BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E), Pacific Gas and Electric Company (U 39-E), and San Diego Gas & Electric Company (U 902-E), for Approval of the Portfolio Allocation Methodology for all Customers. Application No (Filed April 25, 2017) SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), PACIFIC GAS AND ELECTRIC COMPANY (U 39-E), AND SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E) NOTICE OF EX PARTE COMMUNICATION JANET S. COMBS RUSSELL ARCHER Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) On behalf of SOUTHERN CALIFORNIA EDISON COMPANY, PACIFIC GAS AND ELECTRIC COMPANY, and SAN DIEGO GAS & ELECTRIC COMPANY Dated: June 21, 2017

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E), Pacific Gas and Electric Company (U 39-E), and San Diego Gas & Electric Company (U 902-E), for Approval of the Portfolio Allocation Methodology for all Customers. Application No (Filed April 25, 2017) SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), PACIFIC GAS AND ELECTRIC COMPANY (U 39-E), AND SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E) NOTICE OF EX PARTE COMMUNICATION Pursuant to California Public Utility Code Rule of Practice and Procedure 8.3(c)(3), Southern California Edison Company (SCE), Pacific Gas and Electric Company (PG&E), and San Diego Gas & Electric Company (SDG&E) (collectively, the Joint Utilities) respectfully submit this notice of written ex parte communication. SDG&E and PG&E have authorized SCE to file this notice on their behalf. On June 16, 2017, SCE submitted the attached comments on behalf of the Joint Utilities 1 pursuant to the June 1, 2017 Request of President Picker for 1 Pursuant to Rule 1.8(d), counsel for PG&E and SDG&E have given counsel for SCE authorization to file this notice on their behalf. 1

3 Informal Comments on the Customer and Retail Choice En Banc and White Paper. The Joint Utilities comments are attached hereto as Attachment A. Respectfully submitted, JANET S. COMBS RUSSELL ARCHER /s/ Russell Archer By: Russell Archer Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) On behalf of SOUTHERN CALIFORNIA EDISON COMPANY, PACIFIC GAS AND ELECTRIC COMPANY, and SAN DIEGO GAS & ELECTRIC COMPANY June 21,

4 Attachment A Joint Utilities Comments on Customer and Retail Choice En Banc

5 Caroline Choi Senior Vice President, Regulatory Affairs June 16, 2017 Suzanne Casazza Energy Division California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA Dear Ms. Casazza: Joint Utilities Comments on May 19, 2017 En Banc Regarding Customer and Retail Choice Southern California Edison Company (SCE), Pacific Gas and Electric Company (PG&E), and San Diego Gas & Electric Company (SDG&E), collectively, the Joint Utilities, respectfully submit these Comments in response to the Public Utilities Commission s (Commission) May 19, 2017 En Banc, The Changing Nature of Consumer and Retail Choice in California. The Joint Utilities appreciate the thoughtful discussion of stakeholders on many important issues at the May 19 En Banc, and thank the Commission for the opportunity to present the Joint Utilities perspective on customer and retail choice. The evolving energy landscape presents many opportunities and challenges. As stakeholders move toward addressing these opportunities and challenges, it is important as a threshold matter, that we ask the right questions. While there are numerous issues that need to be addressed, the Joint Utilities recommend that the Commission prioritize the following five key questions discussed at the En Banc: 1. How should legacy costs be allocated to ensure fairness to both bundled service and departing load customers? 2. What is the most important goal of retail restructuring (e.g., lowest GHG emissions, lowest cost, or highest reliability), and what model or industry structure is best suited to achieve that goal? 3. Within this preferred industry structure, what services are best provided through a regulated utility provider versus competitive providers versus a hybrid approach? 4. Within this preferred industry structure, which market participant(s) should be responsible for constructing or procuring new resources, and for being the Provider of Last Resort? 5. How should utility products and pricing be more readily updated consistent with a vision of greater technology innovation and evolving customer expectations? Of these five key issues, the Joint Utilities cannot underscore enough the importance of first updating the current approach to allocating legacy costs. Whatever path this Commission and California take on retail choice issues, a fundamental predicate is ensuring the statutory mandate of customer indifference. As a matter of law, fairness, regulatory precedent, and public policy, retail choice must be accompanied by mechanisms for equitably and fully allocating the costs and benefits of the Joint Utilities power procurement portfolios between all customers on whose behalf they were procured. The Joint A-1

6 Utilities urge the Commission to act expeditiously to implement the necessary reforms to achieve customer indifference as a result of decisions to depart utility bundled service. Specifically, California Public Utilities Code (P.U. Code) Section requires that the implementation of a community choice aggregation program shall not result in a shifting of costs between the customers of the community choice aggregator and the bundled service customers of an electrical corporation, and that departing load cost recovery mechanisms shall prevent shifting of recoverable costs between customers. 1 Most stakeholders agree that the current methodology the Commission uses to allocate costs to bundled service and departing load customers -- commonly referred to as the Power Charge Indifference Adjustment or PCIA -- is broken. The PCIA is not sustainable, and the Commission s current approach to achieving indifference for customers is in need of fundamental reform, because using administrativelyset benchmarks to approximate market value results in cost shifts between customer groups, in violation of law. Under the PCIA, costs are being shifted to bundled service customers, and those cost shifts will continue to increase as more customers depart bundled service for other providers. The Commission s staff white paper estimates that up to 25% of the Joint Utilities load will depart by the end of 2017, and that departing load may grow to over 85% by It is imperative that the Commission act now to address the need for a scalable, accurate and transparent mechanism to equitably allocate costs of the Joint Utilities portfolios to bundled service and departing load customers. On April 25, 2017, the Joint Utilities filed an Application to completely reform the PCIA. 3 We urge the Commission to act expeditiously to resolve the issues raised in the Application. The Joint Utilities thank the Commission for the continued discussion and appreciate President Picker s request for informal comments to better shape the regulation of California s electric industry. We look forward to working with the Commission and other stakeholders to address critical issues, such as preserving bundled service customer indifference and establishing a well-designed rate structure to ensure that customers are treated fairly and equitably. Respectfully submitted, /s/ Caroline Choi Caroline Choi, on behalf of the Joint Utilities 1 Section (a)(4) and (d)(1). 2 CPUC staff white paper, May Consumer and retail choice, the role of the utility and an evolving regulatory framework, p. 3 3 See A , Application of Southern California Edison Company, Pacific Gas and Electric Company, and San Diego Gas & Electric Company for Approval of the Portfolio Allocation Methodology for all Customers. A- 2

7 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E), Pacific Gas and Electric Company (U 39-E), and San Diego Gas & Electric Company (U 902-E) for Approval of the Portfolio Allocation Methodology for all Customers. A (Filed April 25, 2017) 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 SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), PACIFIC GAS AND ELECTRIC COMPANY (U 39-E), AND SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E) NOTICE OF EX PARTE COMMUNICATION on all parties identified on the attached service list(s) A 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 hand or by overnight courier to the offices of the Commissioner(s) or other addressee(s). ALJ Anne E. Simon CPUC 505 Van Ness Avenue San Francisco, CA Executed on June 21, 2017, at Rosemead, California. /s/ Regina Coburn Regina Coburn Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

8 CPUC - Service Lists - A Page 1 of 6 6/21/2017 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON, PG&E, AND SD FILER: PACIFIC GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: JUNE 19, 2017 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties GARY GERO DANIEL W. DOUGLASS LA COUNTY CSO - SUSTAINABILITY OFFICER COUNTY OF LOS ANGELES DOUGLASS & LIDDELL 500 WEST TEMPLE STREET, ROOM PARK GRANADA, SUITE 209 LOS ANGELES, CA CALABASAS, CA FOR: COUNTY OF LOS ANGELES (L.A. COUNTY) FOR: DIRECT ACCESS CUSTOMER COALITION (DACC) RUSSELL A. ARCHER DONALD C. LIDDELL SR. AT LAW SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVE. / PO BOX ND AVENUE ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: ALLIANCE FOR RETAIL ENERGY MARKETS (AREM) JOHN W. LESLIE, ESQ E. GREGORY BARNES DENTONS US LLP SAN DIEGO GAS & ELECTRIC COMPANY 4655 EXECUTIVE DRIVE, SUITE CENTURY PARK COURT, BLDG 3. CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: SHELL ENERGY NORTH AMERICA (SHELL FOR: SAN DIEGO GAS & ELECTRIC COMPANY ENERGY) CANDACE CHOE CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION MATTHEW FREEDMAN STAFF THE UTILITY REFORM NETWORK

9 CPUC - Service Lists - A Page 2 of 6 6/21/2017 ROOM MARKET STREET, 14TH FL 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK (TURN) FOR: OFFICE OF RATEPAYER ADVOCATES (ORA) EVELYN KAHL MICHAEL ALCANTAR ALCANTAR & KAHL, LLP AT LAW 345 CALIFORNIA ST., STE ALCANTAR & KAHL, LLP SAN FRANCISCO, CA CALIFORNIA STREET, SUITE 2450 FOR: ENERGY USERS AND PRODUCERS SAN FRANCISCO, CA COALITION (EPUC) FOR: COGENERATION ASSOCIATION OF CALIFORNIA (CAC) NORA SHERIFF BRIAN T. CRAGG COUNSEL ALCANTAR & KAHL LLP GOODIN, MACBRIDE, SQUERI & DAY, LLP 345 CALIFORNIA ST., STE SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: INDEPENDENT ENERGY PRODUCERS ASSOCIATION (CLECA) ASSOCIATION (IEP) JEANNE B. ARMSTRONG VIDHYA PRABHAKARAN DAVIS WRIGHT & TREMAINE LLP GOODIN MACBRIDE SQUERI & DAY LLP 505 MONTGOMERY STREET, SUITE SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SOUTH SAN JOAQUIN IRRIGATION FOR: THE SOLAR ENERGY INDUSTRIES DISTRICT (SSJID) ASSOCIATION (SEIA) MICHAEL B. DAY PATRICK FERGUSON GOODIN MACBRIDE SQUERI DAY & LAMPREY LLP DAVIS WRIGHT TREMAINE, LLP 505 SANSOME STREET, SUITE MONTGOMERY ST., STE 800 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: COMMERCIAL ENERGY OF CALIFORNIA FOR: CALPINE CORPORATION (COMMERCIAL ENERGY) CHARLES R. MIDDLEKAUFF MARK BYRON THE REGENTS OF THE UNIV. OF CALIFORNIA PACIFIC GAS AND ELECTRIC COMPANY 1111 BROADWAY, STE BEALE STREET, B30A, PO BOX 7442 OAKLAND, CA SAN FRANCISCO, CA FOR: THE REGENTS OF THE UNIVERSITY OF FOR: PACIFIC GAS AND ELECTRIC COMPANY CALIFORNIA BARBARA HALE STEVEN S. SHUPE PRESIDENT GENERAL COUNSEL CALIFORNIA COMMUNITY CHOICE ASSOCIATION SONOMA CLEAN POWER AUTHORITY 1125 TAMALPAIS AVE. 50 SANTA ROSA AVE., 5TH FL. SAN RAFAEL, CA SANTA ROSA, CA FOR: CALIFORNIA COMMUNITY CHOICE FOR: SONOMA CLEAN POWER AUTHORITY (SCPA) ASSOCIATION (CALCCA) CAROLYN M. KEHREIN CONSULTANT ENERGY MANAGEMENT SERVICES ANN L. TROWBRIDGE AT LAW DAY CARTER & MURPHY, LLP

