Details for: PGE Comments on Draft Resolution E-5124.pdf

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Erik Jacobson
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 5, 2021
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Comments of Pacific Gas and Electric Company on Draft Resolution

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) appreciates the opportunity to comment on
the California Public Utilities Commission’s (CPUC or Commission) Draft Resolution E5124 (Draft Resolution) approving with modifications, CleanPowerSF’s (CPSF) Advice
Letter (AL) 12-E, East Bay Community Energy’s (EBCE) AL 14-E/E-A, Marin Clean
Energy’s (MCE) AL 42-E/E-A/E-B, Peninsula Clean Energy’s (PCE) AL 11-E, San Jose
Clean Energy (SJCE) AL 15-E, to create Disadvantaged Communities Green Tariff
(DAC-GT) and/or Community Solar Green Tariff (CS-GT) rates and program design in
compliance with Decision (D.)18-06-027.
PG&E’s Comment:
PG&E appreciates the Draft Resolution and its pragmatic approach. PG&E offers two
minor changes to provide further simplicity, clarity, and flexibility. PG&E also provides
one clarification to the Draft Resolution.
1. PG&E Recommends Two Minor Changes for simplicity, clarity, and flexibility.
First, PG&E recommends the Commission permit PG&E to distribute upfront or
common CCA integration costs not specific to an individual CCA among the CCAs’
subaccounts on the basis of their MW allocations as of the effective date of the
resolution. This will help provide additional clarity and simplify this allocation process.
As discussed on page 11 and Finding and Conclusions 14 and 15, the Draft Resolution
adopts PG&E’s proposal to distribute “CCA integration” costs not specific to an
individual CCA, for example start up IT costs, to CCA subaccounts. PG&E recommends
that the Commission specify the allocation of these costs be in proportion to that CCA’s


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PG&E Comments on Draft Resolution E-5124 -2- April 5, 2021 dedicated DAC-GT and CS-GT capacity as of the adoption of this Draft Resolution. This will encourage a fair, clear, and consistent methodology over time. Second, PG&E recommends flexibility to allow CCAs to report on spending of allowance auction proceeds and GHG emissions reductions directly to California Air Resources Board (CARB) if the CARB cap and trade regulations are updated in the future to enable this direct reporting process. As discussed on page 13 of the Draft Resolution, CARB’s current cap and trade regulations place this reporting responsibility directly on the “electrical distribution utilities” 1 (i.e. PG&E) and not the CCAs. It is possible that CARB may adjust those regulations in the future to enable CCA recipients of GHG allowance auction proceeds to report directly to CARB. To accommodate that change, PG&E recommends CCAs report directly to CARB if and when future updates to the cap and trade regulations allow. 2. Clarification of Energy Efficiency Decision Lastly, while PG&E takes no issue with quarterly payment arrangements with the CCAs as set forth in the Draft Resolution, 2 PG&E points out that there is more recent change regarding Energy Efficiency quarterly payments between the IOUs and regional energy networks (RENs). The Draft Resolution relies on D.14-10-046, Ordering Paragraph 24 finding that “uniformity in program rules allows for more consistent program oversight and implementation.” 3 However, the Commission recently updated its guidance to the IOUs regarding the mechanics of contracting and funding: “On the topic of PG&E’s suggestions to allow more flexibility in the utilities’ fiscal agent role for RENs, we agree that there should be flexibility in payment terms and timing, as long as both parties agree. Thus, we explicitly authorize the utility fiscal agent and a REN to depart from the specific requirements of D.12-11-015 and D.14-10-046, as long as the REN and the utility mutually agree.” 4 As mentioned above, PG&E takes no issue with the Draft Resolution requirements for quarterly payments but identifies the Commission’s recent guidance for completeness. Final Regulation Order California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms, section 95892, page 61, “No later than June 30, 2014 and June 30 of each calendar year thereafter, each electrical distribution utility shall submit a report to the Executive Officer describing the disposition of all allocated allowance auction proceeds during the previous calendar year.” Available at 2 Draft Resolution, p. 10. 3 Draft Resolution, pp. 9-10. 4 D. 19-12-021, p. 43. See also p.85 Conclusion of Law 15, and p. 89 Ordering Paragraph 5. 1
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PG&E Comments on Draft Resolution E-5124 -3- April 5, 2021 Respectfully submitted, /S/ Erik Jacobson Director, Regulatory Relations cc: Edward Randolph, Director, Energy Division Energy Division Tariff Unit Joshua Litwin, Regulatory Analyst, Energy Division Christopher Westling, Supervisor, Energy Division Karen Schmidt, Clean Power Alliance of Southern California Nancy Whang, Clean Power Alliance of Southern California Gary A. Stern, Ph.D., Southern California Edison Company Laura Genao c/o Karyn Gansecki, Southern California Edison Company Brandi Anderson, Southern California Edison Company Service List R.14-07-002
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