Details for: SDG&E AL 2852-G-B.pdf


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Clay Faber - Director
Federal & CA Regulatory
8330 Century Park Court
San Diego, CA 92123
CFaber@sdge.com

June 29, 2020
ADVICE LETTER 2852-G-B
(U902-G)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
SUBJECT:

SUPPLEMENT: 2021 AND 2022 RATEMAKING FORECASTS FOR NATURAL
GAS LEAK ABATEMENT MEMORANDUM ACCOUNT (NGLAPMA),
NATURAL GAS LEAK ABATEMENT PROGRAM BALANCING ACOUNT
(NGLAPBA), AND NATURAL GAS LEAK ABATEMENT PROGRAM
SUBACOUNT (NGLAP) IN THE NEW ENVIRONMENTAL REGULATION
BALANCING ACCOUNT (NERBA)

PURPOSE
Pursuant to Energy Division’s request dated June 25, 2020, San Diego Gas and Electric
Company (SDG&E) hereby submits a supplemental advice letter to its 2021 and 2022
Ratemaking Forecasts for the NGLAPMA, NGLAPBA, and NGLAP in the NERBA, previously
submitted in Advice Letter No. (AL) 2852-G-A on June 12, 2020, as directed in Ordering
Paragraph (OP) 10 of the California Public Utilities Commission’s (CPUC or Commission) First
Phase Decision (D.) 17-06-015 and Second Phase D.19-08-020. This supplemental advice
letter replaces AL 2852-G-A in its entirety to revise the protest period.
BACKGROUND
On January 22, 2015, the CPUC issued Rulemaking (R.) 15-01-008 to implement provisions of
Senate Bill (SB) 1371. Phase I of R.15-01-008 was established to specifically address the
overall policies and guidelines for a natural gas leak abatement program consistent with SB
1371 and included the following program development activities: 1) information gathering,
measurement, and Best Practices; 2) targets, compliance, and reporting; and 3) training and
enforcement.
On June 15, 2017, the Commission adopted D.17-06-015 which, among other things, directed
SDG&E on or prior to October 31, 2017 to submit a Tier 3 Advice Letter (AL) to provide the
following to establish 2018 and 2019 revenue requirement forecasts and caps for the Natural
Gas Leak Abatement Program:





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Public Utilities Commission 2 June 29, 2020 a) Identify the incremental costs associated with each individual Best Practice, Pilot Projects and Research & Development (R&D), broken down by type of expenditure including capital, operations and maintenance, and administrative. b) Provide the justifications consistent with the criteria to evaluate Pilot Projects and R&D in Pub. Util. Code § 740.1. c) The proposed allocation methodology for amortization of the account and the corresponding Commission decision authorizing the allocation methodology.1 Additionally, OP 11 authorized the Director of Energy Division to recommend a process for reviewing cost forecasts and the methods for cost recovery in response to the Tier 3 ALs. OP 12 states the ratemaking forecasts and caps that the Commission approves in response to the Tier 3 ALs shall apply until ratemaking amounts and treatment for the Natural Gas Leak Abatement Program for 2020 and beyond, including Best Practices, Pilot Projects and R&D, are reviewed and established in each Utility’s2 next General Rate Case (GRC) or other gas ratemaking proceeding. On October 31, 2017, in compliance with D.17-06-015, SDG&E submitted its Tier 3, AL 2621-G. After the total cost estimates were finalized for AL 2621-G, SDG&E identified updates were needed to the cost estimates. On March 14, 2018, SDG&E submitted supplemental AL 2621-GA, which replaced AL 2621-G in its entirety, to update the cost estimates. Pursuant to the Energy Division’s request to update the total cost estimates in AL 2621-G-A, on July 31, 2018, SDG&E submitted supplemental AL 2621-G-B, which replaced AL 2621-G-A in its entirety. On October 22, 2018 the Commission approved supplemental AL 2621-G-B. On August 15, 2019, the Commission adopted a Second Phase Decision, D.19-08-020, establishing additional policies, including requiring use of the Utility Proposed CostEffectiveness Methodology and two Cost-Benefit Analyses and restriction on rate recovery beginning in 2025, for methane emissions greater than 20% below the 2015 baseline levels. On January 16, 2020, the CPUC voted to modify the Commission’s GRC plan, adopting an extension of the GRC cycle for each utility from three years to four years and extended SoCalGas current GRC through 2023.3 Therefore, this AL is submitted to inform regarding: 1) Forecasted costs for 2021, 2022, and associated Best Practices, as shown in Tables 1 through 3; and 2) Expected upcoming ratemaking applications (GRC, Triennial Cost Allocation Proceeding, etc.) to address future costs for the Natural Gas Leak Abatement Program and predicted date of application. Pursuant to Energy Division’s request dated April 16, 2020, on June 12, 2020, SDG&E submitted a supplemental advice letter to its 2021 and 2022 Ratemaking Forecasts for the NGLAPMA, NGLAPBA, and NGLAP in the NERBA, previously submitted in AL 2852-G on March 12, 2020. AL 2852-G-A replaced AL 2852-G in its entirety to eliminate the thousands 1 D.17-06-015 at pp. 161-162, OP 10. The Utilities are Pacific Gas and Electric Company, SoCalGas, and San Diego Gas and Electric Company. 3 In compliance with D.20-01-002, on April 9, 2020 SoCalGas and SDG&E submitted a joint petition to modify the Test Year (TY) 2019 GRC Decision (D.19-09-051) to extend their current authorized GRC periods through 2023. SoCalGas’ next GRC application will be for a TY 2024 and will be filed by May 15, 2022. 2
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Public Utilities Commission 3 June 29, 2020 reference in the title of Tables 1 through 3, provide updated cost forecasts, and include discussion on the emission reduction forecast. However, AL 2852-G-A included a request to waive the protest period because no protest was received to the initial advice letter. On June 25, 2020, Energy Division directed SDG&E to supplement AL 2852-G-A with a shortened protest comment period of ten (10) days, since no protests were submitted to the initial advice letters. Therefore, this supplemental advice letter replaces AL 2852-G-A in its entirety to revise the protest period. This funding request of $13.2 million4 in loaded, escalated 2020 dollars is forecasted to achieve measurable emission reductions. Annual estimated emission reductions resulting from activities proposed in SDG&E’s 2020 Compliance Plan from 2021 – 2030 are estimated at 5,280 MCF, an estimated 2% reduction from SDG&E’s 2015 emissions inventory baseline of 282,047 MCF. It should be noted that the 2015 baseline is expected to be adjusted in the future due to reporting adjustments and corrections. As such, the estimated percentage reduction will likely change as a result of the updated 2015 baseline. The current estimated 2% reduction in emissions from the 2015 baseline by 2030 is based on the published 2015 baseline, currently approved reporting metrics, and emission models of costeffective measures using currently available technologies and information. Emission models used to forecast reductions will have some degree of variation, and the projected reduction may vary in practice. As proposed research projects and pilots are completed, more accurate modeling may be available for activities such as the installation of methane sensors, transmission pipeline leaks, accelerated repair of minor leaks, and more frequent above-ground leak inspection and repair. In addition, as pilots are concluded, more accurate forecasts may be attainable, and new technologies may become commercially available to further reduce emissions beyond what is currently forecasted. As stated in D.19-08-020, “SDG&E and Southwest Gas (Class B Utilities) have less capability to influence emissions reduction since the percent of their population-based emissions are 90 percent and 97.4 percent, respectively….In addition, these two utilities are responsible for a relatively small percentage of total statewide reported methane emissions (7 percent).”5 As such, SDG&E is not being held to a hard target for emissions reductions. Because 90% of SDG&E’s reported emissions are based on population-, facility-, or componentbased emission factors, forecasting more than a 2% reduction will not be possible until improved reporting metrics are adopted. SDG&E does not have a non-hazardous leak inventory and has already implemented the 26 Mandatory BPs, including more frequent leak surveys. SDG&E has faster average leak repair when compared with other California natural gas utilities6, and therefore less opportunity to reduce methane emissions. Although changes to reporting metrics and emerging technologies may create opportunities for further emission reductions in the future, SDG&E currently cannot forecast a pathway to achieving a 40% emission reduction. 4 The total forecasted revenue requirement is $15.8 million, as illustrated on tables 1-3 herein. Id. at 53. 6 CPUC’s Safety Enforcement Division (SED) Analysis of the Utilities' June 17, 2019, Natural Gas Leak and Emission Reports, p. 40. 5
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Public Utilities Commission 4 June 29, 2020 SDG&E’s FORECASTED COSTS FOR 2021 AND 2022, AND ASSOCIATED BEST PRACTICES Table 1 - Forecasted Costs for Two-Way Balancing Account by Chapter in Loaded 2019 Dollars Ch Chapter Description Addressed Best Practice # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Leak Survey Blowdown Reduction Damage Prevention Algorithm & Proactive Intervention Recordkeeping IT Project AVEVA Electronic Leak Survey Damage Prevention Public Awareness Pipe Fitting Specifications Repeat Offenders IT Systems Gas Speciation Public Leak Maps Methane GHG Policy Distribution Above Ground Leak Surveys Methane Emissions Minimization Training Total Program Summary (Direct) 15, 16 O&M Total 873,107 23, 3-7 27,000 600,000 627,000 29,875 663,894 693,769 2,009,311 24,25,26 171,000 - 171,000 387,222 - 387,222 412,292 9 237,760 702,012 939,772 488,373 779,818 1,268,190 1,570,367 2,919,060 - 2,919,060 4,042,807 - 4,042,807 4,285,773 20,700 750,528 771,228 22,904 830,453 853,357 1,137,333 1,100,000 - 1,100,000 1,332,936 - 1,332,936 1,420,221 22 400,000 - 400,000 458,656 - 458,656 488,351 26 66,786 - 66,786 151,235 - 151,235 161,026 17 200,000 - 200,000 452,892 - 452,892 482,214 20b 4,500 - 4,500 10,190 - 10,190 10,850 2 - - - - - - 19 - - - - - - 11,12 - - - - - - 6,019,913 2,052,540 8,072,453 9,340,311 2,274,165 11,614,475 9, 20b 20b 24,25,26 *Costs are inclusive of a 10% contingency Capital Total Program Summary (Revenue Requirement) Program Summary (Loaded)* - Measure Total 873,107 O&M Total 1,963,221 Capital Total - Measure Total 1,963,221 Measure Total 2,090,340 14,068,078
