Update to Community Choice Aggregate and Energy Service Provider Load Data and Utility Investment and Procurement Information
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- Drusilla Riley
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5 Erik Jacobson Director Regulatory Relations Pacific Gas and Electric Company 77 Beale St., Mail Code B13U P.O. Box San Francisco, CA Fax: August 1, 2017 Advice 5119-E (Pacific Gas and Electric Company U 39 E) Advice 3640-E (Southern California Edison Company U 338 E) Advice 3103-E (San Diego Gas & Electric Company U 902 E) Public Utilities Commission of the State of California Subject: Update to Community Choice Aggregate and Energy Service Provider Load Data and Utility Investment and Procurement Information Purpose Pursuant to Ordering Paragraph (OP) 5 of California Public Utilities Commission (CPUC or Commission) Decision (D.) , Pacific Gas and Electric Company (PG&E), on behalf of Southern California Edison (SCE), and San Diego Gas and Electric (SDG&E), respectfully submits this advice letter to update Tables 3 through 6 based on the most current Community Choice Aggregator (CCA) and Energy Service Provider (ESP) load data and utility investment and procurement information. Background On October 21, 2013, the Commission issued D to establish the Energy Storage Procurement Framework and Design Program ( Energy Storage Program ). The Energy Storage Program set a procurement target of 1,325 megawatts of energy storage projects for the Investor-Owned Utilities ( IOU ) to procure through a series of solicitations from 2014 to All storage projects must be online no later than Additionally, the Energy Storage Program set a procurement target for all CCAs and ESPs to procure one percent of their 2020 load, with all storage projects being online 1 D , Appendix A, p.1 2 Ibid.
6 Advice 5119-E, et al August 1, 2017 no later than As determined by the Commission, the one percent procurement target for CCAs and ESPs is in addition to paying for a portion of IOU storage procurement via non-bypassable charges. 4 On January 5, 2016, the CPUC issued a Scoping Memo and Ruling in Track 2 of the Energy Storage Order Instituting Rulemaking (OIR) seeking parties comments on revision of energy storage procurement targets. 5 The Alliance for Retail Energy Markets and Direct Access Customer Coalition (AReM/DACC) argued that some CCA/ESP procurement obligations can exceed a utility s, and proposed to prohibit future cost recovery through non-bypassable charges and credit ESPs with any excess storage for procurement that is above what the IOUs are obligated to procure. 6 In D , the Commission ruled that revisions to cost recovery of storage procurement were beyond the scope of the proceedings, but that it was in scope to consider revisions to the CCA/ESP storage procurement targets. The Commission reviewed the extent to which the combined one percent procurement obligation and non-bypassable charges assigned to CCAs/ESPs compares with the utility procurement obligations, as a percentage of utility load. In the instance that a CCA/ESP procurement obligation exceeds that of the utility, the Commission adopted an automatic limiter that proportionately reduces each CCA/ESP one percent procurement obligation by the amount the load serving entity s procurement plus its customers share of non-bypassable charges exceeds the utility obligation by a percentage of load. 7 Comparing IOU and CCA/ESP storage procurement obligations as a percentage of load is done using Tables 3 through 6 of D D requires the IOUs to update Tables 3 through 6 on an annual basis beginning August 1, 2017 through The updated tables are provided. 3 D , p Ibid. 5 R Assigned Commissioner and Assigned Administrative Law Judge s Scoping Memo and Ruling Seeking Party Comments, p D , p D , p.27.
