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 THE PROPOSED DECISION ADDRESSING APPLICATIONS OF THE,, SAN DIEGO GAS & ELECTRIC COMPANY AND SOUTHERN CALIFORNIA EDISON COMPANY FOR APPROVAL OF THEIR TRIENNIAL INVESTMENT PLANS FOR THE ELECTRIC PROGRAM INVESTMENT CHARGE PROGRAM FOR THE YEARS 2018 THROUGH 2020 FADIA RAFEEDIE KHOURY KRIS G. VYAS Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: October 1, 2018

2 OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) Section TABLE OF CONTENTS Page I. II. III. INTRODUCTION...1 SCE SUPPORTS THE RAP IN GENERAL, AND SEEKS CLARIFICATION REGARDING A FEW OF THE RAP APPLICATION DELIVERABLES...2 CONCLUSION...3 i

3 OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) Authority TABLE OF AUTHORITIES Page CPUC Rules of Practice and Procedure Rule ii

4 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 THE PROPOSED DECISION ADDRESSING APPLICATIONS OF THE,, SAN DIEGO GAS & ELECTRIC COMPANY AND SOUTHERN CALIFORNIA EDISON COMPANY FOR APPROVAL OF THEIR TRIENNIAL INVESTMENT PLANS FOR THE ELECTRIC PROGRAM INVESTMENT CHARGE PROGRAM FOR THE YEARS 2018 THROUGH 2020 I. INTRODUCTION Pursuant to Rule 14.3 of the California Public Utilities Commission s (Commission) Rules of Practice and Procedure, Southern California Edison Company (SCE) respectfully submits its opening comments regarding Administrative Law Judge Roscow s Proposed Decision (PD) Addressing Applications of the California Energy Commission, Pacific Gas and Electric Company, San Diego Gas and Electric Company and Southern California Edison Company for Approval of Their Triennial Investment Plans for the Electric Program Investment Charge (EPIC) Program for the Years 2018 Through SCE supports the Commission s Proposed Decision approving SCE s

5 Investment Plan application. SCE s opening comments briefly address the PD s requirement that the Investor Owned Utilities (IOU) Administrators jointly file a Research Administration Plan (RAP) Application 180 days from the date of the final decision. 1 SCE s comments specifically seek clarification concerning a few of the RAP Application deliverables. II. SCE SUPPORTS THE RAP IN GENERAL, AND SEEKS CLARIFICATION REGARDING A FEW OF THE RAP APPLICATION DELIVERABLES The PD instructs the IOU Administrators to specify the funding amount for the non-competitive awards to make it easier to assess the fraction of funding that is being directly awarded. 2 Due to shifts in energy policy and potential changes in business needs, SCE is currently unable to reflect an exact amount of direct awards for potential demonstrations in future investment plans. SCE clarifies that creating a chart/graph in the Annual Report to specify the funding amount for the non-competitive awards is achievable, and suggests that the Commission instruct the IOUs to collaborate on a direct awards chart/graph to be included in the Annual Report to help ensure consistent reporting. The PD further instructs the EPIC IOU Administrators to establish a process to make sure that once the California Energy Commission s Applied R&D projects are completed, the results are considered and potential Technology Demonstration & Deployment projects are identified. 3 SCE clarifies that, because the Policy + Innovation Coordination Group s (PICG), Policy + Innovation Partnership Areas (PIPAs) are issue areas of common interest, substantive opportunity, and value identified, around which the PICG will engage in targeted coordination, 4 the PICG PIPA represents the most appropriate body and process to maximize coordination and collaboration between the CEC s applied research results and potential IOU demonstrations. 1 EPIC PD, Ordering Paragraph 6. 2 EPIC PD, Attachment B, at p EPIC PD, Attachment B, at p Energy Division, Staff Proposal: EPIC PICG, February 22, 2018, at p 7. 2

6 Lastly, the PD proposes that the Administrators create a single centralized database containing all relevant information on active and completed EPIC projects along with monitoring and quarterly reporting of key performance metrics, in order to support the on-going evaluation of the Program. 5 SCE supports creating a single centralized database of all of the Administrators EPIC projects. SCE notes that, given the role of the PICG s activities as described in the Energy Division staff proposal, 6 the creation of the database is most appropriately assigned to the PICG coordinator. Database updates can be coordinated with the EPIC Administrators. III. CONCLUSION SCE appreciates the opportunity to provide opening comments on the EPIC PD. SCE reiterates that it looks forward to participating in the PICG and establishing an EPIC Program that is more dynamic, responds quicker to technology changes and gaps and fosters greater transparency and coordination with interested stakeholders. 7 5 EPIC PD, Attachment B, at p Energy Division, Staff Proposal: EPIC PICG, February 22, 2018, at pp SCE Opening Comments on the Energy Division, Staff Proposal: EPIC PICG, at p. 6. 3

7 Respectfully submitted, FADIA RAFEEDIE KHOURY KRIS G. VYAS By: /s/ Kris G. Vyas Kris G. Vyas Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) October 1,

8 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. A (Filed April 28, 2017) And Consolidated Matters. 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 THE PROPOSED DECISION ADDRESSING APPLICATIONS OF THE, PACIFIC GAS AND ELECTRIC COMPANY, SAN DIEGO GAS & ELECTRIC COMPANY AND SOUTHERN CALIFORNIA EDISON COMPANY FOR APPROVAL OF THEIR TRIENNIAL INVESTMENT PLANS FOR THE ELECTRIC PROGRAM INVESTMENT CHARGE PROGRAM FOR THE YEARS 2018 THROUGH 2020 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. Placing the copies in sealed envelopes and causing such envelopes to be delivered by U.S. Mail to the offices of the Commissioners or other addresses. ALJ Stephen C. Roscow CPUC 505 Van Ness Avenue San Francisco, CA Executed October 1, 2018, at Rosemead, California. /s/ Sandra Sedano Sandra Sedano Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