10 CPUC - Service Lists - A Page 3 of 6 6/21/ CELEBRATION WAY 3620 AMERICAN RIVER DRIVE, SUITE 205 WOODLAND, CA SACRAMENTO, CA FOR: ENERGY USERS FORUM (EUF) FOR: CALIFORNIA CLEAN DG COALITION (CCDC) ANN L. TROWBRIDGE AT LAW DAY CARTER & MURPHY LLP 3620 AMERICAN RIVER DRIVE, STE. 205 SACRAMENTO, CA FOR: MERCED IRRIGATION DISTRICT (MID) AND MODESTO IRRIGATION DISTRICT (MODESTO ID) OR (DISTRICTS) Information Only GREGORY S.G. KLATT JESSICA HILGART AT LAW PACIFIC GAS & ELECTRIC COMPANY DOUGLASS & LIDDELL, CA 00000, CA KEITH WHITE LAURA HUDSON KD WHITE CONSULTING PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA MATT FOGELSON PASCHELLE WHITE PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA MRW & ASSOCIATES LLC DAVIS WRIGHT TREMAINE LLP, CA 00000, CA NANCY RADER BLAKE ELDER EXECUTIVE DIRECTOR CLEAN ENERGY SPECIALIST CALIFORNIA WIND ENERGY ASSOCIATION EQ RESEARCH 401 HARRISON OAKS BLVD., STE. 100, CA CARY, NC JAMES A. ROSS CASE ADMINISTRATION CONSULTANT SOUTHERN CALIFORNIA EDISON COMPANY RCS, INC RUSH STREET 266 PENNINGTON LANE ROSEMEAD, CA CHESTERFIELD, MO FOR: COGENERATION ASSOCIATION OF CALIFORNIA ALVIN S. PAK AT LAW TY TOSDAL TOSDAL LAW FIRM, PC

11 CPUC - Service Lists - A Page 4 of 6 6/21/2017 LAW OFFICES OF ALVIN S. PAK 777 S. HIGHWAY 101, SUITE JENSEN COURT SOLANA BEACH, CA ENCINITAS, CA FOR: CALPINE ENERGY SOLUTIONS, LLC (CALPINE SOLUTIONS) GREG BASS MARCIE MILNER WESTERN REGULATORY AFFAIRS DIR. VP - REGULATORY AFFAIRS CALPINE ENERGY SOLUTIONS, LLC SHELL ENERGY NORTH AMERICA (US), L.P. 401 WEST A STREET, SUITE EASTGATE MALL, SUITE 100 SAN DIEGO, CA SAN DIEGO, CA DESPINA NIEHAUS SUE MARA REGULATORY BUSINESS MGR. CONSULTANT SAN DIEGO GAS & ELECTRIC COMPANY RTO ADVISORS, LLC 8330 CENTURY PARK COURT, CP32D 164 SPRINGDALE WAY SAN DIEGO, CA REDWOOD CITY, CA JOSEPH F. WIEDMAN JEANNE M. SOLE SR. REGULATORY & LEGISLATIVE ANALYST DEPUTY CITY PENINSULA CLEAN ENERGY AUTHORITY CITY AND COUNTY OF SAN FRANCISCO 400 COUNTY CENTER, SIXTH FL. 1 DR. CARLTON B. GOODLETT PLACE, RM. 234 REDWOOD CITY, CA SAN FRANCISCO, CA CASE COORDINATION MEGAN SOMOGYI PACIFIC GAS AND ELECTRIC COMPANY GOODIN, MACBRIDE, SQUERI, & DAY, LLP, CA SANSOME ST., STE. 900 SAN FRANCISCO, CA DIANE FELLMAN AVIS KOWALEWSKI VP - REGULATORY & GOVERNMENT AFFAIRS VP - GOV'T & REGULATORY AFFAIRS NRG WEST REGION CALPINE CORPORATION 100 CALIFORNIA ST., STE DUBLIN BLVD, SUITE 100 SAN FRANCISCO, CA DUBLIN, CA MATTHEW BARMACK CYNTHIA CLARK DIR. - MARKET & REGULATORY ANALYSIS RENEWABLE ENERGY MGR. CALPINE CORPORATION UNIVERSITY OF CALIFORNIA 4160 DUBLIN BLVD., SUITE BROADWAY STE DUBLIN, CA OAKLAND, CA FOR: THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, OFFICE OF THE PRESIDENT MARK BYRON BARBARA R. BARKOVICH WHOLESALE ELECTRICITY PROGRAM MGR. CONSULTANT UNIV. OF CALIF. OFFICE OF THE PRESIDENT BARKOVICH & YAP, INC FRANKLIN ST., 6TH FL. PO BOX OAKLAND, CA OAKLAND, CA TIM LINDL C. C. SONG COUNSEL REGULATORY ANALYST KEYES & FOX LLP MARIN CLEAN ENERGY TH STREET, STE TAMALPAIS AVE.

12 CPUC - Service Lists - A Page 5 of 6 6/21/2017 OAKLAND, CA SAN RAFAEL, CA SHALINI SWAROOP MARIN CLEAN ENERGY REGULATORY & LEGISLATIVE COUNSEL MCE REGULATORY MARIN CLEAN ENERGY 1125 TAMALPAIS AVENUE 1125 TAMALPAIS AVENUE SAN RAFAEL, CA SAN RAFAEL, CA PHILLIP MULLER JOHN NIMMONS PRESIDENT COUNSEL SCD ENERGY SOLUTIONS JOHN NIMMONS & ASSOCIATES, INC. 436 NOVA ALBION WAY 175 ELINOR AVE., STE. G SAN RAFAEL, CA MILL VALLEY, CA KEVIN WOODRUFF LAURA TAYLOR WOODRUFF EXPERT SERVICES TH STREET, SUITE 514 BRAUN BLAISING SMITH WYNNE, P.C. SACRAMENTO, CA L STREET, STE SACRAMENTO, CA REGULATORY CLERK SCOTT BLAISING BRAUN BLAISING SMITH WYNNE 915 L STREET, STE BRAUN BLAISING SMITH WYNNE, PC SACRAMENTO, CA L STREET, STE SACRAMENTO, CA STEVEN KELLY LYNN HAUG POLICY DIRECTOR INDEPENDENT ENERGY PRODUCERS ASSCIATION ELLISON SCHNEIDER HARRIS & DONLAN LLP 1215 K STREET, STE CAPITOL AVE., STE. 400 SACRAMENTO, CA SACRAMENTO, CA ANDREW B. BROWN BRIAN STEVENS AT LAW STRATEGIC BUSINESS PLANNER ELLISON SCHNEIDER HARRIS & DONLAN LLP SMUD 2600 CAPITAL AVENUE, SUITE S STREET, MS MD-2 SACRAMENTO, CA SACRAMENTO, CA RALPH R. NEVIS DONALD BROOKHYSER DAY CARTER & MURPHY LLP COUNSEL 3620 AMERICAN RIVER DRIVE, STE. 205 ALCANTAR & KAHL SACRAMENTO, CA S.W. SALMON ST., STE PORTLAND, OR MIKE CADE INDUSTRY SPECIALIST ALCANTAR & KAHL 121 SW SALMON STREET, SUITE 1100 PORTLAND, OR State Service

13 CPUC - Service Lists - A Page 6 of 6 6/21/2017 ANNE E. SIMON MEA HALPERIN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PLANNING & POLICY BRANCH ROOM 5104 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA MITCHELL SHAPSON SCARLETT LIANG-UEJIO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION MARKET STRUCTURE, COSTS AND NATURAL GAS ROOM 5129 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA SUZANNE CASAZZA CALIF PUBLIC UTILITIES COMMISSION MARKET STRUCTURE, COSTS AND NATURAL GAS AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS