Details for: SDG&E AL 3692-E.pdf

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Clay Faber - Director
Regulatory Affairs
8330 Century Park Court
San Diego, CA 92123

February 19, 2021


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.
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.
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.


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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 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: & 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 _______________________________ CLAY FABER Director – Regulatory Affairs
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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 (U902) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Joff Morales Phone #: 858-650-4098 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: 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
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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: 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: 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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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 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 Service List R.20-11-003
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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
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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; T 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
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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 T 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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