Janssen Advantage Energy C. Kappel C. Farrell Energy Policy Initiatives Center (USD) Alcantar & Kahl LLP S. Anders M. Cade Energy Regulatory Solutions Consultants K. Harteloo L. Medina AT&T Energy Strategies, Inc. Regulatory K. Campbell Barkovich & Yap, Inc. EQ Research B. Barkovich General Braun & Blaising, P.C. Goodin, MacBride, Squeri, & Day LLP S. Blaising B. Cragg D. Griffiths J. Squeri CA Dept. of General Services Green Charge H. Nanjo K. Lucas California Energy Markets Hanna and Morton LLP General N. Pedersen California Farm Bureau Federation JBS Energy K. Mills J. Nahigian California Wind Energy Keyes & Fox, LLP N. Rader B. Elder City of Poway Manatt, Phelps & Phillips LLP Poway City Hall D. Huard City of San Diego R. Keen L. Azar McKenna, Long & Aldridge LLP J. Cha J. Leslie D. Heard Morrison & Foerster LLP F. Ortlieb P. Hanschen H. Werner MRW & Associates LLC M. Rahman General NLine Energy M. Swindle NRG Energy D. Fellman Pacific Gas & Electric Co. M. Lawson M. Huffman Tariff Unit RTO Advisors S. Mara SCD Energy Solutions P. Muller Shute, Mihaly & Weinberger LLP O. Armi Solar Turbines C. Frank SPURR M. Rochman Southern California Edison Co. K. Gansecki TerraVerde Renewable Partners LLC F. Lee TURN M. Hawiger UCAN D. Kelly US Dept. of the Navy K. Davoodi US General Services Administration D. Bogni Valley Center Municipal Water Distr G. Broomell Western Manufactured Housing Communities Association S. Dey Interested Parties in: R.19-01-011 R.14-03-003
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Page 1 of 1 ATTACHMENT A ADVICE LETTER 2867-G Cal. P.U.C. Sheet No. Title of Sheet Canceling Cal. P.U.C. Sheet No. Revised 24592-G PRELIMINARY STATEMENT, IV. BALANCING ACCOUNTS, GREENHOUSE GAS BALANCING ACCOUNT (GHGBA), Sheet 1 Revised 24370-G Revised 24593-G PRELIMINARY STATEMENT, IV. BALANCING ACCOUNTS, GREENHOUSE GAS BALANCING ACCOUNT (GHGBA), Sheet 2 Revised 22016-G Revised 24594-G TABLE OF CONTENTS, Sheet 1 Revised 24590-G 1
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Revised San Diego Gas & Electric Company San Diego, California Canceling Cal. P.U.C. Sheet No. 24592-G Revised Cal. P.U.C. Sheet No. 24370-G Sheet 1 PRELIMINARY STATEMENT IV. BALANCING ACCOUNTS GREENHOUSE GAS BALANCING ACCOUNT (GHGBA) 1. Purpose Pursuant to Decision (D.) 14-12-040, the Greenhouse Gas (GHG) Balancing Account (GHGBA) is a two-way, interest bearing balancing account that tracks and records costs incurred to comply with the California Air Resource Board’s (CARB) natural gas supplier Cap and Trade (C&T) Program costs, company facility (e.g., gas compressor station) GHG compliance costs, as well as the revenues received from consignment of natural gas supplier allowances for auction under the ARB Program (collectively, “GHG compliance costs”). Pursuant to D.15-10-032, the GHGBA will also separately identify and record GHG compliance costs associated with Lost and Unaccounted For (LUAF) gas. The GHGBA will record actual costs against actual revenues billed to applicable customers to recover such costs as authorized by the Commission and any corresponding authorized revenue requirement. This account is effective January 1, 2015, and modified on October 22, 2015, the effective date of D.15-10-032. Pursuant to D.18-03-017, effective March 22, 2018, the GHGBA will distribute GHG allowance proceeds as an annual credit to all eligible residential customers. Senate Bill (SB) 1477 requires the CPUC to develop and supervise the administration of the Technology and Equipment for Clean Heating (TECH) Initiative and the Building Initiative for LowEmissions Development (BUILD) Program. In compliance with Resolution (Res.) G-3565, SDG&E will reduce the annual forecast of funding available to customers for the Climate Credit refund by the authorized annual funding obligation of $3.385 million associated with the TECH Initiative and BUILD Program (collectively, “SB 1477 Compliance Costs”). Pursuant to D.20-03-027, effective April 6, 2020, SDG&E will remit its respective “SB 1477 Compliance Costs” directly to Southern California Edison (SCE), the Utility assigned to disburse funds to both the TECH Initiative Implementer and the BUILD Program administrator. Per Ordering Paragraph (OP) 7 of D.20-03-027, the entire first year funding shall be disbursed, on or before June 1, 2020. Further, OP 8 states that on a quarterly basis remittance shall be made on or before March 1, June 1, September 1, and December 1. Funding obligations shall cease following the remittances made on June 1, 2023 unless otherwise directed by a subsequent decision of the Commission. Lastly, OP 3 of D.20-03-027, states that any unspent funds remaining as of July 1, 2033, shall be returned to the ratepayers of the respective gas corporations as part of the California Climate Credit. 2. T N Applicability The GHGBA shall apply to all core and non-core gas customer classes except for those specifically excluded by the Commission. 3. Rates The balance in the GHGBA will be included in gas transportation rates. 4. Accounting Procedures The GHGBA shall include the following four subaccounts that will record the following entries at the end of the month, as applicable: End Users GHG Compliance Cost Subaccount: a) A debit entry to record an allocation of the cost of C&T allowance purchases and/or offsets based on actual GHG emissions associated with SDG&E’s natural gas deliveries to end users to comply with the C&T Program requirements; b) A credit entry equal to actual GHG revenues billed to customers for recovery of C&T Program compliance costs for natural gas deliveries to end users; (Continued) Issued by 1P5 Advice Ltr. No. Decision No. 2867-G Dan Skopec Vice President Regulatory Affairs Submitted Effective Resolution No. May 20, 2020 N N
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Revised San Diego Gas & Electric Company San Diego, California Canceling Cal. P.U.C. Sheet No. 24593-G Revised Cal. P.U.C. Sheet No. 22016-G Sheet 2 PRELIMINARY STATEMENT IV. BALANCING ACCOUNTS GREENHOUSE GAS BALANCING ACCOUNT (GHGBA) End Users GHG Compliance Cost Subaccount (continued): c) An entry to amortize the prior year ending balance as authorized by the Commission; d) An entry equal to the interest on the average of the balance in this account at the beginning of the month and the balance in this account after the above entries at a rate equal to one-twelfth the interest rate on three month Commercial paper for the previous month, as reported in the Federal Reserve Statistical Release, H.15, or its successor. 4. L L Accounting Procedures (continued) Company Facility GHG Compliance Cost Subaccount: a) A debit entry to record an allocation of the cost of C&T allowance purchases and/or offsets based on actual GHG emissions associated with SDG&E’s facilities to comply with the C&T Program requirements; b) A credit entry equal to actual GHG revenues billed to customers for recovery of C&T Program compliance costs for SDG&E’s facilities; c) An entry to amortize the prior year ending balance as authorized by the Commission; d) An entry equal to the interest on the average of the balance in this account at the beginning of the month and the balance in this account after the above entries at a rate equal to one-twelfth the interest rate on three month Commercial paper for the previous month, as reported in the Federal Reserve Statistical Release, H.15, or its successor. LUAF GHG Compliance Subaccount a) A debit entry to record an allocation of the cost of C&T allowances and/or offsets purchases based on actual GHG emissions associated with Lost and Unaccounted For (LUAF) gas to comply with the C&T Program requirements; b) A credit entry equal to actual GHG revenues billed to customers for recovery of C&T compliance costs for LUAF; c) An entry to amortize the prior year ending balance as authorized by the Commission: d) An entry equal to the interest on the average of the balance in this account at the beginning of the month and the balance in this account after the above entries at a rate equal to one-twelfth the interest rate on three month Commercial paper for the previous month, as reported in the Federal Reserve Statistical Release, H.15, or its successor. Consignment Revenues Subaccount: a) A credit entry equal to the revenues received from the consignment of natural gas supplier allowances for auction under the C&T Program; b) A debit entry equal to the portion of GHG revenues returned to customers; c) An entry to amortize the prior year ending balance as authorized by the Commission; d) An annual debit entry to transfer allowance proceeds to the Greenhouse Gas Administrative Cost Memorandum Account (GHGACMA) as authorized by the Commission; e) An entry to transfer funding for the TECH and BUILD pilot programs to SCE (including a return from SCE of any unspent funds remaining at the end of the programs); and f) An entry equal to the interest on the average of the balance in this account at the beginning of the month and the balance in this account after the above entries at a rate equal to one-twelfth the interest rate on three month Commercial paper for the previous month, as reported in the Federal Reserve Statistical Release, H.15, or its successor. 5. Disposition SDG&E will project the year-end balance and will include it in the Annual October Regulatory Account Balance Update Filing to be amortized in rates effective January 1 of the following year. Pursuant to D.15-10-032, SDG&E will also forecast the following year’s compliance costs and consignment revenues for inclusion in rates effective January 1 of the following year as well. Issued by 2P5 Advice Ltr. No. Decision No. 2867-G Dan Skopec Vice President Regulatory Affairs Submitted Effective Resolution No. May 20, 2020 C N N N N
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Revised San Diego Gas & Electric Company San Diego, California Canceling Cal. P.U.C. Sheet No. 24594-G Revised Cal. P.U.C. Sheet No. 24590-G Sheet 1 TABLE OF CONTENTS The following sheets contain all the effective rates and rules affecting rates, service and information relating thereto, in effect on the date indicated herein. Cal. P.U.C. Sheet No. 12805-G TITLE PAGE........................................................................... 24594, 24473, 24591, 24483, 24787-G T 24258, 24545, 20494, 19182-G TABLE OF CONTENTS......................................................... PRELIMINARY STATEMENT I. General Information.................................................... II. Statement of Rates..................................................... III. Cost Allocation and Revenue Requirement………. IV. Balancing Accounts Description/Listing of Accounts…………………….. Curtailment Penalty Funds Account (CPFA)……… California Alternate Rates for Energy (CARE) Balancing Account………………………………… Gas Energy Efficiency Balancing Account (GEEBA) Rewards & Penalties Balancing Account (RPBA)…. Pension Balancing Account (PBA)…………………. Post-Retirement Benefits Other Than Pensions Balancing Account (PBOPBA)……………………. Core Fixed Cost Account (CFCA)…………………... Noncore Fixed Cost Account (NFCA)………………. Post-2005 Gas Energy Efficiency Balancing Account (PGEEBA)………………………………… Post-2005 Gas Low Income Energy Efficiency Balancing Account (PGLIEEBA)……………………. Integrated Transmission Balancing Account (ITBA) Advanced Metering Infrastructure Account (AMIBA) Hazardous Substance Cleanup Cost Acct (HSCCA)… Distribution Integrity Management Program Balancing Account (DIPMBA)…………………….. On-Bill Financing Balancing Account (OBFBA)…… Post-2011 Distribution Integrity Management Program Balancing Account (P-11 DIMPBA)………… Transmission Integrity Management Program Balancing Account (TIMPBA)…………………. 7270, 19259-G 11981, 24581, 24445, 23748, 23574, 16688-G 20597, 23749, 24446, 24447, 14249, 7281-G 7489, 14250, 14251, 14252, 7493, 7494-G 15671, 21123-G 20599-G 15681, 15682-G 19260, 19261-G 19262, 19510-G 22923, 17754-G 22924, 17755-G 24448, 24449, 19266, 24450-G 24451, 20603, 19269-G 18442, 18443-G 15710, 15711-G 24452, 17882-G 16271, 17757, 16273-G 15741, 15742, 17651, 15744, 15745, 15746-G 15747, 19270, 15749, 15750, 15751-G 17172-G 18444-G 19974-G 19975-G New Environmental Regulatory Balancing Account (NERBA)………………………………………………. Master Meter Balancing Account (MMBA)……………. Safety Enhancement Capital Cost Balancing Account (SECCBA)………………………………………….. Safety Enhancement Expense Balancing Account (SEEBA)……………………………………….. Greenhouse Gas Balancing Account (GHGBA)…………. Smart Meter Opt-Out Balancing Account (SMOBA)…. Low Carbon Fuel Standard Balancing Account (LCFSBA) Biomethane Cost Incentive Program Balancing Account (BCIPBA)……………………………………………… (Continued) Issued by 1P5 Advice Ltr. No. Decision No. 2867-G Dan Skopec Vice President Regulatory Affairs 21026, 21027-G 21026-G, 21027-G 22098-G 22099-G 24592, 24593-G T 21113, 21114-G 21124-G 22429-G Submitted Effective Resolution No. May 20, 2020
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