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Public Utilities Commission 5 June 29, 2020 The assumptions for the cost estimates above can be found in the 2020 Compliance Plan, which is organized by chapter and not all Best Practices appear chronologically. Table 2 - Forecasted Costs for One-Way Balancing Account in Loaded 2019 Dollars Ch Chapter Description Addressed Best Practice # R&D Program Summary (Direct) O&M Total Research & Development R&D Capital Total 842,905 Measure Total - 842,905 Program Summary (Loaded)* O&M Total Capital Total 1,142,097 Measure Total - Program Summary (Revenue Requirement) Measure Total 1,142,097 1,216,760 *Costs are inclusive of a 10% contingency The assumptions and details for the R&D cost estimates above can be found in the 2020 Leak Abatement Compliance Plan, which also provides the justifications consistent with the criteria to evaluate Pilot Projects and R&D pursuant to Pub. Util. Code § 740.1. Table 3 – Forecasted Costs for Memorandum Account in Loaded 2019 Dollars Program Summary (Direct) Memo Account Capital Total Measure Total Program Summary (Revenue Requirement) Measure Total - 452,892 482,214 Program Summary (Loaded)* Program Administration O&M Total 200,000 Capital Total Measure Total - 200,000 O&M Total 452,892 *Costs are inclusive of a 10% contingency The cost estimates for the program administration were based on historical costs and estimated labor to complete the Annual Emissions report and 2022 Compliance Plan.
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Public Utilities Commission 6 June 29, 2020 ALLOCATION METHODOLOGY FOR AMORTIZATION OF THE ACCOUNT AND CORRESPONDING COMMISSION DECISION AUTHORIZING THE ALLOCATION METHODOLOGY Consistent with the 2018 Compliance Plan, SDG&E proposes to allocate the projected year-end balances pertaining to natural gas leak abatement programs using the Equal Percent of Authorized Margin (EPAM) method. The EPAM method allocates the balance in an account across customer classes based on each customer class’ share of the total GRC base margin allocated to that customer class as shown in Table 4. This proposed method is consistent with how a regulatory account balance that benefits all customer classes is allocated in a GRC.7 Updated rate impacts can be found in Attachment A. The rate impacts are compared to current rates with 2020 NGLAP amortization of $3.24 million. Table 4 - SDG&E NGLAP Cumulative Revenue Requirement and Annual for 2021, 2022 Cumulative Revenue Requirement (without FF&U) ($000) $412 Annual Revenue Requirement ($000) 2021 2022 204 208 Future costs for the Natural Gas Leak Abatement Program Future costs for the Natural Gas Leak Abatement Program for SDG&E will ultimately be incorporated into the GRC. SDG&E anticipates submitting a future Tier 3 AL forecasting costs for 2023 and 2024 to align cost forecasts with the 2023 and 2024 Leak Abatement Compliance Plan at the same time the Compliance Plan is submitted, unless directed otherwise by the Commission. Due to the timing of SDG&E’s next GRC, SDG&E will also include the 2024 NGLAP forecast in its 2024 GRC application. The 2024 NGLAP forecast will be the same forecast as submitted/approved in its Tier 3 advice letter filing for 2023-2024 Leak Abatement Compliance Plan and is not intended to be re-litigated in the 2024 GRC but only to establish the test year revenue requirements associated with the NGLAP. Should the implementation of the 2024 GRC is delayed beyond January 1, 2024 and the 2024 NGLAP revenue requirement is incorporated in the January 1, 2024 gas transportation rates, a true-up adjustment will be recorded in the GRC Memorandum Account that will be established for the 2024 GRC proceeding. This will avoid double recovering these costs through rates implementing the NGLAP revenue requirements authorized in the Tier 3 advice letter submittal and in 2024 GRC. 7 For example, pursuant to D.16-06-054 (decision addressing SDG&E’s 2016 GRC), the balance in the Research, Development and Demonstration Expense Account (RDDEA) is allocated across all customer classes using the EPAM method. The balance in this account reflects costs associated with activities to benefit all customer classes.
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Public Utilities Commission 7 June 29, 2020 EFFECTIVE DATE OP 10 of D.17-06-015 directs SDG&E to submit this Advice Letter as Tier 3 pursuant to General Order (GO) 96-B and, as such, requires a Resolution to be issued by the Commission. SDG&E respectfully requests that it be approved by the Commission at the earliest opportunity. PROTEST Anyone may protest this advice letter to the California Public Utilities 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. Pursuant to the direction of Energy Division, SDG&E requests that the Commission maintain the original protest period designated in AL 2852-G and shorten the protest period for this supplemental submittal to 10 days. The protest must be made in writing and received by July 9, 2020, which is 10 days following the date this advice letter was submitted to the Commission. There is no restriction on who may file a protest. The address for mailing or delivering a protest to the Commission is: CPUC Energy Division Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 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: Greg Anderson Regulatory Tariff Manager E-mail: GAnderson@sdge.com NOTICE A copy of this submittal has been served on the utilities and interested parties shown on the attached list, including interested parties in R.15-01-008, 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 SDG&ETariffs@SDGE.com. ___________________________________ CLAY FABER Director – Federal & CA Regulatory
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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: Greg Anderson Phone #: 858-654-1717 E-mail: GAnderson@sdge.com E-mail Disposition Notice to: SDGETariffs@sdge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 3 Advice Letter (AL) #: 2852-G-B Subject of AL: Supplement: 2021 and 2022 Ratemaking Forecasts for Natural Gas Leak Abatement Program Memorandum Account, Balancing Account and Subaccount (NGLAPMA, NGLAPBA & NGLAP) in the New Environmental Regulation Balancing Account (NERBA) 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.19-08-020 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: 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: EDTariffUnit@cpuc.ca.gov 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: GAnderson@sdge.com Name: Title: Utility Name: Address: City: State: California 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 R.15-01-008
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San Diego Gas & Electric Advice Letter 2852-G-B June 29, 2020 ATTACHMENT A
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Attachment A Advice Letter 2852-G-B San Diego Gas & Electric Leak Abatement 2022 At Present Rates 5/1/2020 Average Volumes Rate mtherms $/therm A B 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 5/1/2020 Revenues $000's C At Proposed Rates 1/1/2021 Average Volumes Rate mtherms $/therm D E 1/1/2021 Revenues $000's F Revenues $000's G Rates $/therm H Rate change % I CORE Residential Comml & Industrial 313,234 194,777 $1.42424 $0.54940 $446,120 $107,011 313,234 194,777 $1.41639 $0.54717 $443,663 $106,576 ($2,457) ($436) ($0.00784) ($0.00224) -0.6% -0.4% NGV Pre Sempra-Wide Sempra-Wide Adjustment NGV Post Sempra-Wide 24,129 24,129 24,129 $0.34574 ($0.03352) $0.31222 $8,342 ($809) $7,534 24,129 24,129 24,129 $0.34482 ($0.03378) $0.31104 $8,320 ($815) $7,505 ($22) ($6) ($28) ($0.00092) ($0.00026) ($0.00118) -0.3% 0.8% -0.4% 532,140 $1.05360 $560,664 532,140 $1.04811 $557,743 ($2,921) ($0.00549) -0.5% NONCORE COMMERCIAL & INDUSTRIAL Distribution Level Service Transmission Level Service (2) Total Noncore C&I 29,376 17,569 46,945 $0.23980 $0.03781 $0.16420 $7,044 $664 $7,709 29,376 17,569 46,945 $0.23900 $0.03766 $0.16365 $7,021 $662 $7,682 ($23) ($3) ($26) ($0.00080) ($0.00015) ($0.00056) -0.3% -0.4% -0.3% NONCORE ELECTRIC GENERATION Distribution Level Service Pre Sempra Wide Sempra Wide Adjustment Distribution Level Post Sempra Wide Transmission Level Service (2) Total Electric Generation 68,867 68,867 68,867 461,363 530,230 $0.17340 $0.00513 $0.17853 $0.03432 $0.05305 $11,942 $353 $12,295 $15,832 $28,127 68,867 68,867 68,867 461,363 530,230 $0.17280 $0.00500 $0.17780 $0.03417 $0.05282 $11,900 $345 $12,245 $15,763 $28,007 ($42) ($9) ($50) ($70) ($120) ($0.00060) ($0.00013) ($0.00073) ($0.00015) ($0.00023) -0.3% -2.5% -0.4% -0.4% -0.4% 577,175 $0.06209 $35,836 577,175 $0.06183 $35,690 ($146) ($0.00025) -0.4% 1,109,315 $0.53772 $596,500 1,109,315 $0.53495 $593,433 ($3,067) ($0.00277) -0.5% Total CORE 23 24 TOTAL NONCORE 25 26 System Total Changes
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Attachment A Advice Letter 2852-G-B San Diego Gas & Electric Leak Abatement 2022 At Present Rates 5/1/2020 Average Volumes Rate mtherms $/therm A B 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 5/1/2020 Revenues $000's C At Proposed Rates 1/1/2022 Average Volumes Rate mtherms $/therm D E 1/1/2022 Revenues $000's F Revenues $000's G Rates $/therm H Rate change % I CORE Residential Comml & Industrial 313,234 194,777 $1.42424 $0.54940 $446,120 $107,011 313,234 194,777 $1.41641 $0.54718 $443,669 $106,578 ($2,451) ($433) ($0.00782) ($0.00222) -0.5% -0.4% NGV Pre Sempra-Wide Sempra-Wide Adjustment NGV Post Sempra-Wide 24,129 24,129 24,129 $0.34574 ($0.03352) $0.31222 $8,342 ($809) $7,534 24,129 24,129 24,129 $0.34483 ($0.03373) $0.31110 $8,320 ($814) $7,506 ($22) ($5) ($27) ($0.00091) ($0.00021) ($0.00112) -0.3% 0.6% -0.4% 532,140 $1.05360 $560,664 532,140 $1.04813 $557,753 ($2,911) ($0.00547) -0.5% NONCORE COMMERCIAL & INDUSTRIAL Distribution Level Service Transmission Level Service (2) Total Noncore C&I 29,376 17,569 46,945 $0.23980 $0.03781 $0.16420 $7,044 $664 $7,709 29,376 17,569 46,945 $0.23901 $0.03767 $0.16366 $7,021 $662 $7,683 ($23) ($3) ($26) ($0.00079) ($0.00014) ($0.00055) -0.3% -0.4% -0.3% NONCORE ELECTRIC GENERATION Distribution Level Service Pre Sempra Wide Sempra Wide Adjustment Distribution Level Post Sempra Wide Transmission Level Service (2) Total Electric Generation 68,867 68,867 68,867 461,363 530,230 $0.17340 $0.00513 $0.17853 $0.03432 $0.05305 $11,942 $353 $12,295 $15,832 $28,127 68,867 68,867 68,867 461,363 530,230 $0.17281 $0.00503 $0.17783 $0.03417 $0.05283 $11,901 $346 $12,247 $15,766 $28,013 ($41) ($7) ($48) ($66) ($114) ($0.00059) ($0.00010) ($0.00070) ($0.00014) ($0.00022) -0.3% -2.0% -0.4% -0.4% -0.4% 577,175 $0.06209 $35,836 577,175 $0.06185 $35,696 ($140) ($0.00024) -0.4% 1,109,315 $0.53772 $596,500 1,109,315 $0.53497 $593,449 ($3,051) ($0.00275) -0.5% Total CORE 23 24 TOTAL NONCORE 25 26 System Total Changes
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