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
April 1, 2021
Advice 6145-E
(Pacific Gas and Electric Company ID U 39 E)
Public Utilities Commission of the State of California
Subject:
2021 Energy Resource Recovery Account Trigger Amount
Pacific Gas and Electric Company (PG&E) hereby submits its annual advice letter
calculating the Energy Resource Recovery Account (ERRA) trigger amount for 2021,
pursuant to Decisions (D.) 02-10-062, D.04-01-050, D.04-12-048, and D.15-05-008.
Purpose and Background
The purpose of this advice letter is to establish PG&E’s 2021 ERRA trigger amount in
compliance with Public Utilities Code Section 454.5(d)(3); and D.02-10-062, D.04-01-050,
D.04-12-048, and D.15-05-008.
In D.02-10-062, the California Public Utilities Commission (Commission or CPUC)
established a “trigger” mechanism to comply with the Public Utilities Code Section
454.5(d)(3) requirement that “any overcollection or undercollection in the power
procurement balancing account does not exceed 5 percent of the electrical corporation’s
actual recorded generation revenues for the prior calendar year excluding revenues
collected for the Department of Water Resources.”1 In D.04-01-050, the Commission
ordered the utilities to submit their ERRA trigger amount advice letters on or before April 1
of each year.
ERRA Trigger Calculation
Pursuant to D.02-10-062, the 4 percent trigger requires PG&E to file an expedited
application requesting approval within 60 days should the balance reach or exceed the
5 percent threshold of prior year recorded generation revenues. PG&E’s 2021 ERRA
trigger amount or 4 percent of the actual recorded generation revenues for the prior
calendar year is $218.6 million. PG&E’s 2021 ERRA threshold amount or 5 percent of
the actual recorded generation revenues for the prior calendar year is $273 million.
1
D.02-10-062, p. 54 (quoting Pub. Util. Code § 454.5(d)(3)).
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Advice 6145-E
-2-
April 1, 2021
Consistent with PG&E’s previous annual ERRA trigger submittals, this year’s calculation
is based on generation revenues that PG&E records in various balancing accounts,
including the ERRA, the Portfolio Allocation Balancing Account (PABA), the Modified
Transition Cost Balancing Account (MTCBA), the New System Generation Balancing
Account (NSGBA), and the Green Tariff Shared Renewables Balancing Account
(GTSRBA).2 These balancing accounts include fuel and electric procurement costs,
ongoing competition transition costs, capital and non-fuel operating costs in PG&E’s
existing generation asset base, cost allocation mechanism costs, and expenses PG&E
incurred to procure renewable generation resources for customers participating in the
Green Tariff Shared Renewables Program.
The 2020 revenues from these regulatory accounts and the corresponding 2021 trigger
amount are shown below:
2020 ERRA Revenues (including TBCC revenue & AB920 credit)
2020 Uncapped PABA Revenues
2020 PUBA Revenues
2020 MTCBA Revenues
2020 NSGBA Revenues
2020 GTSRBA Revenues
Total 2020 Generation Revenues, excluding DWR
2021 ERRA Trigger (4% of total 2020 revenue)
2021 ERRA Threshold Amount (5% of total 2020 revenue)
2,707,173,542.33
2,638,565,367.26
(247,158,483.32)
76,739,955.87
282,683,813.00
8,367,737.00
$5,466,371,932
$218,654,877
$273,318,597
Conclusion
PG&E requests that the Commission approve $218.6 million as PG&E’s 2021 ERRA
trigger amount and $273 million as PG&E’s 2021 ERRA threshold amount. PG&E also
requests that this 2021 trigger amount and threshold amount remain in effect until the
Commission adopts the 2022 trigger amount and threshold amount, to be submitted by
advice letter on or before April 1, 2022.
The submittal would not increase any current rate or charge, cause the withdrawal of
service, or conflict with any rate schedule or rule.
2
Starting in May 2020, PG&E began recording the PCIA revenue shortfall that exceeded the
adopted departed load customer PCIA rate cap, to the PCIA Undercollection Balancing Account
(PUBA). The generation revenues recorded in this balancing account have been included in the
2021 ERRA trigger calculation. Please see PG&E’s annual ERRA Forecast application for a full
description of these balancing accounts.
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Advice 6145-E
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April 1, 2021
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 April 21, 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
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).
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Advice 6145-E
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April 1, 2021
Effective Date
PG&E requests that this Tier 1 advice letter become effective upon date of submittal,
which is April 1, 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 A.20-07-002. 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 A.20-07-002
- Page 4 -
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) #: 6145-E
Subject of AL: 2021 Energy Resource Recovery Account Trigger Amount
Keywords (choose from CPUC listing): Compliance, Balancing Account
AL Type:
Monthly
Quarterly
Annual
One-Time
Other:
If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:
D.02-10-062, D.04-01-050, D.04-12-048, and D.15-05-008
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: 4/1/21
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 5 -
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 6 -
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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