Details for: SDG&E AL 3559-E.pdf

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Clay Faber - Director
CA & Federal Regulatory
8330 Century Park Court
San Diego, CA 92123-1548

June 26, 2020
(U 902-E)


Pursuant to Ordering Paragraph (OP) 8 of Decision (D.)18-12-003, issued on December 21, 2018,
San Diego Gas & Electric Company (SDG&E) files this information-only Tier 1 advice letter to
indicate whether or not certain biomass generation facilities that have power purchase
agreements (PPA) with SDG&E have certified their operation in compliance with applicable air
pollution control requirements during the reported time period. SDG&E has one Tree Mortality
(TM) facility through the Bioenergy Renewable Auction Mechanism (BioRAM) program that is
required to submit this attestation at this time.
Resolutions E-4770 and E-4805 required SDG&E, Southern California Edison and Pacific Gas &
Electric Company (the IOUs) to enter into contracts with certain biomass generation facilities that
consume prescribed amounts of dead and dying trees located in high-hazard zones. In response
to the above- mentioned Resolutions, SDG&E entered into a BioRAM PPA with HL Power
Company, LP (HLP) on November 14, 2016.1
The Commission approved D.18-12-003 on December 13, 2018, pertaining to the IOUs
establishing a non-bypassable charge for costs associated with tree mortality biomass energy
procurement. OP 8 of the Decision orders SDG&E to collect information on whether or not the
TM facility claims it is in compliance with the facility’s air pollution control requirements and,
beginning six months after issuance of D.18-12-003, provide a semi-annual, information-only
advice letter to the Commission confirming whether the TM facility under contract with SDG&E
has certified whether it complied with applicable air pollution control requirements over the
previous six months.2 If the requirements were not met, the advice letter must explain the
circumstances of the non-compliance and the steps taken by the TM facility operator to rectify the
non-compliance. If the non-compliance is ongoing, the advice letter must include the expected
resolution of the non-compliance. Each advice letter must also state whether any of SDG&E’s TM
contracts are with facilities operating in federal severe or extreme nonattainment areas for
particulate matter or ozone.


The HLP BioRAM PPA was approved in Advice Letter 3002-E, effective December 16, 2016.
D.18-12-003, page 29.



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Public Utilities Commission June 26, 2020 DISCUSSION Pursuant to OP 8 of D.18-12-003, SDG&E respectfully submits this information-only advice letter providing HLP’s attestation confirming that the facility operated in compliance with applicable air pollution control requirements between July 1, 2019 to the end of December 31, 2019. HLP’s compliance is documented in Attachment A, a compliance certificate issued by the Lassen County Air Pollution Control District. HLP has further attested that it does not operate in federal severe or extreme non-attainment areas for particulate matter or ozone. Please see Attachment A for applicable HLP attestation and supporting certification. EFFECTIVE DATE This filing is subject to Energy Division disposition and should be classified as Tier 1 pursuant to Ordering Paragraph 8 of D.18-12-003, which SDG&E respectfully requests become effective on June 26, 2020. PROTEST In accordance with GO 96-B Section 6.2, this information-only submittal is not subject to protest. NOTICE A copy of this filing has been served on the utilities and interested parties shown on the attached list, including interested parties in A.16-11-005 and R.18-07-003, by providing them a copy hereof either electronically or via the U.S. mail, properly stamped and addressed. Address changes should be directed to the email above. _____________________________ CLAY FABER Director – California & Federal Regulatory Attachment A (2 pages): • • Attestation from HL Power Company, LP, dated January 31, 2020 HL Power Title V Semiannual Compliance Certification and Deviation Report: 2nd Half 2
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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 (U902) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Joff Morales Phone #: 858-650-4098 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) #: 3559-E Subject of AL: Information Only - HL Power Company, LP, Confirmation of Tree Mortality Facility Compliance with Air Pollution Control Requirements 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.18-12-003 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: 6/26/20 No. of tariff sheets: N/A 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: 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: Greg Anderson Title: Utility Name: San Diego Gas & Electric Address: 8330 Century Park Court, CP32C City: San Diego Zip: 92123 State: California Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: 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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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 A.16-11-005 R.18-07-003
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San Diego Gas & Electric Advice Letter 3559-E June 25, 2020 ATTACHMENT A
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H.L. Power Cu., an affiliate of Greenleaf POWER Ianuary 31, 2020 Mr. Mike Ruzzo Origination Manager, Contract Management, Electric 8: Fuel Procurement San Diego Gas Electric Via Email Dear Mr. Ruzzo: Attached please find a copy of the Title Semiannual Compliance Certification and Deviation Report submitted by l-{L Power to Lassen County Air Pollution Control District, covering the period from June 1. 2019, to December 31, 2019. During the period, HL Power Company ms in compliance with all terms and conditions of its Tifle Major Facility Operating Permit (representing the facility's applicable air pollution control requirements]. There were no Air Quality Violations during this period. Excess emissions or deviations have been noted and reported in excess emissions reports or deviation reports generated at the time of the event. None of these instances led to a notice of violation being issued by any Governmental Authority. Please feel free to contact me at (916) 596-2503 should you have any questions. Best re rd Greg Coo Chief Operating Officer
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TITLE SEMIANNUAL COMPLIANCE CERTIFICATION AND DEVIATION REPORT: 2"“ HALF DISTRICT: LASSEN COUNTY AIR POLLUTION CONTROL DISTRICT FACILITY INFORMATION I FACILITY NAME: HL POWER COMPANY 2. EACILITY LOCATION: 732-U25 WENDEL ROAD, WENDEL, CA. 96136 3. FACILITY PERM!’ NUMBER: 18-98~TV-3 4. ASF PLANT ID: 06-035-00009 5. REPQRT PER JULY DECEMBER 31, 2019 METHODS USED TO DETERMINE COMPLIANCE I. MONITORING: EMISSIONS MONITORING PROGRAM, AND FER FORMANCE SOURCE TESTING (STACK TESTING) 2. RECORD KEEPINQ; RECORDS ARE GENERATED AND KEPT ON Fl'LE FOR ALL RI-ZQUIRED OPERATIONAL AND EMISSIONS MONITORING DATA. 3. REPORTING: QUARTERLY REPORTS ARE SUBMITTED LISTING ALL DEVIATIONS FROM PERMIT LIMITS WITH DETAILS PROVIDED. 4. TESTING: ANNUAL STACK TEST WAS CONDUCTED MAY 22”" 23”‘, 2019. TEST RESULTS DEMONSTRATED COMPLIANCE WITH ALL EMISSION LMITS. During the period of July I, 2018 December 31, 2019, HL Power Company was in compliance with all terms and conditions of its Major Facility Operating Permit. Excess emissions or deviations have been noted and reported in excess emissions reports or deviation reports generated at the time of the event. Additionally, Quarterly and Annual Reports have been submitted as required in the permit. Note that excess emissions due to start-ups and shutdowns are exempt by permit and are summarized on the Quarterly CEMS Summary Report, and are on tile in CEMs logs. I certify that, based on information and belief formed afler reasonable inquiry, the statements and information in this document and the quarterly reports are true, accurate, and complete. Jang13l,g020 File: TITLE ANNUAL COMPLIANCE CERTIFICATION 2019
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