9 CPUC - Service Lists - A Page 1 of 5 10/1/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR APPROVAL FILER: LIST NAME: LIST LAST CHANGED: SEPTEMBER 19, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties MADELINE STANO MARIA STAMAS ENERGY LEGAL COUNSEL LEGAL FELLOW, ENERGY PROGRAM THE GREENLINING INSTITUTE NATURAL RESOURCES DEFENSE COUNCIL, CA 00000, CA FOR: THE GREENLINING INSTITUTE FOR: NATURAL RESOURCES DEFENSE COUNCIL (NRDC) KRIS G. VYAS, ESQ. JAMES ANDERSON SR. ATTORNEY PRESIDENT AND CEO SOUTHERN CALIFORNIA EDISON COMPANY CLEANTECH SAN DIEGO 2244 WALNUT GROVE AVE. / PO BOX INDIA STREET ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: CLEANTECH SAN DIEGO ELLEN N. ADLER ANAND DURVASULA SR. COUNSEL SAN DIEGO GAS & ELECTRIC COMPANY COMMISSIONER RANDOLPH 8330 CENTURY PARK COURT, CP32D ROOM 4107 SAN DIEGO, CA VAN NESS AVENUE FOR: SAN DIEGO GAS & ELECTRIC COMPANY SAN FRANCISCO, CA FOR: ORA CHRISTOPHER J. WARNER MARK MILES ATTORNEY CEO MARK CONSULTING, INC. 77 BEALE STREET / PO BOX LAKESHORE AVENUE, SUITE 25A SAN FRANCISCO, CA OAKLAND, CA 94606

10 CPUC - Service Lists - A Page 2 of 5 10/1/2018 FOR: FOR: MARK MILES CONSULTING, INC. (MMCI) SHIRLEY GEE DEEPA LOUNSBURY MANAGING PARTNER CALSEED PROGRAM MGR. ANGEL PLUS, LLC CALIFORNIA CLEAN ENERGY FUND 844 PROSPECT AVENUE TH STREET, SUITE 1220 OAKLAND, CA OAKLAND, CA FOR: ANGEL PLUS, LLC FOR: CALIFORNIA CLEAN ENERGY FUND (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 LESLIE ALMOND SOUTHERN CALIFORNIA EDISON, CA 00000, CA PAMELA DOUGHMAN MRW & ASSOCIATES LLC

11 CPUC - Service Lists - A Page 3 of 5 10/1/2018 CALIF. ENERGY COMMISSION, CA 00000, CA DANIEL DOUGLASS CASE ADMINISTRATION ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVE. / PO BOX PARK GRANADA, SUITE 209 ROSEMEAD, CA CALABASAS, CA FOR: WESTERN POWER TRADING FORUM WALKER A. MATTHEWS, III ANNLYN FAUSTINO SR. ATTORNEY REGULATORY & COMPLIANCE SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE. / PO BOX CENTURY PARK COURT, CP32F ROSEMEAD, CA SAN DIEGO, CA CHRISTA LIM DEAN A. KINPORTS REGULATORY CASE MGR. REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32D 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA SAN DIEGO, CA CENTRAL FILES BRENT COLASURDO SAN DIEGO GAS & ELECTRIC COMPANY UMBERG ZIPSER LLP 8330 CENTURY PARK CT, CP31-E SAN DIEGO, CA , CA JULIE CERIO LARA ETTENSON DIR - CA EE POLICY 77 BEALE ST., RM. 2388B NATURAL RESOURCES DEFENSE COUNCIL SAN FRANCISCO, CA SUTTER ST., 21ST FL. 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. POLICY ASSOCIATE, BUS. DEVELOPMENT TESLA, INC. 77 BEALE STREET, RM 2388B 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)

12 CPUC - Service Lists - A Page 4 of 5 10/1/2018 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 CHERYL COX DIR - UTILITY SOLUTIONS CHARGEPOINT, INC. PROCUREMENT STRATEGY AND OVERSIGHT BRANC 245 HACIENDA AVENUE 300 Capitol Mall CAMPBELL, CA Sacramento, CA GABRIEL HERRERA, ESQ. LYNN HAUG OFFICE OF CHIEF COUNSEL ATTORNEY ELLISON SCHNEIDER HARRIS & DONLAN LLP 1516 NINTH STREET, MS CAPITOL AVE., STE. 400 SACRAMENTO, CA SACRAMENTO, CA FOR: ANDREW B. BROWN ATTORNEY AT LAW ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITAL AVENUE, SUITE 400 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 5015 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 95814

13 CPUC - Service Lists - A Page 5 of 5 10/1/2018 ANTHONY NG DORIS YAMAMOTO 1516 NINTH STREET, MS NINTH STREET, MS 51 SACRAMENTO, CA SACRAMENTO, CA 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 WILLIAM DIETRICH SUPERVISOR, BLDG ENERGY EFFICIENCY SR. ATTY - CHIEF COUNSEL'S OFFICE TH STREET 1516 NINTH STREET, MS-14 SACRAMENTO, CA SACRAMENTO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS