Clay Faber - Director
Regulatory Affairs
8330 Century Park Court
San Diego, CA 92123
cfaber@sdge.com
February 19, 2021
ADVICE LETTER 3692-E
(U902-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
SUBJECT:
MODIFICATIONS TO THE LOCAL GENERATION BALANCING ACCOUNT
PURSUANT TO DECISION 21-02-028
San Diego Gas & Electric Company (SDG&E) hereby submits this advice letter requesting
California Public Utilities Commission (Commission) approval of proposed modifications to its
electric tariffs, as shown in Attachment A, consistent with Decision (D.) 21-02-028.
PURPOSE
Pursuant to Ordering Paragraph (OP) 5 of D.21-02-028, this advice letter modifies the preliminary
statement of SDG&E’s Local Generating Balancing Account (LGBA) to implement direction
provided by the Commission.1 SDG&E’s modifications to its LGBA preliminary statement are
summarized below in the “Discussion” section.
BACKGROUND
In August 2020, a prolonged extreme heat event led to a grid emergency that ultimately required
the California Independent System Operator (CAISO) to initiate rotating outages in its balancing
authority area to prevent wide-spread service interruptions.
In response, among other actions, the Commission approved D.21-02-028 on February 11, 2021.
The decision directs the state’s three large investor-owned utilities (IOUs) to contract for capacity
on behalf of all customers in their respective distribution service territories with the costs and
benefits allocated to all benefitting customers through the Commission’s established Cost
Allocation Mechanism (CAM).2 D.21-02-028 outlines the parameters SDG&E must adhere to in
seeking procurement approval from the Commission.3
D.21-02-028, p. 1.
D.21-02-028, p. 17.
3 D.21-02-028, pp. 10-12.
1
2
- Page 1 -
Public Utilities Commission
2
February 19, 2021
On February 16, 2021, SDG&E submitted Advice Letter 3689-E requesting approval pursuant to
D.21-02-028 of system reliability contracts totaling 109 MW, which includes procurement costs
that will be recorded in LGBA.4
DISCUSSION
D.21-02-028 (OP 5) directs SDG&E to file a Tier 2 advice letter to make the tariff changes needed
to adjust balancing accounts to implement the requirements set forth in the decision, with an
effective date of December 28, 2020. Accordingly, SDG&E includes as Attachment A hereto an
update to its LGBA to reflect the expansion of SDG&E’s eligible contract costs to include resource
types, such as incremental energy storage and efficiency upgrades, as well as the associated
Independent Evaluator engagement costs associated with procurement efforts determined
eligible per D.21-02-028.
EFFECTIVE DATE
SDG&E believes this submittal is subject to Energy Division disposition and should be classified
as Tier 2 (pending staff disposition) pursuant to D.21-02-028. SDG&E respectfully requests that
this submittal be effective on December 28, 2020 pursuant to OP 5 of D.21-02-028.
PROTEST
Anyone may protest this Advice Letter to the 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
March 11, 2021, which is 20 days after 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
In AL 3689-E SDG&E requested authority to designate 20 MW of incremental capacity as the
replacement capacity for 20 MW of proposed resources that were withdrawn and required in
Resolution E-5117 to be replaced, and to recover costs for those 20 MW through the Modified
Cost Allocation Mechanism (as directed in D.19-11-016). SDG&E requested authority in AL
3689-E to recover costs for the remaining 89 MW through the CAM, consistent with D.21-02028.
4
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Public Utilities Commission
3
February 19, 2021
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
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.20-11-003, 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 SDGETariffs@sdge.com.
_______________________________
CLAY FABER
Director – Regulatory Affairs
- Page 3 -
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: Joff Morales
Phone #: 858-650-4098
E-mail: JMorales@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: 2
Advice Letter (AL) #: 3692-E
Subject of AL: Modifications to the Local Generation Balancing Account (LGBA) Pursuant to Decision 21-02-028
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.21-02-028
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: 12/28/20
No. of tariff sheets: 3
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:
See Attachment 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
- Page 4 -
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: District of Columbia
Telephone (xxx) xxx-xxxx:
Facsimile (xxx) xxx-xxxx:
Email:
Zip:
Clear Form
- Page 5 -
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
California Farm Bureau Federation
K. Mills
California Wind Energy
N. Rader
Cameron-Daniel, P.C.
General
City of Poway
Poway City Hall
City of San Diego
L. Azar
J. Cha
D. Heard
F. Ortlieb
H. Werner
M. Rahman
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
Commercial Energy
J. Martin
regulatory@commercialenergy.net
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
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
Energy Regulatory Solutions Consultants
L. Medina
TerraVerde Renewable Partners LLC
F. Lee
Energy Strategies, Inc.
K. Campbell
TURN
M. Hawiger
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
Manatt, Phelps & Phillips LLP
D. Huard
R. Keen
McKenna, Long & Aldridge LLP
J. Leslie
Morrison & Foerster LLP
P. Hanschen
MRW & Associates LLC
General
NLine Energy
M. Swindle
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
Service List
R.20-11-003
- Page 6 -
Page 1 of 1
ATTACHMENT A
ADVICE LETTER 3692-E
Cal. P.U.C.
Sheet No.
Title of Sheet
Revised 34155-E
PRELIMINARY STATEMENT, II. BALANCING ACCOUNTS,
LOCAL GENERATING BALANCING ACCOUNT (LGBA), Sheet
1
Original 34156-E
PRELIMINARY STATEMENT, II. BALANCING ACCOUNTS,
LOCAL GENERATING BALANCING ACCOUNT (LGBA), Sheet
2
Revised 34157-E
TABLE OF CONTENTS, Sheet 1
Canceling Cal.
P.U.C. Sheet No.
Revised 28765-E
Revised 33615-E
1
- Page 7 -
Revised
San Diego Gas & Electric Company
San Diego, California
Canceling
Cal. P.U.C. Sheet No.
34155-E
Revised
Cal. P.U.C. Sheet No.
28765-E
Sheet 1
PRELIMINARY STATEMENT
II. BALANCING ACCOUNTS
LOCAL GENERATING BALANCING ACCOUNT (LGBA)
1. Purpose
The LGBA, approved in Decision (D.) 13-03-029, is a two-way balancing account to record the revenues
and costs of generation where the Commission has determined that the resource is subject to a cost
allocation mechanism (CAM). This generation will take the form of power purchasing agreements (PPA)
as well as company-owned generation and energy storage units associated with new generation
resources and any other like resources approved by the Commission for CAM treatment. The LGBA will
have sub-accounts corresponding to each generation resource where the Commission has found that
the costs should be subject to CAM treatment.
Pursuant to D.21-02-028, Ordering Paragraph (OP) 5, effective December 28, 2020, SDG&E will record
the revenues and costs related to contracting for capacity that is available to serve peak and net peak
load in the summer of 2021 (including independent evaluator costs) and seek approval for cost recovery,
subject to CAM treatment.
N
N
N
N
2. Applicability
The LGBA applies to all customers per D.13-03-029.
3. Rates
The Local Generation Charge (LGC) will be charged for recovery of new generation, energy storage
costs and costs associated with D. 21-02-028 as a non-bypassable charge applicable to bundled
service, Direct Access, and Community Choice Aggregation customers.
(Continued)
Issued by
1P7
Advice Ltr. No.
Decision No.
3692-E
D.21-02-028
Dan Skopec
Vice President
Regulatory Affairs
Submitted
Effective
Resolution No.
Feb 19, 2021
T
T
- Page 8 -
Original
San Diego Gas & Electric Company
San Diego, California
Canceling
Cal. P.U.C. Sheet No.
34156-E
Cal. P.U.C. Sheet No.
Sheet 2
PRELIMINARY STATEMENT
N
N
N
II. BALANCING ACCOUNTS
LOCAL GENERATING BALANCING ACCOUNT (LGBA)
4. Accounting Procedures
SDG&E shall maintain the LGBA by recording the following entries at the end of each month to each
applicable sub-account:
T
a) An entry equal to costs associated with procurement related contract costs;
b) An entry equal to the capital-related costs (depreciation, taxes, and return) of company-owned
generation and company-owned energy storage units;
c) An entry equal to the revenue requirements associated with company-owned generation and
company-owned energy storage units;
d) An entry equal to company-owned energy storage units’ Operating & Maintenance (O&M);
e) An entry for revenues as collected through the LGC;
f)
An entry equal to revenues received from the sales of the right to dispatch or revenues from the
resource’s operation and / or the revenues determined using a CPUC approved methodology;
g) An entry equal to costs associated with the engagement of an Independent Evaluator;
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h) Entries for amortizations or authorized transfers to or from other regulatory accounts; and
T
i)
T
An entry equal to the interest on the average of the balance at the beginning of the month and the
balance after the entries above for each account, at a rate equal to one-twelfth of the interest rate on
three-month Commercial Paper for the previous month, as reported in the Federal Reserve
Statistical Release, H.15, or its successor publication.
5. Disposition
The balance in the LGBA will be addressed in the Company’s Energy Resource Recovery Account
proceeding or in another proceeding deemed appropriate by the Commission.
Issued by
2P5
Advice Ltr. No.
Decision No.
3692-E
D.21-02-028
Dan Skopec
Vice President
Regulatory Affairs
Submitted
Effective
Resolution No.
Feb 19, 2021
- Page 9 -
Revised
San Diego Gas & Electric Company
San Diego, California
34157-E
Revised
Canceling
Cal. P.U.C. Sheet No.
Cal. P.U.C. Sheet No.
33615-E
Sheet 1
TABLE OF CONTENTS
The following sheets contain all the effective rates and rules affecting rates, service and information relating thereto, in
effect on the date indicated herein.
Cal. P.U.C. Sheet No
TITLE PAGE.............................................................
TABLE OF CONTENTS.............................................
16015-E
34157, 33616, 31243, 33380, 33381, 33253-E
33254, 33382, 32346, 32352, 33383, 31804-E
31805, 31174, 33419, 31176, 31177-E
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PRELIMINARY STATEMENT:
I. General Information……......................................
II. Balancing Accounts
Description/Listing of Accounts
California Alternate Rates for Energy (CARE) Balancing Acct
Rewards and Penalties Balancing Account (RPBA)…….
Transition Cost Balancing Account (TCBA)……………...
Post-1997 Electric Energy Efficiency Balancing Acct (PEEEBA
Tree Trimming Balancing Account (TTBA)……………..
Baseline Balancing Account (BBA)……………………….
Energy Resource Recovery Account (ERRA)……………
Low-Income Energy Efficiency Balancing Acct (LIEEBA)……
Non-Fuel Generation Balancing Account (NGBA)………
Electric Procurement Energy Efficiency Balancing Account (EPEEBA)
Common Area Balancing Account (CABA)………………
Nuclear Decommissioning Adjustment Mechanism (NDAM)…
Pension Balancing Account (PBA)………………………..
Post-Retirement Benefits Other Than Pensions Balancing Account
(PBOPBA)
8274, 30670, 31260-E
19402, 32302, 33617-E
26553, 26554-E
21929, 23295-E
31213, 31214, 31215, 31216, 31631, 31632-E
22059, 30893-E
27944, 19422-E
21377, 28769-E
26358, 26359, 26360, 26361, 31631, 31632-E
19431, 19432-E
31217, 31218, 31219, 25575-E
30675-E
28770-E
30676-E
29835, 27949-E
29836, 27951-E
Community Choice Aggregation Implementation Balancing Account
(CCAIBA)……………………………...
19445-E
31453, 22813, 21116-E
26555-E
30647, 30648, 30649-E
30998, 30999-E
30677-E
22078-E
30102, 30103, 27692-E
22797-E
30678-E
30820-E
34155, 34156-E
27955, 27956-E
31664, 31665-E
26898, 26899-E
Electric Distribution Fixed Cost Account (EDFCA)……
Rate Design Settlement Component Account (RDSCA)
California Solar Initiative Balancing Account (CSIBA)….
SONGS O&M Balancing Account (SONGSBA)……
On-Bill Financing Balancing Account (OBFBA)……
Solar Energy Project Balancing Account (SEPBA)….
Electric Program Investment Charge Balancing Acct (EPICBA)
Tax Equity Investment Balancing Account (TEIBA)
California Energy Systems 21st Century Balancing Acct (CES-21BA)
Greenhouse Gas Revenue Balancing Account (GHGRBA).
Local Generation Balancing Account (LGBA)…………….
New Environmental Regulatory Balancing Account (NERBA)…………
Master Meter Balancing Account (MMBA)………………………
Smart Meter Opt-Out Balancing Account (SMOBA)………………..
(Continued)
Issued by
1P4
Advice Ltr. No.
Decision No.
3692-E
D.21-02-028
Dan Skopec
Vice President
Regulatory Affairs
Submitted
Effective
Resolution No.
Feb 19, 2021
T
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