Details for: SDG&E AL 3639-E_2926-G.pdf


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

October 30, 2020
Advice Letter 3639-E/2926-G
(U902-M)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
SUBJECT:

SDG&E’s Revenue Requirement Effective January 1, 2021 in Compliance
with the 2019 General Rate Case Decision 19-09-051

PURPOSE
San Diego Gas & Electric Company (SDG&E) submits for approval with the California Public
Utilities Commission (Commission) this Tier 1 Advice Letter (AL), in accordance with the 2019
General Rate Case (GRC) Decision (D.) 19-09-051, to adjust the revenue requirement for PostTest Year (PTY) 2021) and provide a 10-year rolling average of historical uncollectible rates.
BACKGROUND
On October 6, 2017, SDG&E filed its GRC Application (A.) 17-10-007.1 The Commission issued
D.19-09-051 on October 1, 2019, adopting, among other things, SDG&E’s revenue
requirements to establish rates to provide electric and natural gas services for the test year
period beginning January 1, 2019 through December 31, 2019, and the PTY attrition
adjustments for 2020 through 2021.
Pursuant to Ordering Paragraph (OP) 5 of D.19-09-051, Southern California Gas Company
(SoCalGas) and SDG&E shall each file respective Tier 1 AL with updates to their PTY revenue
requirements. OP 5 specifically states:
…Tier 1 Advice Letters are to be filed on November 1, 2020 to adjust the revenue
requirement for 2021 beginning on January 1, 2021.
Pursuant to Finding of Fact (FOF) 150 of D.09-09-051, SDG&E and SoCalGas are to provide a
10-year rolling average of historical uncollectible rates annually. FOF 150 specifically states:
A 10-year rolling average of historical uncollectible rates starting from 2007 to 2016 with
adjustments to occur annually by advice letter is reasonable.

1

Proceedings A.17-10-007 (Application of San Diego Gas & Electric Company for Authority, Among
Other Things, to Update its Electric and Gas Revenue Requirement and Base Rates Effective on January
1, 2019) and A.17-10-008 (Application of Southern California Gas Company for Authority, Among Other
Things, to Update its Gas Revenue Requirement and Base Rates Effective on January 1, 2019) were
consolidated by Ruling of November 8, 2017.





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Public Utilities Commission 2 October 30, 2020 REVENUE REQUIREMENT Electric Revenue Requirement/Base Margin Adjustment: The PTY 2021 revenue requirement adopted in D.19-09-051 provides an electric base margin revenue requirement of $1,702 million2 without franchise fees and uncollectibles (FF&U) and net of miscellaneous revenue. It includes $1,502 million for electric distribution and $200 million for generation (which includes $1.509 million for SONGS3). Gas Revenue Requirement/Base Margin Adjustment: The PTY 2020 revenue requirement adopted in D.19-09-051 provides a gas base margin revenue requirement of $430 million4 without FF&U and net of miscellaneous revenue for SDG&E. TEN-YEAR HISTORICAL DATA SDG&E updated its uncollectible expense rate to 0.169% for PTY 2021 in AL 3449-E/2811-G,5 submitted on October 28, 2019. Herein, SDG&E presents the uncollectible expense historical data used in calculating the PTY 2021 uncollectible rate. 2 SDG&E herein updates its PTY 2021 revenue requirement per OP 5 and affirms that officer salaries, bonuses, and benefits are excluded from the PTY 2021 revenue requirement, per OP 12. The figures herein do not include the savings adopted in Resolution E-5071. SDG&E will implement the 2020 and 2021 savings related to Resolution E-5071 concurrently with the implementation of PTY 2021. In addition, the 2021 updated revenue requirement does not include any reductions authorized in the Application for Rehearing (AFR) D.20-07-038. These reductions will be incorporated into rates in accordance with a Commission-issued decision on SDG&E’s April 9, 2020 Petition for Modification (PFM) decision of D.1909-051, when it is issued. 3 SDG&E’s revenue requirement for San Onofre Nuclear Generation Site (SONGS) in 2021 will be determined in a final decision in Southern California Edison’s (SCE) TY 2021 GRC. The SONGS 2020 revenue requirement will be held constant for 2021 until SCE’s final decision is issued. 4 See Footnote 1. 5 Approved by the Commission on December 17, 2019.
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Public Utilities Commission 3 October 30, 2020 2021 Uncollectible Rate Recorded Uncollectible Expense: 2009-2018 Uncollectible Uncollectible Rate Expense Sales Revenue (a) / (b) (a) (b) Year 2009 $ 5,278,315 $ 2,836,818,502 0.186% 2010 $ 4,828,063 $ 2,865,422,686 0.168% 2011 $ 6,162,914 $ 3,087,387,963 0.200% 2012 $ 5,027,626 $ 3,030,246,377 0.166% 2013 $ 4,911,906 $ 3,225,416,802 0.152% 2014 $ 5,309,773 $ 3,779,062,099 0.141% 2015 $ 6,455,318 $ 4,033,166,170 0.160% 2016 $ 6,427,130 $ 3,737,413,809 0.172% 2017 $ 6,500,662 $ 3,984,777,398 0.163% 2018 $ 7,815,235 $ 4,233,059,153 0.185% 10 Year Average $ 58,716,942 $ 34,812,770,959 0.169% EFFECTIVE DATE SDG&E believes this Advice Letter is subject to Energy Division disposition and should be classified as Tier 1 (Effective Pending Disposition) pursuant to GO 96-B. Therefore, SDG&E respectfully requests that this compliance submittal become effective on October 30, 2020, the date submitted. 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. The protest must be made in writing and must be received no later than November 19, 2020, which is 20 days of 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 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 SDGETariffs@sdge.com
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Public Utilities Commission 4 October 30, 2020 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.17-10-007, by either providing them a copy electronically or by mailing them a copy hereof properly stamped and addressed. Address changes should be directed to SDG&E Tariffs by e-mail at SDGETariffs@sdge.com. /s/ Clay Faber CLAY FABER Director – Regulatory Affairs Attachments
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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-E ) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Aurora Carrillo Phone #: (858) 654-1542 E-mail: acarrillo@sdge.com E-mail Disposition Notice to: acarrillo@sdge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 3639-E/2926-G Subject of AL: SDG&E’s Revenue Requirement Effective January 1, 2021 in Compliance with the 2019 General Rate Case Decision 19-09-051 Keywords (choose from CPUC listing): GRC, Revenue Requirement AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: 19-09-051 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: 10/30/20 No. of tariff sheets: N/A 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: Greg Anderson 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) 654-1717 Facsimile (xxx) xxx-xxxx: Email: GAnderson@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) Public Utilities Commission CA. Public Avocates (CalPA) R. Pocta Energy Division M. Ghadessi M. Salinas L. Tan R. Ciupagea Tariff Unit CA Energy Commission B. Penning B. Helft Advantage Energy C. Farrell Alcantar & Kahl LLP M. Cade K. Harteloo AT&T Regulatory Barkovich & Yap, Inc. B. Barkovich Biofuels Energy, LLC K. Frisbie Braun & Blaising, P.C. S. Blaising D. Griffiths Buchalter K. Cameron M. Alcantar CA Dept. of General Services H. Nanjo California Energy Markets General General Order No. 96-B ADVICE LETTER SUBMITTAL MAILING LIST Clean Energy Renewable Fuels, LLC P. DeVille NRG Energy D. Fellman Clean Power Research T. Schmid G. Novotny Pacific Gas & Electric Co. M. Lawson M. Huffman Tariff Unit Davis Wright Tremaine LLP J. Pau Douglass & Liddell D. Douglass D. Liddell Ellison Schneider Harris & Donlan LLP E. Janssen C. Kappel Energy Policy Initiatives Center (USD) S. Anders Energy Regulatory Solutions Consultants L. Medina Energy Strategies, Inc. K. Campbell EQ Research General Goodin, MacBride, Squeri, & Day LLP B. Cragg J. Squeri Green Charge K. Lucas Hanna and Morton LLP N. Pedersen JBS Energy J. Nahigian Keyes & Fox, LLP B. Elder California Farm Bureau Federation K. Mills Manatt, Phelps & Phillips LLP D. Huard R. Keen California Wind Energy N. Rader McKenna, Long & Aldridge LLP J. Leslie Cameron-Daniel, P.C. General Morrison & Foerster LLP P. Hanschen MRW & Associates LLC General City of Poway Poway City Hall City of San Diego L. Azar J. Cha D. Heard F. Ortlieb H. Werner M. Rahman NLine Energy M. Swindle 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 Copies to AddisScott9@aol.com ckingaei@yahoo.com clower@earthlink.net hpayne3@gmail.com puainc@yahoo.com Interested Parties: A.17-10-007
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