7 Advice 5119-E, et al August 1, 2017 Updated Tables Table 3: ENERGY STORAGE COST RECOVERY (Data as of July 2017) SERVICE TERRITORY PG&E SCE SDG&E Storage MW recovered or approved for recovery via non-bypassable charges (to date) 8 Future (known additional) MW expected to be None known recovered via CAM Total MW expected to be recovered via nonbypassable charges Table 4: DIRECT ACCESS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of June 2017) SERVICE TERRITORY PG&E SCE SDG&E Applicable ESP load (GWh) 14 9,657 11,260 3,400 DA MW share of non-bypassable charges % ESP procurement obligation (GWh) This information reflects Cost Allocation Mechanism (CAM) and distribution charge recovery, and only those contracts that have been approved for recovery to date. Storage projects resulting from the biennial storage solicitations have not yet come on-line, so their above market costs have not been identified, and PCIA costs have not yet been allocated to nonutility Load Serving Entities (LSEs). We do not include a requirement of a forecast of nonbypassable charges as suggested by CCA Parties in comments on the Proposed Decision as we find this too speculative and of limited value. 9 6 MW via distribution charge + 10 MW of customer-sited SGIP/PLS projects (R : Motion of PG&E to Further Update Information in its January 4, 2016 Report Regarding Energy Storage System Procurement Targets and Policies - July 7, 2017), and 0.5 MW for Browns Valley (A ; D ) MW via distribution charge MW of SGIP/PLS + 22 MW of Aliso Canyon Energy Storage (ACES) projects (Resolution E MW of original 27 MW authorization was cancelled) MW in West LA Basin via SCE 2013 LCR RFO to replace SONGs capacity (D ) MW via distribution rates MW of SGIP/PLS (D , Attach A) MW of ACES storage projects (Resolution E-4798) MW ACES Design Build Transfer project (Resolution E-4791) + Preferred Resources Pilot 2-60 MW (A ) MW (A LCR RFO Moorpark) + 20 MW ACES EGTs (A ) 13 A June 2017 data, available at Supplemental Direct Access Implementation Activities Report Statewide Summary June 15, Direct Access (DA) ESPs are responsible for non-bypassable charges based on load share for CAM and distribution rates. This does not include PCIA for storage. ESPs comprise 13.0 percent of load share, based on the latest Direct Access Implementation Activities Report, published June 15, 2017, accessible at:
8 Advice 5119-E, et al August 1, % ESP procurement obligation (MW) Table 5: COMMUNITY CHOICE AGGREGATORS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of June 2017) SERVICE TERRITORY PG&E SCE SDG&E Applicable CCA load (GWh) 17 3, CCA MW share of non-bypassable charges MW 2 0 1% CCA procurement obligation (GWh) % CCA procurement obligation (MW) 6 MWs 1 0 Table 6: COMPARISON OF UTILITY, DIRECT ACCESS, AND COMMUNITY CHOICE AGGREGATORS STORAGE PROCUREMENT COST OBLIGATIONS (Data as of January 2017) SERVICE TERRITORY PG&E SCE SDG&E Storage obligation as % of total 2020 load forecast 20 - Storage Target of 1325 MW Storage obligations as % total of 2020 load forecast Storage Target of 1825 MW 21 ESP Current Share: 1% procurement obligation + non-bypassable charge (MW / % of load) CCA Current Share: 1% procurement obligation + non-bypassable charge (MW / % of load) 580 MW ~ 2.7% 746 MW ~ 3.5% 19 MW ~ 1.1 % 6.5 MW ~ 1.1 % 580 MW ~2.6% 746 MW ~3.3% 72 MW ~3.6% 3 MW ~2.8% 165 MW ~3.7% 331 MW ~7.4% 16 MW ~2.6% 0 The filing would not increase any current rate or charge, cause the withdrawal of service, or conflict with any rate schedule or rule. 16 Assumes 64 percent capacity factor (CF) for ESPs and CCAs. MW = 1000*GWh/(CF/8760) 17 These totals only include existing CCAs for which data are available Lancaster, Marin, and Sonoma. Planned CCAs are not included. When additional CCAs report load that load should be reflected in the updates to these tables CCA load forecast data available at: Corrected LSE and BA Tables Mid Baseline Mid AAEE. 19 Currently active CCAs comprise 3 percent of forecasted 2020 load in PG&E territory; 0.5% of forecasted 2020 load in SCE territory. Percentages are derived from California Energy Demand Update Forecast, California Energy Commission, accessible at: load assumptions: PG&E 21,597 MWs in 2020; SCE 22,296 MWs in 2020; SDG&E 4,455 MWs in Source: California Energy Commission Draft Staff Report. Docket 16-IEPR. December 5, Includes procurement under AB 2868.
9 Advice 5119-E, et al August 1, 2017 Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or , no later than August 21, 2017, which is 20 days after the date of this filing. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4 th Floor San Francisco, California Facsimile: (415) 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 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: For PG&E: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box San Francisco, California Facsimile: (415) PGETariffs@pge.com For SCE: Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Facsimile: (626) AdviceTariffManager@sce.com Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company
10 Advice 5119-E, et al August 1, Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415) Karyn.Gansecki@sce.com For SDG&E: Megan Caulson Regulatory Tariff Manager 8330 Century Park Court, CP31F San Diego, CA mcaulson@semprautilities.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) 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). Effective Date PG&E, SCE, and SDG&E request that this Tier 1 advice filing become effective upon date of filing, which is August 1, 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 Address changes to the General Order 96-B service list should be directed to PG&E at address PGETariffs@pge.com. For changes to any other service list, please contact the Commission s Process Office at (415) or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter filings can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List R
11 CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/cpuc Utility No. Pacific Gas and Electric Company (ID U39 E) Utility type: Contact Person: Kingsley Cheng ELC GAS Phone #: (415) PLC HEAT WATER and EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water (Date Filed/ Received Stamp by CPUC) Advice Letter (AL) #: 5119-E, et al. Tier: 1 Subject of AL: Update to Community Choice Aggregate and Energy Service Provider Load Data and Utility Investment and Procurement Information Keywords (choose from CPUC listing): Compliance, Procurement, Storage AL filing type: Monthly Quarterly Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D 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: Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: No Confidential information will be made available to those who have executed a nondisclosure agreement: N/A Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential information: Resolution Required? Yes No Requested effective date: August 1, 2017 Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A No. of tariff sheets: 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 proposed: N/A Pending advice letters that revise the same tariff sheets: N/A Protests, dispositions, and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: California Public Utilities Commission Energy Division EDTariffUnit 505 Van Ness Ave., 4 th Flr. San Francisco, CA EDTariffUnit@cpuc.ca.gov Pacific Gas and Electric Company Attn: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson 77 Beale Street, Mail Code B13U P.O. Box San Francisco, CA PGETariffs@pge.com
12 PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Division of Ratepayer Advocates Office of Ratepayer Advocates, Electricity Planning and Policy B Albion Power Company Don Pickett & Associates, Inc. OnGrid Solar Alcantar & Kahl LLP Douglass & Liddell Pacific Gas and Electric Company Anderson & Poole Downey & Brand Praxair Atlas ReFuel Ellison Schneider & Harris LLP Regulatory & Cogeneration Service, Inc. BART Evaluation + Strategy for Social SCD Energy Solutions Innovation Barkovich & Yap, Inc. G. A. Krause & Assoc. SCE Bartle Wells Associates GenOn Energy Inc. SDG&E and SoCalGas Braun Blaising McLaughlin & Smith, P.C. GenOn Energy, Inc. SPURR Braun Blaising McLaughlin, P.C. Goodin, MacBride, Squeri, Schlotz & San Francisco Water Power and Sewer Ritchie CENERGY POWER Green Charge Networks Seattle City Light CPUC Green Power Institute Sempra Energy (Socal Gas) CalCom Solar Hanna & Morton Sempra Utilities California Cotton Ginners & Growers Assn ICF SoCalGas California Energy Commission International Power Technology Southern California Edison Company California Public Utilities Commission Intestate Gas Services, Inc. Southern California Gas Company (SoCalGas) California State Association of Counties Kelly Group Spark Energy Calpine Ken Bohn Consulting Sun Light & Power Casner, Steve Leviton Manufacturing Co., Inc. Sunshine Design Center for Biological Diversity Linde Tecogen, Inc. City of Palo Alto Los Angeles County Integrated Waste TerraVerde Renewable Partners Management Task Force City of San Jose Los Angeles Dept of Water & Power TerraVerde Renewable Partners, LLC Clean Power MRW & Associates Tiger Natural Gas, Inc. Clean Power Research Manatt Phelps Phillips TransCanada Coast Economic Consulting Marin Energy Authority Troutman Sanders LLP Commercial Energy McKenna Long & Aldridge LLP Utility Cost Management Cool Earth Solar, Inc. McKenzie & Associates Utility Power Solutions County of Tehama - Department of Public Modesto Irrigation District Utility Specialists Works Crossborder Energy Morgan Stanley Verizon Crown Road Energy, LLC NLine Energy, Inc. Water and Energy Consulting Davis Wright Tremaine LLP NRG Solar Wellhead Electric Company Day Carter Murphy Nexant, Inc. Western Manufactured Housing Communities Association (WMA) Defense Energy Support Center ORA YEP Energy Dept of General Services Office of Ratepayer Advocates Yelp Energy
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