Details for: PGE AL 5985-E.pdf


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Erik Jacobson
Director
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

October 29, 2020

Advice 5985-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California
Subject:

Request to Extend Procurement Authority Pursuant to Pacific Gas and
Electric Company’s Assembly Bill 57 Bundled Procurement Plan

Purpose
Pacific Gas and Electric Company (PG&E) hereby requests California Public Utilities
Commission (CPUC or Commission) approval to extend its procurement authority under
PG&E’s currently effective Assembly Bill (AB) 57 Bundled Procurement Plan, approved
by the Commission in 2015 (2014 BPP). Pursuant to its terms, the 2014 BPP will remain
in effect until December 31, 2024, or the date on which the 2014 BPP is superseded by
a subsequent Commission-approved bundled procurement plan, whichever is earlier. As
of the filing date, there is no schedule set to review and approve an update to the bundled
procurement plan. PG&E seeks to update its 2014 BPP to extend procurement authority
until the Commission approves an updated bundled procurement plan for PG&E.
Background
On December 30, 2013, the Commission issued R.13-12-010, “Order Initiating
Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term
Procurement Plans.”1 The Long-Term Procurement Plan (LTPP) proceedings, including
R.13-12-010, generally operated on a two-year cycle, with the IOUs submitting for
approval both procurement plans that projected their procurement needs over a 10-year
horizon and bundled procurement plans for authority to procure to meet those needs.
Pursuant to AB 57, codified at Public Utilities Code Section 454.5, the Commission’s
approval of the IOUs’ bundled procurement plans establishes up-front and achievable
standards for IOU procurement activities and cost recovery. Procuring in compliance with
the bundled procurement plans creates an efficient process that eliminates the need for
IOUs to seek approval of individual transactions through the advice letter or application
process.

1

See 15-10-031, p. 4.





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Advice 5985-E -2- October 29, 2020 On October 23, 2015, the Commission issued Decision (D.) 15-10-031 in R.13-12-010, approving, inter alia, PG&E’s 2014 BPP.2 PG&E’s approved 2014 BPP, as amended, governs procurement through December 31, 2024 and is limited to transactions with a duration of less than five years, for the 10-year planning period January 1, 2015 through December 31, 2024.3 Thus, PG&E’s ratable rates and position limits, products, transactional processes, and other rules described in the 2014 BPP represent upfront and achievable standards and criteria that establish PG&E’s pre-approved authority to procure resources through transactions with durations of less than five years that are per se eligible for cost recovery. However, given its 10-year planning period that expires on December 31, 2024, PG&E’s 2014 BPP five year procurement authority has become increasingly truncated starting with the sixth year of the planning period (e.g., in 2020, the maximum transaction duration has become increasingly less than five years; in 2021, it will become increasingly less than four years; in 2022, it will become increasingly less than three years; etc.), to the detriment of the efficient process adopted by the Commission in approving the 2014 BPP. On February 19, 2016, the Commission initiated R.16-02-007, “Order Instituting Rulemaking to Develop an Electricity Integrated Resource Planning Framework and to Coordinate and Refine Long-Term Procurement Planning Requirements,” (2016 IRP Proceeding). The 2016 IRP Proceeding essentially replaced the prior LTPP proceedings, with remaining issues from R.13-12-010 transferred to the 2016 IRP. The Commission opened R.20-05-003 (the 2020 IRP Proceeding) as the successor proceeding in May 2020 and then closed the 2016 IRP Proceeding in D.20-09-026. In opening the 2020 IRP Proceeding, the Commission stated that the procurement track of 2020 IRP Proceeding will be the venue for consideration of IOU bundled procurement plans, including any necessary changes to the 2014 BPP;4 however, the scoping memo issued in the 2020 IRP Proceeding on September 24, 2020 does not provide a clear schedule for such consideration.5 As such, the 2014 BPP remains in effect at this time, and any updates must be made via advice letter. PG&E Requests Extension of Its AB 57 Procurement Authority Pending Action by the Commission in the 2020 IRP Proceeding Currently, PG&E’s pre-approved AB 57 authority under the 2014 BPP is limited to contracts with a duration of less than five years through December 31, 2024. As a result, for each day that passes after January 1, 2020, PG&E’s pre-approved 5-year procurement authority is eroded by a day. In order to ensure PG&E’s ability to continue efficiently procuring through transactions with durations less than five years, PG&E’s 2 Since its approval in D.15-10-031, PG&E has submitted and obtained disposition and/or approval of various advice letters updating the 2014 BPP. 3 2014 BPP, Sheets 1, 32; see also D.07-12-052, p. 172; D.14-02-040, p. 39; D.19-08-014, p. 6. 4 Rulemaking 20-05-003, Order Instituting Rulemaking to Continue Electric Integrated Resource Planning and Related Procurement Processes, issued May 14, 2020, p. 10. 5 Rulemaking 20-05-003, Assigned Commissioner’s Scoping Memo and Ruling, issued September 24, 2020, pp. 11-12.
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Advice 5985-E -3- October 29, 2020 2014 BPP procurement authority must be extended beyond December 31, 2024, unless the 2014 BPP is superseded by a subsequent Commission-approved bundled procurement plan prior to that date. Therefore, PG&E requests that the Commission extend PG&E’s procurement authority under its 2014 BPP on a rolling basis, effective as of the approval of this advice letter, until an updated or new bundled procurement plan is approved for PG&E in the 2020 IRP Proceeding or elsewhere. This authority will enable PG&E to continue to procure maximum transactions of less than five years under the 2014 BPP, consistent with the upfront and achievable standards required by AB 57, unless and until an updated or new PG&E bundled procurement plan is approved. Attachment A sets forth PG&E’s requested modifications to its 2014 BPP to effectuate this extension. Attachments Attachment A Redline Edits, BPP (Sheet 1, 32) Attachment B Clean BPP (Sheet 1, 32) Protests ***Due to the COVID-19 pandemic and the shelter at home orders, PG&E is currently unable to receive protests or comments to this advice letter via U.S. mail or fax. Please submit protests or comments to this advice letter to EDTariffUnit@cpuc.ca.gov and PGETariffs@pge.com*** Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or E-mail, no later than November 18, 2020, which is 20 days after the date of this filing. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: EDTariffUnit@cpuc.ca.gov 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:
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Advice 5985-E -4- October 29, 2020 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: PGETariffs@pge.com 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 PG&E requests that this Tier 3 advice letter become effective by no later than December 31, 2020, and that the Commission issue a resolution by that date. 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 and the parties on the service list for R.16-02-007 and R.20-05-003. Address changes to the General Order 96-B service list should be directed to PG&E at email address PGETariffs@pge.com. For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter filings can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List R.16-02-007, R.20-05-003
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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 U39E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Kimberly Loo Phone #: (415)973-4587 E-mail: PGETariffs@pge.com E-mail Disposition Notice to: KELM@pge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 3 Advice Letter (AL) #: 5985-E Subject of AL: Request to Extend Procurement Authority Pursuant to Pacific Gas and Electric Company’s Assembly Bill 57 Bundled Procurement Plan Keywords (choose from CPUC listing): Compliance, Procurement 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: 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: No. of tariff sheets: 0 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: EDTariffUnit@cpuc.ca.gov 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: PGETariffs@pge.com 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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Advice 5985-E October 29, 2020 Attachment A Redline Edits, BPP (Sheet 1, 32)
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Pacific Gas and Electric Company San Francisco, California I. Cal. P.U.C. Sheet No. 1 Pacific Gas and Electric Company 2014 Bundled Procurement Plan Introduction In accordance with the Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judge, issued May 6, 2014 in Rulemaking (“R.”) 13-12-010, Pacific Gas and Electric Company (“PG&E”) is filing its Bundled Procurement Plan (“BPP”) covering the period from the date the BPP is approved to December 31, 2024 until an updated or new BPP is approved for PG&E in a formal BPP proceeding initiated within the Integrated Resources Plan ProceedingRulemaking 20-05-003 or elsewhere. PG&E’s BPP became effective on October 22, 2015, the date the California Public Utilities Commission (“CPUC” or “Commission”) adopted Decision (“D.”) 15-10-031 approving the BPP with modifications, and will remain in effect until December 31, 2024, or the BPP is superseded by a subsequent Commission-approved BPP, whichever is earlier. PG&E’s BPP establishes the upfront achievable standards and criteria for PG&E’s procurement activities and the recovery of procurement costs without an after-the-fact reasonableness review, consistent with California Public Utilities Code (“Pub. Util. Code”) § 454.5. A. PG&E’s Procurement Goals PG&E’s goals are to provide safe, reliable, affordable, and environmentallysensitive electric and gas service to its customers throughout northern and central California. The BPP is intended to achieve these goals for PG&E’s bundled electric customers. PG&E’s first priority is safety. For PG&E-owned facilities, the focus on safety includes ensuring that PG&E’s facilities are developed, maintained, and operated in a safe Decision No. 15-10-031 Issued by Robert Kenney Vice President Regulatory and External Affairs Date Filed Effective Resolution No. September 20, 2016
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Pacific Gas and Electric Company San Francisco, California Cal. P.U.C. Sheet No. 1a Pacific Gas and Electric Company 2014 Bundled Procurement Plan manner. PG&E has undertaken comprehensive safety efforts and has initiated a number of key safety programs to ensure that its hydroelectric, renewable, fossil-fueled, and Decision No. 15-10-031 Issued by Robert Kenney Vice President Regulatory and External Affairs Date Filed Effective Resolution No. September 20, 2016
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Pacific Gas and Electric Company San Francisco, California C. Cal. P.U.C. Sheet No. 32 Pacific Gas and Electric Company 2014 Bundled Procurement Plan Description of Cost Recovery for Bundled Procurement Plan Procurement PG&E’s ERRA is to record and recover power costs, excluding CDWR contract costs, associated with PG&E’s authorized procurement plan, pursuant to D.02-10-062, D.02-12-074 and Pub. Util. Code § 454.5(d)(3), and any succeeding decision, which approves PG&E’s procurement activities. Costs recorded in ERRA include, but are not limited to, procurement costs associated with third-party contracts, UOG fuels, CAISO market purchases and charges, GHG procurement costs, hedging and collateral costs, revenues or costs related to CRRs and convergence bidding, costs related to IE, and fees associated with participating in the WREGIS. These costs are offset by revenues received from the CAISO markets, sales to third parties, and other market transactions related to procurement. The specific costs, expenses, and revenues recovered in ERRA are identified in Electric Preliminary Statement CP – ERRA. V. Pre-Approval, Approval, and Filing Requirements PG&E may execute contracts that are consistent with the BPP with a contract duration of less than five years without Commission pre-approval. Specifically, PG&E can enter into contracts with delivery terms of less than five years, provided the delivery term ends within the 10-calendar-year Long-Term Procurement Plan procurement cycle (e.g., for the 2014 BPP, contracts utilizing this rule may not include deliveries beyond December 31, 2024 on a rolling basis until an updated or new BPP is approved). 15 The length of the contract duration includes any extension options provided for in the contract. 15 [INSERT RESOLUTION APPROVING ADVICE LETTER 5985-E]See D.07-12-052 at p. 172 and OP 19. Decision No. 15-10-031 Issued by Robert Kenney Vice President Regulatory and External Affairs Date Filed Effective Resolution No. September 20, 2016
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Pacific Gas and Electric Company San Francisco, California Cal. P.U.C. Sheet No. 32a Pacific Gas and Electric Company 2014 Bundled Procurement Plan For contracts with a duration of five years or greater, PG&E will file an application for pre-approval of the contract. The only exceptions to Decision No. 15-10-031 Issued by Robert Kenney Vice President Regulatory and External Affairs Date Filed Effective Resolution No. September 20, 2016
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Advice 5985-E October 29, 2020 Attachment B Clean BPP (Sheet 1, 32)
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Pacific Gas and Electric Company San Francisco, California I. Cal. P.U.C. Sheet No. 1 Pacific Gas and Electric Company 2014 Bundled Procurement Plan Introduction In accordance with the Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judge, issued May 6, 2014 in Rulemaking (“R.”) 13-12-010, Pacific Gas and Electric Company (“PG&E”) is filing its Bundled Procurement Plan (“BPP”) covering the period from the date the BPP is approved until an updated or new BPP is approved for PG&E in Rulemaking 20-05-003 or elsewhere. PG&E’s BPP became effective on October 22, 2015, the date the California Public Utilities Commission (“CPUC” or “Commission”) adopted Decision (“D.”) 15-10-031 approving the BPP with modifications, and will remain in effect until the BPP is superseded by a subsequent Commission-approved BPP. PG&E’s BPP establishes the upfront achievable standards and criteria for PG&E’s procurement activities and the recovery of procurement costs without an after-the-fact reasonableness review, consistent with California Public Utilities Code (“Pub. Util. Code”) § 454.5. A. PG&E’s Procurement Goals PG&E’s goals are to provide safe, reliable, affordable, and environmentallysensitive electric and gas service to its customers throughout northern and central California. The BPP is intended to achieve these goals for PG&E’s bundled electric customers. PG&E’s first priority is safety. For PG&E-owned facilities, the focus on safety includes ensuring that PG&E’s facilities are developed, maintained, and operated in a safe manner. PG&E has undertaken comprehensive safety efforts and has initiated a number of key safety programs to ensure that its hydroelectric, renewable, fossil-fueled, and Decision No. 15-10-031 Issued by Robert Kenney Vice President Regulatory and External Affairs Date Filed Effective Resolution No. September 20, 2016
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Pacific Gas and Electric Company San Francisco, California C. Cal. P.U.C. Sheet No. 32 Pacific Gas and Electric Company 2014 Bundled Procurement Plan Description of Cost Recovery for Bundled Procurement Plan Procurement PG&E’s ERRA is to record and recover power costs, excluding CDWR contract costs, associated with PG&E’s authorized procurement plan, pursuant to D.02-10-062, D.02-12-074 and Pub. Util. Code § 454.5(d)(3), and any succeeding decision, which approves PG&E’s procurement activities. Costs recorded in ERRA include, but are not limited to, procurement costs associated with third-party contracts, UOG fuels, CAISO market purchases and charges, GHG procurement costs, hedging and collateral costs, revenues or costs related to CRRs and convergence bidding, costs related to IE, and fees associated with participating in the WREGIS. These costs are offset by revenues received from the CAISO markets, sales to third parties, and other market transactions related to procurement. The specific costs, expenses, and revenues recovered in ERRA are identified in Electric Preliminary Statement CP – ERRA. V. Pre-Approval, Approval, and Filing Requirements PG&E may execute contracts that are consistent with the BPP with a contract duration of less than five years without Commission pre-approval. Specifically, PG&E can enter into contracts with delivery terms of less than five yearson a rolling basis until an updated or new BPP is approved. 15 The length of the contract duration includes any extension options provided for in the contract. For contracts with a duration of five years or greater, PG&E will file an application for pre-approval of the contract. The only exceptions to 15 [INSERT RESOLUTION APPROVING ADVICE LETTER 5985-E]. Decision No. 15-10-031 Issued by Robert Kenney Vice President Regulatory and External Affairs Date Filed Effective Resolution No. September 20, 2016
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PG&E Gas and Electric Advice Submittal List General Order 96-B, Section IV AT&T Albion Power Company Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. California Cotton Ginners & Growers Assn California Energy Commission California Hub for Energy Efficiency Financing California Alternative Energy and Advanced Transportation Financing Authority California Public Utilities Commission 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 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 San Diego Gas & Electric Company SPURR San Francisco Water Power and Sewer Sempra Utilities Sierra Telephone Company, Inc. 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 Utility Cost Management Utility Power Solutions Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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