Details for: PGE AL 6044-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

January 7, 2021

Advice 6044-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California
Subject:

2021 Proposed Budget for Administrative Costs to Support the
Disadvantaged Communities – Single Family Solar Homes (DACSASH) Program

Purpose
Authorized by Ordering Paragraph (OP) 6 in Decision (D.) 20-12-003, PG&E hereby
submits for review, this Tier 2 Advice Letter of its proposed annual budget for 2021 for
reasonable administrative costs to support the Disadvantaged Communities – Single
Family Solar Homes (DAC-SASH) Program.
Background
On June 21, 2018, the California Public Utilities Commission (Commission or CPUC)
approved D.18-06-027, Alternate Decision Adopting Alternatives to Promote Solar
Distributed Generation in Disadvantaged Communities, implementing three new
programs that are targeted to assist customers is disadvantaged communities (DACs).
The DAC programs are: 1) DAC Single Family Solar Homes (DAC-SASH), 2) DAC Green
Tariff (DAC-GT), and 3) Community Solar Green Tariff (CS-GT).
D.18-06-027 states that the DAC-SASH program has an annual $10 million budget,
collected first through available greenhouse gas allowance proceeds, and if such funds
are exhausted, the program will be funded through public purpose program funds.1
PG&E’s proportionate share of the funding is 43.7%, or $4.37 million annually.2 DACSASH program funds will be reviewed in the annual Energy Resource Recovery Account
(ERRA) proceeding.3 The DAC-SASH program administration budget is 10%.4 Southern
California Edison (SCE) leads the co-funding agreement for the statewide Program
Administrator’s, GRID Alternatives, administrative costs. In the 2019 ERRA proceeding,

1

D.18-06-027, p. 102, OP 8.
D.18-06-027, p. A-6.
3 D.18-06-027, p. 102, OP8.
4 D.18-06-027, p. A-6.
2





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Advice 6044-E -2- January 7, 2021 PG&E has requested recovery of PG&E’s program start-up costs,5 consistent with OP 10 of D.18-06-027. On December 3, 2020, the CPUC approved D.20-12-003, Decision Regarding Petition for Modification of Decision 18-06-027 and Providing Direction Regarding Marketing and Outreach of the Disadvantaged Communities – Single-Family Solar Homes. OP 6 of this decision authorizes PG&E to submit a Tier 2 Advice Letter within 30 days of issuance of the decision with its proposed annual budgets for 2021 for reasonable administrative costs needed to support the DAC-SASH program.6 OP 6 authorizes PG&E to submit budgets annually, similar to DAC-GT and CS-GT.7 OP 7 authorizes PG&E to seek recovery of its approved administration costs through its DAC-SASH Balancing Account and to include such costs in its annual ERRA proceedings for reasonableness review.8 Proposed 2021 Budget As authorized in OP 6 of D.20-12-003, PG&E submits the following proposed DAC-SASH budget for 2021 administration costs to support the program, shown below in Table 1. Table 1: 2021 DAC-SASH Proposed PG&E Budget 2021 Proposed PG&E Budget DAC-SASH $30,000 The activities associated with this work are expected to include: • • • • • • • Reviewing and approving administration and incentive invoices Ensuring compliance with all regulatory requirements Drafting, reviewing, and responding to any regulatory filings Financial planning and analysis for the program Annual third-party security review for GRID Alternatives Executing a non-disclosure agreement with GRID Alternatives Generating and transmitting data items to GRID Alternatives.9 PG&E’s proposed DAC-SASH budget for 2021 administration costs was based on its 2020 expenditures plus estimated costs of executing a non-disclosure agreement and transmitting the data items listed in D.20-12-003 Appendix A.10 In 2020, PG&E incurred 5 Start-up costs are defined as cost incurred prior to September 2019, which is when the DACSASH program launched. 6 D. 20-12-003, p. 14, OP 6. 7 D. 20-12-003, p. 14, OP 6. 8 D. 20-12-003, p. 14, OP 7. 9 Per OP 2 of D.20-12-003, PG&E must annually transmit the data items listed in Appendix A to GRID Alternatives. 10 D.20-12-003, p. A-1 - A-2, Appendix A.
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Advice 6044-E -3- January 7, 2021 internal program administration expenses in supporting the DAC-SASH program. The activities associated with this work included: • • • • • Reviewing and approving administration and incentive invoices Ensuring compliance with all regulatory requirements Drafting, reviewing, and responding to regulatory filings11 Financial planning and analysis for the program Annual third-party security review for GRID Alternatives. These expenses do not include GRID Alternatives’ administrative costs, which are invoiced and paid per the co-funding agreement led by SCE. Table 2 shows the recorded amount PG&E spent on internal DAC-SASH program administration in 2020. Table 2: 2020 DAC-SASH PG&E Expenditures 2020 PG&E Expenditures DAC-SASH $25,349 Incremental costs from 2020 to 2021 include the estimated costs associated with complying with OP 2 of D.20-12-003, in which PG&E will execute a non-disclosure agreement and transmit the data items listed in Appendix A.12 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 submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than January 27, 2021, which is 20 days after the date of this submittal. 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 11 12 This included filings in R.14-07-002 and PG&E’s annual ERRA proceeding. D.20-12-003, p. 13, OP 2.
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Advice 6044-E -4- January 7, 2021 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: 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 2 advice submittal become effective on regular notice, February 6, 2021, which is 30 calendar days after the date of submittal 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 service list for R.14-07-002. 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 submittals can also be accessed electronically at: http://www.pge.com/tariffs/.
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Advice 6044-E /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List R.14-07-002 -5- January 7, 2021
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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 U39 E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Annie Ho Phone #: (415) 973-8794 E-mail: PGETariffs@pge.com E-mail Disposition Notice to: AMHP@pge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 6044-E Subject of AL: 2021 Proposed Budget for Administrative Costs to Support the Disadvantaged Communities – Single Family Solar Homes (DAC-SASH) Program Keywords (choose from CPUC listing): Compilance 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: 2/6/21 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: 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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PG&E Gas and Electric Advice Submittal List General Order 96-B, Section IV AT&T Albion Power Company East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Alta Power Group, LLC Anderson & Poole Engineers and Scientists of California 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 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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