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 2018-2020 Electric Program Investment Charge Investment Plan A.17-04-028 (Filed April 28, 2017) And Consolidated Matters. A.17-05-003 A.17-05-005 A.17-05-009 REPLY 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 FADIA RAFEEDIE KHOURY KRIS G. VYAS Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6613 Facsimile: (626) 302-6997 E-mail: kris.vyas@sce.com Dated: October 8, 2018
REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) Section TABLE OF CONTENTS Page I. II. III. IV. INTRODUCTION...1 SCE IS IN COMPLIANCE WITH THE REQUIREMENTS FOR EPIC...2 SCE SUPPORTS AND RECOMMMENDS A WORKSHOP TO INCREASE UTILITY MATCH-FUNDING OPPORTUNITIES...3 CONCLUSION...3 i
REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U-338-E) Authority TABLE OF AUTHORITIES Page CPUC Decisions D.12-05-037... 2 CPUC Rules of Practice and Procedure Rule 14.3... 1 ii
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 2018-2020 Electric Program Investment Charge Investment Plan A.17-04-028 (Filed April 28, 2017) And Consolidated Matters. A.17-05-003 A.17-05-005 A.17-05-009 REPLY 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 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 reply 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 1
Investment Plans for the Electric Program Investment Charge (EPIC) Program for the Years 2018 Through 2020. SCE s reply comments address issues raised by the Public Advocates Office. 1 II. SCE IS IN COMPLIANCE WITH THE REQUIREMENTS FOR EPIC The Public Advocates Office is simply mistaken in its attempts to conflate grid demonstrations and pilots. Across two proceedings, 2 SCE has consistently shown that there is a difference between EPIC-funded Technology Demonstration and Deployment (TD&D) projects and General Rate Case (GRC)-funded pilots. In the Commission s decision establishing the EPIC Program, the EPIC investment categories correspond to the four stages in the product development cycle. The Commission determined the Utilities should only fund EPIC TD&D projects to provide support through the valley of death as the technology moves toward commercialization. More specifically, the staff proposal defines EPIC TD&D projects as: The installation and operation of pre-commercial technologies at a scale sufficiently large and in conditions sufficiently reflective of anticipated actual operating environments, to enable the financial community to effectively appraise the operational and performance characteristics of a given technology and the financial risks it presents. 3 GRC-funded pilots occur post-demonstration and prior to broad deployment of commercially available technologies. These pilots are fundamentally different than EPIC TD&D projects. The pilots occur at a post-demonstration stage and the pilots aim to: Validate the extent to which technology may be applicable and operationally feasible across the utility s service territory; and Develop design standards and operating policies and procedures that are absolutely critical to help ensure that broad deployment occurs in a safe and reliable manner. 4 1 Formerly known as the Office of Ratepayer Advocates. 2 Application (A.)17-05-005 and A.16-09-001. 3 D.12-05-037, at p. 39 (emphasis added). 4 See A.16-09-001, SCE 2018 GRC, SCE s Reply Brief at p. 40; Exhibit SCE-18, Vol. 11, at pp. 11-14. 2
GRC-funded pilots use technology that has moved beyond the TD&D stage; and commercially available technology by definition is not eligible for EPIC. III. SCE SUPPORTS AND RECOMMENDS A WORKSHOP TO INCREASE UTILITY MATCH- FUNDING OPPORTUNITIES The Public Advocates Office wishes to retain a Tier 3 advice letter review process for proposals between triennial review cycles. 5 SCE continues to advocate for an adaptable program that can more quickly respond to shifts in energy policy and advances in technology developments. Therefore, SCE supports the Commission s decision to establish the Policy Innovation + Coordination Group (PICG). The PICG has the potential to improve how transparent and flexible the EPIC Program can be. While the PICG and Tier 3 review process could be a potentially efficient process for requesting new projects, a more dynamic process is needed to leverage match-funding opportunities. SCE agrees with the CEC that match funding is an integral component for EPIC TD&D projects. 6 SCE suggests that the Commission convene a PICG workshop that focuses on further improving and leveraging utility costshare opportunities for EPIC TD&D projects, so that we can maximize the benefits that customers receive when such TD&D projects are funded. IV. CONCLUSION SCE appreciates the opportunity to reply to the Public Advocates Office s opening comments. SCE respectfully requests that the Commission decline to follow the Public Advocates Office s proposed modifications to the PD, and move forward with approving the utilities respective 2018-2020 EPIC Investment Plans. 5 Public Advocates Office Opening Comments, at p. 9. 6 CEC Comments at pp. 11-12 (discussing that match funding is an integral component in other government programs besides EPIC). 3
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 91770 Telephone: (626) 302-6613 Facsimile: (626) 302-6997 E-mail: kris.vyas@sce.com October 8, 2018 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 2018-2020 Electric Program Investment Charge Investment Plan. A.17-04-028 (Filed April 28, 2017) And Consolidated Matters. A.17-05-003 A.17-05-005 A.17-05-009 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 REPLY 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.17-04-028 et al. Service was effected by one or more means indicated below: Transmitting the copies via e-mail to all parties who have provided an e-mail 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 94102 Executed October 8, 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
CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 1 of 5 10/8/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A1704028 - PG&E - FOR APPROVAL FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: OCTOBER 5, 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 00000 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 800 2159 INDIA STREET ROSEMEAD, CA 91770 SAN DIEGO, CA 92101 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 5307 SAN DIEGO, CA 92123 505 VAN NESS AVENUE FOR: SAN DIEGO GAS & ELECTRIC COMPANY SAN FRANCISCO, CA 94102-3214 FOR: ORA CHRISTOPHER J. WARNER MARK MILES ATTORNEY CEO PACIFIC GAS AND ELECTRIC COMPANY MARK CONSULTING, INC. 77 BEALE STREET / PO BOX 7442 1200 LAKESHORE AVENUE, SUITE 25A SAN FRANCISCO, CA 94120 OAKLAND, CA 94606
CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 2 of 5 10/8/2018 FOR: PACIFIC GAS AND ELECTRIC COMPANY 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 436 14TH STREET, SUITE 1220 OAKLAND, CA 94610 OAKLAND, CA 94612 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 94720 BERKELEY, CA 94720 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 2 254 E. HACIENDA AVENUE RICHMOND, CA 94804 CAMPBELL, CA 95008 FOR: CALIFORNIA ENVIRONMENTAL JUSTICE FOR: CHARGEPOINT, INC. ALLIANCE (CEJA) ALLAN L. WARD, II CHIEF COUNSELS OFFICE 1516 9TH STREET, MS 14 SACRAMENTO, CA 95814 FOR: CALIFORNIA ENERGY RESOURCES CONSERVATION AND DEVELOPMENT COMMISSION Information Only AARON RENFRO SOUTHERN CALIFORNA EDISON, CA 00000 BONNIE DATTA SR. DIR - AMERICAS & ASIA PACIFIC SIEMENS, CA 00000 ISAAC SEVIER JOHN MINNICUCCI NATURAL RESOURCES DEFENSE COUNCIL SOUTHERN CALIFORNIA EDISON, CA 00000, CA 00000 KENT THOMSON LESLIE ALMOND SOUTHERN CALIFORNIA EDISON PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA 00000 PAMELA DOUGHMAN MRW & ASSOCIATES LLC
CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 3 of 5 10/8/2018 CALIF. ENERGY COMMISSION, CA 00000, CA 00000 JONATHAN LAKEY DANIEL DOUGLASS ATTORNEY PROCUREMENT STRATEGY AND OVERSIGHT BRANC DOUGLASS & LIDDELL 320 West 4th Street Suite 500 4766 PARK GRANADA, SUITE 209 Los Angeles, CA 90013 CALABASAS, CA 91302 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 91770 2244 WALNUT GROVE AVE. / PO BOX 800 ROSEMEAD, CA 91770 ANNLYN FAUSTINO CHRISTA LIM REGULATORY & COMPLIANCE REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92123 SAN DIEGO, CA 92123 DEAN A. KINPORTS CENTRAL FILES REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA 92123-1530 SAN DIEGO, CA 92123 BRENT COLASURDO JULIE CERIO UMBERG ZIPSER LLP PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE ST., RM. 2388B, CA 92614 SAN FRANCISCO, CA 94104 LARA ETTENSON DANIEL OHLENDORF DIR - CA EE POLICY PACIFIC GAS AND ELECTRIC COMPANY NATURAL RESOURCES DEFENSE COUNCIL 77 BEALE STREET, ROOM 2388B 111 SUTTER ST., 21ST FL. SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94104 GREG STEWART GEORGE ZAHARIUDAKIS PACIFIC GAS AND ELECTRIC COMPANY RESOURCE / ENTEGRATED PLANNING 77 BEALE STREET, ROOM 2388B PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94105 77 BEALE STREET, RM 2388B SAN FRANCISCO, CA 94105-0001 FRANCESCA WAHL DEBORAH BEHLES SR. POLICY ASSOCIATE, BUS. DEVELOPMENT OF COUNSEL TESLA, INC. CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANC 444 DE HARO STREET, STE. 101 SAN FRANCISCO, CA 94107, CA 94131 FOR: CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANCE (CEJA)
CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 4 of 5 10/8/2018 CASE ADMINISTRATION CHRIS KING PACIFIC GAS AND ELECTRIC COMPANY GLOBAL CHIEF REGULATORY OFFICER SIEMENS SMART GIRD SOLUTIONS, CA 94177 4000 E 3RD AVE., STE. 400 FOSTER CITY, CA 94404 ROGER LIN RENEE SAMSON CENTER ON RACE POVERTY & THE ENVIRONMENT DIR - UTILITY SOLUTIONS 1999 HARRISON STREET, STE. 650 CHARGEPOINT, INC. OAKLAND, CA 94612 245 HACIENDA AVENUE FOR: CALIFORNIA ENVIRONMENTAL JUSTICE CAMPBELL, CA 95008 ALLIANCE CHERYL COX GABRIEL HERRERA, ESQ. OFFICE OF CHIEF COUNSEL PROCUREMENT STRATEGY AND OVERSIGHT BRANC 300 Capitol Mall 1516 NINTH STREET, MS 14 Sacramento, CA 95814 SACRAMENTO, CA 95814-5512 FOR: LYNN HAUG ANDREW B. BROWN ATTORNEY ATTORNEY AT LAW ELLISON SCHNEIDER HARRIS & DONLAN LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVE., STE. 400 2600 CAPITAL AVENUE, SUITE 400 SACRAMENTO, CA 95816 SACRAMENTO, CA 95816-5905 State Service MARIA SOTERO CHRISTOPHER MYERS REGULATORY ANALYST-ENERGY DIVISION CALIFORNIA PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH ROOM 4104, CA 00000 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 JOANNA GUBMAN KARIN M. HIETA COMMISSIONER RANDOLPH ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 5010 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 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 94102-3214 SAN FRANCISCO, CA 94102-3214 DAVID X. HUANG SARA KIM STAFF ATTORNEY PROCUREMENT STRATEGY AND OVERSIGHT BRANC 300 Capitol Mall 1516 NINTH STREET, MS-14
CPUC - Service Lists - A1704028 https://ia.cpuc.ca.gov/servicelists/a1704028_84365.htm Page 5 of 5 10/8/2018 Sacramento, CA 95814 SACRAMENTO, CA 95814 ANTHONY NG DORIS YAMAMOTO 1516 NINTH STREET, MS 51 1516 NINTH STREET, MS 51 SACRAMENTO, CA 95814-5512 SACRAMENTO, CA 95814-5512 ERIK STOKES LAURIE TENHOPE 1516 NINTH STREET, MS 43 1516 NINTH STREET, MS 51 SACRAMENTO, CA 95814-5512 SACRAMENTO, CA 95814-5512 LINDA SPIEGEL MARK KOOTSTRA 1516 NINTH STREET, MS 51 1516 NINTH STREET, MS 51 SACRAMENTO, CA 95814-5512 SACRAMENTO, CA 95814-5512 MIKHAIL HARAMATI WILLIAM DIETRICH SUPERVISOR, BLDG ENERGY EFFICIENCY SR. ATTY - CHIEF COUNSEL'S OFFICE 1500 5TH STREET 1516 NINTH STREET, MS-14 SACRAMENTO, CA 95814-5512 SACRAMENTO, CA 95814-5512 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS