Details for: SCE's Joint IOUs Protest Response to Advice 4587-E et al.pdf


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Shinjini C. Menon.
Managing Director, State Regulatory Operations

October 11, 2021
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
SUBJECT:

Joint Reply to Protest to Advice 4587-E et al, Southern California Edison
Company, Pacific Gas and Electric Company, San Diego Gas & Electric
Company, Liberty Utilities (CalPeco Electric), Bear Valley Electric Service,
Inc., and PacifiCorp’s Updates to GHG Templates

Dear Energy Division Tariff Unit:
In accordance with General Rule 7.4.3 of General Order (GO) 96-B, Southern California
Edison Company (SCE) hereby submits this joint reply to the protest of the Public
Advocates Office at the California Public Utilities Commission (Cal Advocates).
I. BACKGROUND
In compliance with California Public Utilities Commission (CPUC or Commission)
Decision (D.) 21-08-026 (Decision), Ordering Paragraph (OP) 13, Southern California
Edison Company (SCE) submitted Advice 4587-E et al on behalf of Pacific Gas and
Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Liberty
Utilities (CalPeco Electric), Bear Valley Electric Service, Inc. (BVES), PacifiCorp d/b/a
Pacific Power (PacifiCorp), and itself (collectively, the Joint Investor-Owned Utilities or
Joint IOUs), with proposed changes to greenhouse gas (GHG) reporting Templates D-1
through D-5. A supplemental advice letter was submitted on October 1, 2021 to reflect
two minor edits as well as redline and clean versions of both the templates and
instructions.
Cal Advocates submitted a protest on October 4, 2021 of the proposed changes to
Templates D-1 through D-5 (Protest).

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-3377

Fax (626) 302-6396





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Energy Division California Public Utilities Commission October 11, 2021 Page 2 II. REPLY TO PROTEST Cal Advocates agrees with the updates proposed by the Joint IOUs except the complete removal of Template D-2, which shows historical forecast and recorded GHG emissions and costs. Additionally, Cal Advocates correctly explains that the GHG emissions and cost data supplied in this template is not readily available elsewhere in the same format and in one table, given that the forecast data appears in other sections of each IOU’s Energy Resource Recovery Account (ERRA) or Energy Cost Adjustment (ECA) forecast filings, while the recorded data appears in each IOU’s ERRA or ECAC compliance filing. Cal Advocates requests that a modified version of Template D-2 remain a requirement and the Joint IOUs do not oppose that request. Accordingly, consistent with Cal Advocates request, the Joint IOUs agree to submit a supplemental advice letter with Template D-2 modified to remove “lines 9-12 and 18 of Template D-2 regarding Indirect GHG emissions and costs” as they “are unnecessary and can be removed.”1 The changes requested result in a GHG emissions table that focuses only on direct GHG emissions and costs and aligns with the requirements to show this version of the Template in the ERRA/ECAC compliance proceedings. III. CONCLUSION The Joint IOUs appreciate the thoughtful response of Cal Advocates and agree to file a supplemental advice letter to reflect the requested adjustments to Template D-2. Southern California Edison Company /s/ Shinjini C. Menon Shinjini C. Menon SCM:ms:jm cc: Edward Randolph, Director, CPUC Energy Division Franz Cheng, CPUC Energy Division Julie Halligan, Cal Advocates Service Lists R.20-05-002 and R.13-08-002 1 Protest of Cal Advocates, , p. 3
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