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
February 26, 2021
Advice 6101-E
(Pacific Gas and Electric Company ID U 39 E)
Public Utilities Commission of the State of California
Subject:
2020 True-Up for the Solar on Multifamily Affordable Housing
(SOMAH) Program Funding
Purpose
Pursuant to Ordering Paragraph (OP) 6 and Section 3 of Decision (D.) 20-04-012, Pacific
Gas and Electric Company (PG&E) submits this Tier 1 advice letter to provide a true-up
amount for the final three months of 2020 for the funding of the Solar on Multifamily
Affordable Housing (SOMAH) program, to be incorporated into PG&E’s 2022 Energy
Resource Recovery Account (ERRA) Forecast SOMAH set aside request.
Background
On December 14, 2017, the California Public Utilities Commission (Commission or
CPUC) adopted D.17-12-022, Decision Adopting Implementation Framework for
Assembly Bill 693 and Creating the Solar on Multifamily Affordable Housing Program,
requiring each of the participating utilities to reserve 10% of the proceeds from the sale
of greenhouse gas allowances through its annual ERRA proceedings for use in the
SOMAH program.1
On February 27, 2020, the Commission adopted D.20-02-047, Decision Adopting Pacific
Gas and Electric Company’s 2020 Energy Resource Recovery Account Forecast and
Generation Non-Bypassable Charges Forecast and Greenhouse Gas Forecast Revenue
Return and Reconciliation, directing PG&E to set aside $20.665 million, or 50% of the full
calendar year, for its 2020 SOMAH program funding allocation since funding was only
authorized through June 30, 2020.2 D.20-02-047 also directed PG&E to transfer set
asides on a quarterly basis.3
1
D.17-12-022, p. 69, Ordering Paragraph (OP) 4.
D.20-02-047, p. 21.
3
D.20-02-047, p. 22.
2
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Advice 6101-E
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February 26, 2021
On April 16, 2020, the Commission adopted D.20-04-012, Decision Determining Revenue
Availability and Adequacy of Participation and Interest in the Solar on Multifamily
Affordable Housing, continuing authorization of funds for the SOMAH program through
June 30, 20264 and directed the participating utilities to propose set aside amounts for
the SOMAH program from July 1, 2020 to December 31, 2020 in their 2021 ERRA
forecasts.5 D.20-04-012 also requires each of the participating utilities to provide a trueup for the final three months of each year via a Tier 1 advice letter as soon as the
information is available, and no later than March 1st of the following year.6
On December 17, 2020, the Commission adopted D.20-12-038, Decision Adopting Pacific
Gas and Electric Company’s 2021 Energy Resource Recovery Account Forecast,
Generation Non-Bypassable Charges Forecast, Greenhouse Gas Forecast Revenue
Return and Reconciliation, and Related Calculations and Rate Proposals, approving
$20.86 million, the forecasted SOMAH set aside for the second half of 2020.7
2020 SOMAH Set Aside Amounts
In April 2020, PG&E set aside $10.117 million, which was 10% of the recorded
Greenhouse Gas (GHG) allowance revenues for the first quarter of 2020. In July 2020,
PG&E set aside $7.796 million, which was 10% of the recorded GHG allowance revenues
for the second quarter of 2020. No true-up was needed for the first half of 2020 because
PG&E set aside 10% of the recorded GHG allowance revenue amount, not forecasted.
In January 2021, PG&E set aside $20.863 million for the second half of 2020 per D.2012-038.8 This forecasted amount was the sum of 10% of the recorded GHG allowance
revenues for the third quarter of 2020 and 10% of the forecasted GHG allowance
revenues for the fourth quarter of 2020.
This advice letter provides a true-up amount for the final three months of 2020. The
forecasted set aside amount for the fourth quarter of 2020 was $9,771,903, but 10% of
recorded GHG allowance revenue for this time period was $9,585,070. The SOMAH set
aside for the last three months of 2020 was over-forecasted by $186,832.
Table 1 below shows the difference between actual SOMAH set asides and 10% of
recorded GHG allowance revenue for each quarter in 2020.
4
D.20-04-012, p. 14, OP 6.
D.20-04-012, p. 14, OP 5.
6
D.20-04-012, p. 10-11.
7
D.20-12-038, p. 24-25.
8
D.20-12-038, p. 24-25.
5
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Advice 6101-E
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February 26, 2021
Table 1: 2020 SOMAH Set Aside Amounts (Thousands of Dollars)
2020
Quarter
Q1 2020
Q2 2020
Q3 2020
Q4 2020
2020 Total
Recorded
GHG
Allowance
Revenues
$101,173
$77,956
$110,914
$95,851
$385,894
Set Aside Based on
10% of Recorded
GHG Allowance
Revenue
$10,117
$7,796
$11,091
$9,585
$38,589
Actual Set
Aside
$10,117
$7,796
$11,091
$9,772
$38,776
Difference
(Actual Set Aside
– 10% Recorded
Set Aside)
$0
$0
$0
$187
$187
Table 2 below shows the difference between actual SOMAH set asides and 10% of
recorded GHG allowance revenue for 2016 through 2020.
Table 2: SOMAH Set Aside Amounts from 2016-2020 (Thousands of Dollars)
Calendar
Year ERRA
Forecast
2016(b)
2017
2018
2019
2020
Total
Recorded
GHG
Allowance
Revenues
$301,670
$345,514
$348,099
$389,041
$385,894
$1,619,383
Set Aside Based on
10% of Recorded
GHG Allowance
Revenue
$15,084
$34,551
$34,810
$38,904
$38,589
$161,938
Actual Set
Aside(a)
$15,084
$34,551
$34,810
$38,904
$38,776
$162,125
Difference
(Actual Set Aside
– 10% Recorded
Set Aside)
$0
$0
$0
$0
$187
$187
(a) Years 2016-2018 include true-ups for previous under-collections, which were collected in 2020 per
D.20-02-047 and 2021 per D.20-12-038.
(b) AB 693 implemented SOMAH mid-way through 2016; therefore, GHG Revenues and set aside
amount are pro-rated 50 percent and totals reflect the pro-rated amounts.
The SOMAH set-aside for the fourth quarter of 2020 was over-forecasted by $186,832.
D.20-04-012 states that the utilities shall not return any funds that are set aside to the
SOMAH program until given explicit direction from the Commission.9 PG&E intends to
reserve $186,832 within the SOMAH Balancing Account. In the 2022 ERRA Forecast
filing, PG&E plans to propose enacting the true-up by netting the 2020 reserve of
$186,832 from the 2022 SOMAH set aside request.
In the event that the last three months of any given year are under-forecasted, PG&E
would similarly file a true up advice letter stating the under-forecasted amount and not
9
D.20-04-012, p. 11.
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Advice 6101-E
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February 26, 2021
request additional set aside to account for the true up amount in that advice letter, but
would instead make this request in the next ERRA Forecast filing.
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 March 18, 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
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
- Page 4 -
Advice 6101-E
-5-
February 26, 2021
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
Pursuant to General Order (GO) 96-B, Rule 5.1, this advice letter is submitted with a Tier
1 designation. PG&E requests that this Tier 1 advice submittal become effective upon
date of submittal, which is February 26, 2021.
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.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/.
/S/
Erik Jacobson
Director, Regulatory Relations
cc:
Service List R.14-07-002
- Page 5 -
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: 1
Advice Letter (AL) #: 6101-E
Subject of AL: 2020 True-Up for the Solar on Multifamily Affordable Housing (SOMAH) Program Funding
Keywords (choose from CPUC listing): Compliance, Solar
AL Type:
Monthly
Quarterly
Annual
One-Time
Other:
If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:
D.20-04-012
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: 2/26/21
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
- Page 6 -
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
- Page 7 -
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
- Page 8 -
