Upload
others
View
0
Download
0
Embed Size (px)
Citation preview
1814184
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Order Instituting Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term Procurement Plans.
)))
Rulemaking 10-05-006
OPENING BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON TRACK II
MICHAEL D. MONTOYA CAROL A. SCHMID-FRAZEE MELISSA HOVSEPIAN
Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1337 Facsimile: (626) 302-1935 E-mail:Carol [email protected]
Dated: June 17, 2011
Opening Brief Of Southern California Edison Company (U 338-E) on Track II TABLE OF CONTENTS
Section Page
-i-
I. EXECUTIVE SUMMARY ......................................................................................................................1
II. THE COMMISSION SHOULD ADOPT SCE’S PROPOSED AB 57 BUNDLED PP WITHOUT MODIFICATION...............................................................................5
A. There Was No Opposition To Most Elements of the AB 57 Bundled PP...........................................................................................................................5
1. SCE’s AB 57 Bundled PP Is In Compliance With the Preferred Loading Order ..........................................................................................6
2. DRA’s Concerns Regarding SCE’s Natural Gas Hedging Activities Are Misguided As They Are Designed To Cost-Effectively Reduce Customer Price Risk.................................................................8
B. The Commission Should Adopt SCE’s Unopposed Request To Contract For A Term Of Five Years Or Less ....................................................................10
C. The Commission Should Adopt SCE’s Unopposed Change To Its Congestion Revenue Rights (CRRs) Procurement Plan ....................................................10
D. The Commission Should Adopt SCE’s Unopposed Additional Non-Standard Products ......................................................................................................11
E. The Commission Should Adopt SCE’s Unopposed Changes To Its Authorized Brokers And Exchanges Table........................................................................11
III. THE COMMISSION SHOULD ADOPT SCE’S REMAINING PROPOSED CHANGES TO THE 2006 LTPP PROCUREMENT PLAN........................................................12
A. The Commission Should Adopt SCE’s New Hedging Proposals......................................12
1. SCE’s Proposed CRT Appropriately Changes As Customer Rates Change .........................................................................................................12
2. The Commission Should Adopt SCE’s Proposed Procurement Limits and Ratable Rates Without Any Further Limitations ................................................................................................13
B. The Commission Should Adopt SCE’s New Renewable Procurement Proposals and Corresponding Renewables Products....................................15
Opening Brief Of Southern California Edison Company (U 338-E) on Track II
TABLE OF CONTENTS (CONTINUED)
Section Page
-ii-
1. SCE’s Proposed Short-Term Renewable Procurement Authority Is An Appropriate Mechanism To Assist In Meeting The State’s Renewable Energy Goals .....................................................15
2. The Commission Should Adopt SCE’s Proposed Renewable Integration Products ............................................................................18
3. SCE’s Proposed Fixed Price For Short Run Avoided Cost Floating Swap Is Necessary And Appropriate.......................................................19
C. The Commission Should Adopt SCE’s Proposals For Modification Of Convergence Bidding ...................................................................................................20
1. Track II Of The LTPP Is The Appropriate Forum For Considering Changes To Convergence Bidding....................................................20
2. SCE’s Proposed Revisions To Its Convergence Bidding Have Sufficient Protections For Bundled Customers ............................................21
IV. THE COMMISSION SHOULD ADOPT SCE’S PREFERRED PLANNING ANALYSIS FOR PURPOSES OF SETTING PROCUREMENT LIMITS .................................23
A. For the Most Part, SCE Used CPUC Standardized Planning Assumptions And Methodology ........................................................................................24
B. To The Extent That SCE’s Preferred Assumptions Deviated From the CPUC Standardized Planning Assumptions, SCE’s Preferred Assumptions Were More Reasonable Than The CPUC Standardized Planning Assumptions For Purposes Of Establishing SCE’s Position Limits For Forward Procurement Activity ...............................................26
1. SCE Used Appropriate Assumptions About the Demand Forecast ..................................................................................................................26
a) SCE Fully Supported Its EE Assumption ..................................................26
(1) SCE Preferred Assumptions Are Consistent With Commission Decisions and A CEC Forecast That Will Require An Aggressive Approach........................................................................................27
(2) SCE Preferred Assumptions Appropriately Implicitly Include Energy Savings From Building Codes and Appliance Standards......................................28
Opening Brief Of Southern California Edison Company (U 338-E) on Track II
TABLE OF CONTENTS (CONTINUED)
Section Page
-iii-
b) SCE Used Appropriate DR Assumptions ..................................................29
2. SCE Used Appropriate Assumptions About DA...................................................30
3. SCE Used Appropriate Flexible Compliance Assumptions for Renewables.......................................................................................................31
