BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of Pacific Gas and Electric Company for Approval of its Electric Program Investment Charge Investment Plan And Consolidated Matters. A (Filed April 28, 2017) A A A OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) REGARDING ELECTRIC PROGRAM INVESTMENT CHARGE PROPOSED DECISION KRIS G. VYAS WALKER A. MATTHEWS, III Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: December 28, 2017

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of Pacific Gas and Electric Company for Approval of its Electric Program Investment Charge Investment Plan And Consolidated Matters. A (Filed April 28, 2017) A A A OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) REGARDING ELECTRIC PROGRAM INVESTMENT CHARGE PROPOSED DECISION I. INTRODUCTION Pursuant to Rule 14.3 of the California Public Utilities Commission s (Commission s) Rules of Practice and Procedure, Southern California Edison Company (SCE) respectfully submits these comments concerning Administrative Law Judge (ALJ) Roscow s Proposed Decision (PD) in the Electric Program Investment Charge (EPIC) proceeding. As discussed below, SCE generally supports the PD. II. SCE SUPPORTS THE COMISSION S APPROVAL OF THE CEC S INVESTMENT PLAN SCE supports ALJ Roscow s PD approving the CEC s EPIC Investment Plan Application. 1 The CEC carefully coordinated with SCE, Pacific Gas & Electric (PG&E) and San Diego Gas & Electric (SDG&E) (collectively, the Utilities) in planning and refining the A

3 2020 EPIC Investment Plans. The CEC and the Utilities jointly attended the Electric Power Research Institute s session on potential gaps. Also, as noted in SCE s EPIC Application, 2 the CEC and the Utilities held a joint webinar, as well as three joint stakeholder workshops. 3 Moreover, the CEC and the Utilities held bi-weekly conference calls to coordinate Investment Plans. The Administrators intend to continue to meet and engage to coordinate, leverage funding, identify areas of collaboration and avoid duplication of efforts. 4 III. SCE CONDITIONALLY SUPPORTS THE COMMISSION S PROPOSED INDEPENDENT BODY SCE conditionally supports the Policy and Innovation Coordination Group (PICG) as proposed in the PD. SCE supports the PD s stated goal that the PICG help ensure that EPIC investments are optimally aligned with and informed by key Commission and California energy innovation needs and goals. 5 Furthermore, SCE appreciates the PD s guidance that the PICG not create undue burdens on the EPIC Administrators. 6 However, SCE believes the PCIG needs to do more than simply provide coordination; it should also provide support for the four EPIC Administrators. For example, the Evaluation Report identified the independent body as a means to improve project results dissemination. 7 While the PD indicates that the Commission does not intend the PICG to be a broad administrative support body, 8 SCE recommends that the PD not exclude the PICG s potential administrative support activities at this time. This is particularly important in light of the fact that the EPIC Utility Administrators have identified administrative 2 A Id. at p Id. 5 PD, p PD, p EPIC Evaluation Report, pp PD, p

4 assistance needs. Administrative support, as noted in SCE s EPIC Evaluation Report Opening Comments, could help the Administrators focus on actual program implementation, which directly supports the PD s stated goal for the PICG to provide an overarching view of the program and targeted coordination among EPIC [Administrators] and the Commission. 9 SCE supports the PD s recommendation for next steps toward establishment of the PICG, and supports the PD language directing the Energy Division to develop a staff proposal as soon as possible in 2018 that provides further detail regarding how the PICG framework adopted in this decision should be implemented. 10 SCE recommends allowing Energy Division staff fully consider all aspects of the PICG s potential activities in their forthcoming proposal. The Evaluation Report recommends the Commission should establish priorities among its current policy goals and funding criteria to better guide the administrators in their investment planning. 11 While the PICG could be very helpful in supporting the EPIC Administrators and the Commission s efforts to track policy goals and inform related Commission proceedings, these policy goals must still need be prioritized by the Commission, in order to maximize the value of the PICG. IV. SCE REQUESTS THE COMMISSION PROVIDE THE UTILITIES A FULL THREE YEARS TO COMMIT FUNDS TO PROJECTS SCE understands the Commission s need to timely approve the CEC s EPIC Investment Plan Application, since the CEC participates in the State budgeting process. Moreover, SCE supports the PD s approval of the EPIC budgets. Since the Commission will need to issue a Phase 2 decision addressing the Utilities Portfolios in 2018, SCE respectfully requests a full three years to commit funding to projects. 9 PD, p Id. at p EPIC Evaluation Report, I-5; PD, p

5 V. CONCLUSION SCE appreciates the efforts ALJ Roscow and the Commission have made to move forward on SCE s EPIC Investment Plan Application. SCE generally supports the PD. SCE supports the PD s approval of the CEC s EPIC Investment Plan Application. SCE conditionally supports the PICG as proposed in the PD. SCE supports the PD s approval of the EPIC budgets. Lastly, SCE understands the need for a subsequent decision that addresses the Utilities Portfolios and further defines the PCIG s structure and activities. However, once a Phase 2 decision is issued in 2018, SCE requests a full three years to commit funding to projects. Respectfully submitted, KRIS G. VYAS WALKER A. MATTHEWS, III /s/ Kris G. Vyas By: Kris G. Vyas Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) kris.vyas@sce.com December 28,

6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of Pacific Gas and Electric Company for Approval of its Electric Program Investment Charge Investment Plan And Consolidated Matters. A (Filed April 28, 2017) A A A CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) REGARDING ELECTRIC PROGRAM INVESTMENT CHARGE PROPOSED DECISION on all parties identified on the attached consolidated service list(s): A , et al. Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address and by U.S. mail to those on the service list without an address. Placing copies in sealed envelopes and causing such envelopes to be delivered by U.S. mail to the offices of the Assigned ALJ(s) or other addressee(s) as follows: ALJ Stephen C. Roscow CPUC 505 Van Ness Ave. San Francisco, CA Executed December 28, 2017, at Rosemead, California. /s/gina Leisure Gina Leisure SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

7 CPUC - Service Lists - A Page 1 of 5 12/28/2017 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR APPROVAL FILER: LIST NAME: LIST LAST CHANGED: DECEMBER 27, 2017 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties MARIA STAMAS KRIS G. VYAS, ESQ. LEGAL FELLOW, ENERGY PROGRAM SR. ATTORNEY NATURAL RESOURCES DEFENSE COUNCIL SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. / PO BOX 800, CA ROSEMEAD, CA FOR: NATURAL RESOURCES DEFENSE COUNCIL FOR: SOUTHERN CALIFORNIA EDISON COMPANY (NRDC) JAMES ANDERSON KIRSTIE C. RAAGAS PRESIDENT AND CEO REGULATORY COUNSEL CLEANTECH SAN DIEGO SAN DIEGO GAS & ELECTRIC COMPANY 2159 INDIA STREET 8330 CENTURY PARK COURT, CP31F SAN DIEGO, CA SAN DIEGO, CA FOR: CLEANTECH SAN DIEGO FOR: SAN DIEGO GAS & ELECTRIC COMPANY ANAND DURVASULA CHRISTOPHER J. WARNER ATTORNEY LEGAL DIVISION ROOM BEALE STREET / PO BOX VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: FOR: ORA MARK MILES SHIRLEY GEE CEO MANAGING PARTNER MARK CONSULTING, INC. ANGEL PLUS, LLC 1200 LAKESHORE AVENUE, SUITE 25A 844 PROSPECT AVENUE OAKLAND, CA OAKLAND, CA 94610

8 CPUC - Service Lists - A Page 2 of 5 12/28/2017 FOR: MARK MILES CONSULTING, INC. (MMCI) FOR: ANGEL PLUS, LLC DEEPA LOUNSBURY MADELINE STANO CALSEED PROGRAM MGR. ENERGY LEGAL COUNSEL CALIFORNIA CLEAN ENERGY FUND THE GREENLINING INSTITUTE TH STREET, SUITE TH STREET, 2ND FLOOR OAKLAND, CA OAKLAND, CA FOR: CALIFORNIA CLEAN ENERGY FUND FOR: THE GREENLINING INSTITUTE (CALCEF) ANDREW G. CAMPBELL ANDREW G. CAMPBELL EXE. DIR EXEC. DIR., ENERGY INSTITUTE AT HAAS UNIVERSITY OF CALIFORNIA, BERKELEY UNIVERSITY OF CALIFORNIA, BERKELEY ENERGY INSTITUTE AT HAAS UNIVERSITY OF CALIFORNIA, BERKELEY 324 GIANNINI HALL 324 GIANNINI HALL BERKELEY, CA BERKELEY, CA FOR: SOCIAL SCIENCE RESEARCHERS FOR: RESEARCH CENTER COALITION SHANA LAZEROW ANTHONY HARRISON ATTORNEY DIR - PUBLIC POLICY COMMUNITIES FOR A BETTER ENVIRONMENT CHARGEPOINT 120 BROADWAY, SUITE E. HACIENDA AVENUE RICHMOND, CA CAMPBELL, CA FOR: CALIFORNIA ENVIRONMENTAL JUSTICE FOR: CHARGEPOINT, INC. ALLIANCE (CEJA) ALLAN L. WARD, II CHIEF COUNSELS OFFICE TH STREET, MS 14 SACRAMENTO, CA FOR: CALIFORNIA ENERGY RESOURCES CONSERVATION AND DEVELOPMENT COMMISSION Information Only AARON RENFRO SOUTHERN CALIFORNA EDISON, CA BONNIE DATTA SR. DIR - AMERICAS & ASIA PACIFIC SIEMENS, CA ISAAC SEVIER JOHN MINNICUCCI NATURAL RESOURCES DEFENSE COUNCIL SOUTHERN CALIFORNIA EDISON, CA 00000, CA KENT THOMSON LARA ETTENSON SOUTHERN CALIFORNIA EDISON NATURAL RESOURCES DEFENSE COUNCIL, CA 00000, CA LESLIE ALMOND PAMELA DOUGHMAN

9 CPUC - Service Lists - A Page 3 of 5 12/28/2017 CALIF. ENERGY COMMISSION, CA 00000, CA MRW & ASSOCIATES LLC, CA DANIEL DOUGLASS ATTORNEY DOUGLASS & LIDDELL 4766 PARK GRANADA, SUITE 209 CALABASAS, CA FOR: WESTERN POWER TRADING FORUM CASE ADMINISTRATION WALKER A. MATTHEWS, III SOUTHERN CALIFORNIA EDISON COMPANY SR. ATTORNEY 2244 WALNUT GROVE AVE. / PO BOX 800 SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA WALNUT GROVE AVE. / PO BOX 800 ROSEMEAD, CA ANNLYN FAUSTINO DEAN A. KINPORTS REGULATORY & COMPLIANCE REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA SAN DIEGO, CA EMMA D. SALUSTRO CENTRAL FILES ATTORNEY SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY (SDG&E) BRENT COLASURDO JULIE CERIO UMBERG ZIPSER LLP 77 BEALE ST., RM. 2388B, CA SAN FRANCISCO, CA DANIEL OHLENDORF GREG STEWART 77 BEALE STREET, ROOM 2388B 77 BEALE STREET, ROOM 2388B SAN FRANCISCO, CA SAN FRANCISCO, CA GEORGE ZAHARIUDAKIS FRANCESCA WAHL RESOURCE / ENTEGRATED PLANNING SR. ASSOCIATE, BUS. DEVELOPMENT TESLA, INC. 77 BEALE STREET, B9A 444 DE HARO STREET, STE. 101 SAN FRANCISCO, CA SAN FRANCISCO, CA DEBORAH BEHLES CASE ADMINISTRATION OF COUNSEL CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANC, CA 94177, CA FOR: CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANCE (CEJA)

10 CPUC - Service Lists - A Page 4 of 5 12/28/2017 CHRIS KING ROGER LIN GLOBAL CHIEF REGULATORY OFFICER CENTER ON RACE POVERTY & THE ENVIRONMENT SIEMENS SMART GIRD SOLUTIONS 1999 HARRISON STREET, STE E 3RD AVE., STE. 400 OAKLAND, CA FOSTER CITY, CA FOR: CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANCE RENEE SAMSON GABRIEL HERRERA, ESQ. DIR - UTILITY SOLUTIONS OFFICE OF CHIEF COUNSEL CHARGEPOINT, INC. 245 HACIENDA AVENUE 1516 NINTH STREET, MS 14 CAMPBELL, CA SACRAMENTO, CA LYNN HAUG ANDREW B. BROWN ATTORNEY ATTORNEY AT LAW ELLISON SCHNEIDER HARRIS & DONLAN LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVE., STE CAPITAL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA State Service MARIA SOTERO CHRISTOPHER MYERS REGULATORY ANALYST-ENERGY DIVISION CALIFORNIA PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH ROOM 4104, CA VAN NESS AVENUE SAN FRANCISCO, CA JOANNA GUBMAN KARIN M. HIETA COMMISSIONER RANDOLPH ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA STEPHEN C. ROSCOW THOMAS GARIFFO DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PLANNING & POLICY BRANCH ROOM 5109 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA DAVID X. HUANG SARA KIM STAFF ATTORNEY PROCUREMENT STRATEGY AND OVERSIGHT BRANC 300 Capitol Mall 1516 NINTH STREET, MS-14 Sacramento, CA SACRAMENTO, CA ANTHONY NG DORIS YAMAMOTO 1516 NINTH STREET, MS NINTH STREET, MS 51 SACRAMENTO, CA SACRAMENTO, CA

11 CPUC - Service Lists - A Page 5 of 5 12/28/2017 ERIK STOKES LAURIE TENHOPE 1516 NINTH STREET, MS NINTH STREET, MS 51 SACRAMENTO, CA SACRAMENTO, CA LINDA SPIEGEL MARK KOOTSTRA 1516 NINTH STREET, MS NINTH STREET, MS 51 SACRAMENTO, CA SACRAMENTO, CA MIKHAIL HARAMATI SUPERVISOR, BLDG ENERGY EFFICIENCY TH STREET SACRAMENTO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS