Details for: 4312-E (Part 1 of 1).pdf

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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

October 13, 2020
(U 338-E)

Information-Only Advice Letter, Southern California Edison
Company’s Modification of Demand Response Evaluation,
Measurement and Verification Plan for 2018-2022 Pursuant to
Decision 17-12-003

Southern California Edison (SCE) hereby submits this Information-Only Advice Letter
(Advice) to modify its Demand Response (DR) Process Evaluation, Measurement and
Verification (EM&V) Plan for the 2018-2022 schedule as set forth in Advice 3812-E and
its Attachment A.
In Advice 3182-E filed on June 1, 2018 and titled SCE’s Demand Response Evaluation,
Measurement and Verification Plan for 2018-2022 Pursuant to Decision 17-12-003,
SCE outlined its five-year EM&V plan (Plan) for SCE DR programs. This Plan included
two process evaluations for three DR programs: Critical Peak Pricing (CPP), Smart
Energy Program (SEP, formerly PTR), and Summer Discount Plan (SDP) Program. The
Plan included process evaluations for these three programs in the 2020 and 2022
program years. However, due to the unusual circumstances related to the COVID
pandemic and state and local government orders restricting normal customer activities,
SCE will delay its DR process evaluations to 2021 and eliminate the second evaluation
in 2022.
Ordering Paragraph (OP) 44 of Decision (D) 17-12-003 approved SCE’s EM&V program
and budget, and required SCE to hold a meeting with parties of Application (A.)17-01012 et al. to discuss the EM&V planning process and develop a five-year EM&V activity
schedule. The OP further required SCE to submit the five-year schedule by June 1,
On April 30, 2018, SCE complied with this directive by hosting a meeting, noticed on the
A.17.01-012 et al. service list, to discuss development of its EM&V plan. On June 1,
2018, in Advice 3182-E, SCE presented its five-year EM&V plan, found in Attachment
A, in compliance with OP 44.
P.O. Box 800

8631 Rush Street Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4312-E (U 338-E) -2- October 13, 2020 In Figure 2 on page 7 of Attachment A, SCE describes “Key Activities and Milestones (subject to change).” SCE outlined its EM&V activity timeline, which included a process evaluation of the three targeted DR programs in September 2020 and September 2022. DISCUSSION Because coronavirus-related state and several local stay-at-home orders have been in effect since March 2020, many SCE customers are spending significantly more time at home than is typical. In addition, due to COVID-related closures, customers participating in DR programs may not be able to take advantage of the usual alternative locations during DR dispatch events, such as movie theaters, beaches, shopping malls and restaurants. These circumstances in calendar year 2020 have likely also impacted commercial customers. The unusual nature of this situation affecting all classes of DR participants would result in process evaluations in 2020 that would not be truly representative for the three designated DR programs. As such, SCE will postpone process evaluations of CPP, SEP and SDP to 2021 and will cover the full Demand Response season through October 2021. As a result, SCE expects a process evaluation report for 2021 to be complete by the end of February 2022. The main objective of process evaluations is to identify potential future improvements to the program being evaluated. Process evaluations not only assess the way a program is designed, operated and delivered as authorized but also document program operations for stakeholder visibility. SCE expects the results of the 2021 process evaluations to provide information that will be more useful to program staff for improving features such as program efficiency, cost-effectiveness, and customer satisfaction. Because stay-athome orders have created an unusual situation in 2020, it is not an appropriate year to assess normal program functioning and identify process improvements. Process evaluations are conducted when sufficient time has passed for processes to mature so that studies can identify inefficiencies, areas of improvements, and benefits of the programs being evaluated. The programs selected by SCE for evaluation have either not been evaluated for over five years or are being evaluated for the first time. The California Evaluation Framework (Framework) provides a “consistent, systemized, cyclic approach for planning and conducting evaluations of California’s energy efficiency and resource acquisition programs."1 Prepared primarily for SCE in 2004, the Framework provides valuable information concerning when evaluations should be conducted, the types of evaluation that can be conducted, and a discussion of approaches for conducting those studies. Importantly, this Framework states that most programs do not need a process evaluation every year of their implementation cycle. (Framework, p. 214.) For these reasons, SCE will use the results of the 2021 evaluation as appropriate to improve the CPP, SEP and SDP DR programs and will not conduct another process evaluation in 2022. 1 The California Evaluation Framework, Prepared for the California Public Utilities Commission and the Project Advisory Group (June 2004), p. 1.
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ADVICE 4312-E (U 338-E) -3- October 13, 2020 SCE estimated $1,274,193 for EM&V in the 2018-2022 cycle representing two process evaluations. SCE had budgeted approximately 50 percent for the first evaluation due to be conducted in 2020, and 50 percent for the second evaluation in 2022. SCE had begun some preparatory work earlier in 2020 before it became apparent that postponing process evaluation to 2021 was the best course of action. Including this work already completed in 2020, SCE estimates that completing one round of process evaluation in 2021 will cost approximately 60 to 65 percent of the amount originally budgeted for the two process evaluations. As such, SCE expects to realize a cost savings of approximately 35 to 40 percent of the original estimate of $1,274,193 by conducting one process evaluation instead of the two evaluations planned for the 2018-2022 funding cycle. Further, SCE will reconcile any unspent program funds in 2023 in SCE’s annual Energy Resource Recovery Account (ERRA) Application as part of its reasonableness review of the Demand Response Program Balancing Account (DRPBA). After the 20182022 program cycle concludes, SCE will return any unspent uncommitted funds to ratepayers as provided in the DRPBA mechanism. This Advice will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule. TIER DESIGNATION This advice letter is being submitted as information-only. Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.1, this advice letter is submitted with a Tier 1 designation. EFFECTIVE DATE SCE requests that this Advice Letter be made effective on October 13, 2020, the same day as its submission to the Commission. PROTESTS In accordance with GO 96-B, Section 6.2, this information-only advice letter is not subject to protest. NOTICE In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this Advice Letter to the interested parties on the attached GO 96-B and A.17-01-012 et al service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-4039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 7032021 or by electronic mail at Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping this Advice Letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at
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ADVICE 4312-E (U 338-E) -4- October 13, 2020 For questions, please contact Jerilyn López Mendoza at (626) 201-1109 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:jlm:jm
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 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: Advice Letter (AL) #: Subject of AL: 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 #: Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: 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: No. of tariff sheets: -0- 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: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 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: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: Name: Title: Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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