a) Passage Of Recently Enacted SB x 1 2 Does Not Call Into Question The Use of Flexible Compliance for Renewables In SCE’s Preferred Analysis ............................................32
b) SCE Used Appropriate RES Compliance Assumptions...............................................................................................33
C. SCE Used Appropriate CHP Assumptions ........................................................................33
D. The GHG Emissions Results In SCE’s Preferred Analysis Are Appropriate ........................................................................................................................35
V. CONCLUSION.....................................................................................................................................36
APPENDIX A............................................................................................................................................37
Opening Brief Of Southern California Edison Company (U 338-E) on Track II
TABLE OF AUTHORITIES
Title Page
-i-
California Statutes California Public Utilities Code
§365.1(b)......................................................................................................................30
§399.11(a) ....................................................................................................................15
§454.4...........................................................................................................................17
§454.5.........................................................................................................................1, 6
§454.5 (b)(7) ..................................................................................................................2
Health & Safety Code §38500............................................................................................................................2
California Public Utilities Commission Decisions D.07-09-040.................................................................................................................19
D.07-12-052...................................................................................................................2
D.08-07-047...........................................................................................................26, 27
D.10-03-022...........................................................................................................30, 31
D.10-12-034.................................................................................................4, 20, 21, 22
D.10-12-035.....................................................................................................19, 33, 34
D.11-03-051...........................................................................................................19, 34
California Public Utilities Commission Rulemaking R.10-05-006 ...............................................................................................................1, 6
R.08-08-009 .................................................................................................................32
California Public Utilities Commission Rules and Procedures
Rule 13.11 ......................................................................................................................1
California Legislation AB 32 .................................................................................................................2, 6, 7, 9
AB 57 .............................................................................................................................1
SB x 1 2............................................................................................................15, 18, 32
SB 695..........................................................................................................................30
Opening Brief Of Southern California Edison Company (U 338-E) on Track II
LIST OF TABLES
Table Page
-ii-
Table III-1 Key Input Assumptions .......................................................................................................... 25 1
1815184 - 1 -
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Order Instituting Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term Procurement Plans.
)))
Rulemaking 10-05-006
OPENING BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON TRACK II
I.
EXECUTIVE SUMMARY
Pursuant to Rule 13.11 of the California Public Utilities Commission’s (Commission or
CPUC) Rules of Practice and Procedure and the Administrative Law Judge’s Ruling, dated
February 18, 2011, Southern California Edison Company (SCE) hereby submits its Opening
Brief on Track II of the 2010 Long Term Procurement Plan (LTPP) proceeding. The purpose of
Track II of the 2010 LTPP is for the Commission to consider individual investor-owned utility
(IOU) procurement plans for their bundled customers, as required by Assembly Bill (AB) 57
which is codified at Public Utilities Code Section 454.5.1 In this Track II of the 2010 LTPP,
SCE presents in Exhibits 200, 201, and 201-C its proposed AB 57 Bundled Procurement Plan
(AB 57 Bundled PP). The Commission should adopt SCE’s proposed AB 57 Bundled PP
without modification.
1 Rulemaking (R.) 10-05-006, Assigned Commissioner and Administrative Law Judge’s Joint Scoping Memo and Ruling, dated December 3, 2010 (December 3, 2010 Scoping Memo), pp.39-40.
1815184 - 2 -
There was no opposition to most elements of SCE’s proposed AB 57 Bundled PP,
including the proposed changes from SCE’s 2006 Conformed LTPP. Parties’ concerns with
SCE’s AB 57 Bundled PP were generally, but not completely, limited to SCE’s compliance with
the Preferred Loading Order2 and AB 32,3 and with SCE’s natural gas hedging plan.
The first concern regarding the Preferred Loading Order and AB 32 is unwarranted, as
SCE clearly documented its adherence to the Preferred Loading Order throughout its AB 57
Bundled PP.4 Additionally, in other procurement-related proceedings and venues, the
Commission addresses the objectives and procurement requirements for preferred resources.
SCE fully complies with all procurement requirements in those proceedings before considering
its potential residual energy requirement in this forum through its AB 57 Bundled PP. The focus
of an AB 57 procurement plan is the establishment of “[t]he upfront standards and criteria by
which the acceptability and eligibility for rate recovery of a proposed procurement transaction
will be known by the electrical corporation prior to execution of the transaction.”5 SCE’s
proposed AB 57 Bundled PP appropriately focuses on this issue, while demonstrating full
adherence to the Preferred Loading Order. Moreover, SCE’s AB 57 Bundled PP is committed to
not only meeting renewable energy goals set by the Commission and the legislature, but also
proposes new renewable procurement methods and products so that SCE can enhance its means
of procuring preferred resources that reduce greenhouse gas (GHG) emissions.
As for SCE’s natural gas hedging plan, it is unchanged from the 2006 Conformed LTPP
adopted in D.07-12-052, except that SCE proposes to calculate ratable rates on a rolling 12-
month basis instead of the current monthly approach. Natural gas is the single largest market-
sensitive exposure SCE’s customers currently face.6 SCE has appropriately used and proposes to
continue appropriately using financial gas hedging to manage its customers’ market price risk
2 Energy Action Plan II, http://cpuc.ca.gov/published/report/51604.html. 3 Health and Safety Code, §38500 et al. 4 SCE, Exhibit 207, pp.4-6. 5 Pub. Util. Code § 454.5(b)(7). 6 SCE, Exhibit 207, p.11.
1815184 - 3 -
exposure.7 The purpose of a hedge is to reduce customer exposure to market price fluctuations.
These natural gas hedges act as an insurance policy to avoid higher future natural gas prices.8 If
those prices do not materialize, the hedges, like an insurance policy, will still have mitigated
customer price risk.9 DRA’s generalized concerns about SCE’s natural gas hedging activities do
not take a long-term perspective on the value of a hedge program for bundled customers,10 and
should be rejected.
As for SCE’s proposed changes to its 2006 Conformed LTPP authority, there was no
opposition to many of the changes, including:
• SCE’s change to allow contracts for a term of five years or less, instead of less than 5 years;
• SCE’s change to its Congestion Revenue Rights (CRRs) Procurement Plan to limit its monthly reporting requirement to a single month-end report;
• Addition of certain items on SCE’s list of additional non-standard products, including electricity transmission products for non-California Independent System Operator (CAISO) transmission and sales of forward energy from resources located outside the CAISO; and
• SCE’s changes to its authorized brokers and exchanges table to remove the column “Products Traded and/or Information Provided” allowing SCE to transact any product on its list of authorized procurement products through any broker or exchange on its list of authorized brokers and exchanges.
The Commission should adopt these unopposed changes to SCE’s 2006 Conformed LTPP
without modification.
SCE’s AB 57 Bundled PP also contained a few changes to its 2006 Conformed LTPP that
were opposed. The Commission should reject the opposition to these important proposals and
adopt SCE’s AB 57 Bundled PP without change as summarized below:
• SCE’s proposed Customer Risk Tolerance (CRT) methodology appropriately changes as customer rates change, but provide a more stable approach than DRA’s proposed indexed CRT.
7 Id. 8 Id. at p.12. 9 Id. 10 DRA, Exhibit 400, pp.24-25.
1815184 - 4 -
• SCE’s proposed changes to the 2006 Conformed LTPP’s electric capacity procurement limits and ratable rates to eliminate load forecast error and generation outage contingencies and the three-times ratable rate design from its ratable rate procurement limit methodology are more restrictive on SCE’s hedging activities, but still allow sufficient hedging.
• SCE’s proposed short-term renewable procurement authority, including its proposed Forward Renewable Energy/Renewable Energy Credits (REC) products, appropriately assists in meeting the State’s renewable energy goals using methods allowed for conventional resources.
• SCE’s proposed renewable integration products assist in cost-effectively meeting the State’s renewable energy goals by clearly allowing SCE to enter into transactions to manage the delivery of intermittent Preferred Loading Order resources.
• SCE’s proposed fixed price for Short Run Avoided Cost (SRAC) floating swap is an appropriate addition to SCE’s natural gas hedge toolset. SRAC prices are based on natural gas prices and therefore fluctuate with natural gas prices. Substituting a fixed price for an SRAC price appropriately hedges customers’ exposure to natural gas price fluctuations.
• SCE’s proposals to modify convergence bidding are timely. These proposals limit customer exposure by retaining the existing Commission-imposed protections in Decision (D.) 10-12-034, including the $20 million stop-loss limit, but allow SCE to pursue additional convergence bidding strategies that will benefit its bundled customers.
The Commission should adopt these changes without modification.
Finally, SCE requests that the Commission adopt its proposed position and ratable rates,
which were based on SCE’s Preferred Assumptions. SCE’s position limits serve as maximum
limits on SCE’s procurement of resources after accounting for SCE’s existing and planned
Preferred Loading Order resources and utility-owned generation. Because SCE’s position limits
provide an upper-bound on SCE’s residual procurement authority, SCE used planning
assumptions that were not as optimistic and aggressive as the CPUC’s Standardized Planning
Assumptions, as the CPUC’s Standardize Planning Assumptions would yield procurement
position limits that significantly limit SCE’s forward procurement activity. For the purpose of
establishing position limits, it is not reasonable to use the most aggressive and optimistic
assumptions on Preferred Loading Order resources, because “failure to realize those assumptions
1815184 - 5 -
could result in a costly procurement deficiency.”11 However, SCE actively considers the status
of all Preferred Loading Order resources before committing to conventional resources. The
adoption of SCE’s Preferred Assumptions to establish SCE’s position limits has no bearing or
relevancy to the Commission’s consideration of planning assumptions in Track I. The Track I
analysis looks at all three utilities’ service areas as one and determines what new generation
resources need to be built to meet system-wide need and assesses the impact of various
procurement-related policies.12 The Track I analysis is not dependent on SCE’s Track II
preferred planning assumptions, which are only used to establish SCE’s position limits and
resulting ratable rates.
II.
THE COMMISSION SHOULD ADOPT SCE’S PROPOSED AB 57 BUNDLED PP
WITHOUT MODIFICATION
A. There Was No Opposition To Most Elements of the AB 57 Bundled PP
With the exception of a very narrow set of issues, the vast majority of SCE’s AB 57
Bundled PP was not opposed by parties. SCE’s proposed AB 57 Bundled PP contains only a few
elements that were modified from the 2006 Conformed LTPP. Within SCE’s limited set of
changes, only a few were contested, as further discussed in Section III below. The rest of the
proposed changes were unopposed, as described further in this section below. Additionally,
there were two concerns raised by DRA and a few other parties related to SCE’s compliance
with the Preferred Loading Order and SCE’s natural gas hedging activities that appear to be the
result of a fundamental misunderstanding of the purpose of SCE’s AB 57 Bundled PP and
hedging activities. As such, these concerns are unwarranted and should be disregarded by the
Commission, as SCE explains immediately below.
11 SCE, Exhibit 207, p.7, line 12. 12 December 3, 2010 Scoping Memo, p.3.
1815184 - 6 -
1. SCE’s AB 57 Bundled PP Is In Compliance With the Preferred Loading
Order
Several parties, DRA in particular, indicated concern that SCE’s AB 57 Bundled PP is
not consistent with the State’s Preferred Loading Order and AB 32,13 but these concerns appear
to be based on a fundamental misunderstanding of the purpose of SCE’s AB 57 Bundled PP. As
required by AB 57, SCE’s AB 57 Bundled PP sets forth the upfront, achievable standards and
criteria by which SCE’s procurement activity will be deemed per se reasonable and therefore
eligible for cost recovery.14 In this Track II LTPP proceeding, the Commission directed the
parties not to litigate the objectives and procurement requirements of preferred resources that are
already addressed in separate proceedings.15 Therefore, SCE’s AB 57 Bundled PP addresses the
procurement required to serve the residual energy requirements of SCE’s bundled customers,
after first fully accounting for all of SCE’s committed and forecasted preferred resources (i.e.,
Energy Efficiency (EE), Demand Response (DR), renewables, Qualifying Facility (QF)
contracts, Combined Heat and Power (CHP), and Distributed Generation (DG)) and utility-
owned generation (UOG).16 SCE fully considers all cost-effective preferred resources before
committing to conventional resources. Indeed, SCE’s residual procurement is open to all
resource technologies that can meet SCE’s procurement requirements, including preferred
resources. SCE provided a comprehensive description of its adherence to the Preferred Loading
Order in its AB 57 Bundled PP.17
Additionally, to facilitate the procurement of preferred resources, as explained in Section
III below, SCE has proposed to expand its Renewables Portfolio Standard (RPS) procurement
capabilities to allow short-term RPS procurement pursuant to its AB 57 procurement plan.
13 DRA, Exhibit 400, pp.12-19; CBE, Exhibit 1000, p.7; and WEM, Exhibit 800, pp.16-21. 14 Cal. Pub. Util. Code § 454.5. 15 See, e.g., R.10-05-006, Order Instituting Rulemaking, dated May 12, 2010, p.12 n.22; see also Administrative
Law Judge’s Ruling on Resource Planned Assumptions – Part 3 (Energy Efficiency) – Track I, dated June 22, 2010, p.4.
16 SCE, Exhibit 207, pp.4-5. 17 See SCE, Exhibit 207, pp.4-6, for a summary.
1815184 - 7 -
SCE’s proposal would allow for the increased flexibility to procure products consistent with the
Preferred Loading Order and GHG emissions reduction policies. However, DRA opposed this
proposal even though it would address DRA’s concern that SCE should do more to incorporate
the Preferred Loading Order in SCE’s AB 57 procurement activity.
Since SCE’s resource acquisition strategy prioritizes preferred resources that reduce
GHG emissions from SCE’s bundled customer portfolio, SCE’s AB 57 Bundled PP is also
consistent with the GHG reduction goals of AB 32.18 Indeed, SCE has already reduced its GHG
emissions to below its 1990 levels and forecasts to have an average GHG emission rate of less
than 500 lbs./MWh by 201519 due to SCE’s early GHG-reducing actions20 and SCE’s
compliance with the Preferred Loading Order. Moreover, SCE accounts for the GHG emissions
reduction benefits prior to selecting supply offers in its competitive procurement processes.
SCE thus fully complies with the Preferred Loading Order and AB 32 by accounting for
preferred resources in its procurement planning and transaction activity covered by SCE’s
proposed transaction position limits and ratable rates.21 As a result, the Commission should
approve SCE’s AB 57 Bundled PP without modification. Parties’ specific concerns regarding
procurement of preferred resources should be addressed in the proceedings dealing with such
preferred resources.22
18 Id. at p.6. 19 SCE, Exhibit 203-C, Figure A-11, p. A-11. 20 For example, the closure of the coal-burning Mohave Generation Station on December 31, 2005, and the
announced sale of SCE’s ownership rights to the coal-burning Four Corner Generation Station in late 2012. 21 SCE addresses its commitment and compliance with the Preferred Loading Order throughout its 2010 AB 57
Bundled PP. See, e.g., SCE, Exhibit 200, pp.7-8, pp.10-15, and pp.57-61; SCE, Exhibit 202, pp.14-27. 22 SCE, Exhibit 207, p.4.
1815184 - 8 -
2. DRA’s Concerns Regarding SCE’s Natural Gas Hedging Activities Are
Misguided As They Are Designed To Cost-Effectively Reduce Customer
Price Risk
DRA’s testimony23 raises concerns about the IOUs “over hedging” arguing that it is too
expensive relative to its benefits (reduced price volatility) to customers. Based on DRA’s
testimony, SCE assumes DRA is primarily concerned with the IOUs’ financial natural gas
hedging activities. Although financial natural gas hedging is just one component of a large
hedging program (i.e., essentially of SCE’s procurement activities), it is a valuable tool to
mitigate rate volatility. This is because natural gas is the single largest market-sensitive cost
exposure SCE’s customers face and as a most mature and liquid commodity market in which
SCE transacts, the natural gas market offers the most competitive hedging options.24
DRA’s conclusions are based on the 20-20 hindsight of the actual hedging results. These,
of course, cannot be known at the time the hedges were executed.25 Since hedges are akin to
insurance policies, the fact that the hedged risk did not occur (i.e., higher natural gas prices did
not result) does not mean that such hedges were not prudent and cost effective at the time they
were placed. As SCE has repeatedly communicated, SCE hedges a limited portion of its
customers’ future natural gas price exposure, on a regular basis, and with products that give the
best forecasted risk reduction per forecasted dollar spent. Because SCE does not hedge its entire
future natural gas requirement, the unhedged portion will be exposed to fluctuating natural gas
prices and therefore be higher or lower-priced than the hedged portion. DRA is focused on
periods of time when the hedged portion of the portfolio was higher-priced than the unhedged
portion of the portfolio, and questioned the value proposition of SCE’s hedging activity. Had the
hedged portion of the portfolio been lower-priced than the unhedged portion of the portfolio, it is
doubtful that DRA would raise these concerns.
23 DRA, Exhibit 400, pp.24-25. 24 SCE, Exhibit 207, pp.10-11. 25 Id. at p.11.
1815184 - 9 -
Additionally, DRA only examines a very small window in time within a long history of
volatile natural gas prices.26 Events over the past few years have caused a downward trend in
natural gas prices, including the recession’s impact on demand and advances in shale gas
extraction. These factors have contributed to more than a 60% reduction in price since the
summer of 2008, yet SCE does not know of any consultant (or intervenor in this proceeding)
who forecast this price decline. The size of SCE customers’ exposure coupled with such large
price swings demonstrates the need for hedging to protect customers against such volatility.
Hedging activities do have a cost associated with them, as with any form of insurance. It
is clearly within the Commission’s exercise of judgment in representing the interests of utility
bundled customers to decide, such as by establishing a consumer risk tolerance (CRT) factor,
how much rate volatility customers are able to accept. However, such a decision should be based
on longer-term expectations of price volatility, not whether recent hedges have been “in the
money” or not in any particular period. Again, since SCE does not hedge 100% of forecasted
natural gas requirement, when hedges are out of the money, customers benefit from lower costs
on the unhedged portion. Conversely, when hedges are in the money, they provide price
protection for the portion of the forecasted requirement that was hedged, thus moderating the
volatility of energy procurement costs for customers. SCE urges the Commission to take a long-
term view on hedging, and continue to support cost-effective hedging programs for a portion of
the bundled customer portfolio. To do otherwise would be to subject a substantial portion of the
bundled customer portfolio to unmanaged price outcomes. DRA’s testimony regarding hedging
should have no bearing on the Commission’s approval of SCE’s AB 57 Bundled PP.
Other than the unfounded concerns regarding natural gas hedging and compliance with
the Preferred Loading Order and AB 32, no other concerns were raised by parties regarding the
relatively unchanged portions of SCE’s AB 57 Bundled PP. For SCE’s proposed changes, most
26 Id. at p.12.
1815184 - 10 -
of these were unopposed by parties, as described further below, and should thus be approved by
the Commission without modification.
B. The Commission Should Adopt SCE’s Unopposed Request To Contract For A Term
Of Five Years Or Less
In this AB 57 Bundled PP, SCE proposed to procure contracts of “5 years or less” in
duration, instead of contracts limited to “less than 5 years” as authorized in SCE’s 2006
Conformed LTPP.27 As explained in further detail in SCE’s testimony,28 the “less than five-
year” contract limitation causes unnecessary and inefficient procurement constraints to the
detriment of its bundled customers. Under the current “less than five-year” term limitation, if
SCE wants to maximize its allowable procurement term, it must solicit contracts with partial year
effective periods contrary to standard industry practice. Otherwise, SCE must seek shorter-term
contracts that entail more transaction activity and less opportunity for suppliers to offer stable
pricing. Market liquidity for longer-term products is also often limited to annual terms. Since no
party objected to SCE’s proposal to contract for terms of “five years or less” and this is
effectively a one-day (or even arguably a one-hour) increase to SCE’s current procurement
authority, the Commission should approve this request.
C. The Commission Should Adopt SCE’s Unopposed Change To Its Congestion
Revenue Rights (CRRs) Procurement Plan
SCE’s proposal to submit to SCE’s Procurement Review Group (PRG) a single monthly
Congestion Revenue Rights (CRR) allocation and auction results report within five (5) business
days after completion of the last monthly CRR process, instead of within three (3) business days
of each monthly allocation and auction tier result,29 was also uncontested by other parties.
SCE’s proposed change to its current CRR reporting requirement, which requires SCE to submit
27 SCE, Exhibit 200, p.49. 28 SCE, Exhibit 202, pp.53-55. 29 SCE, Exhibit 200, p.56; SCE, Exhibit 201, pp. G-4 through G-5.
1815184 - 11 -
three (3) separate monthly CRR reports for each month’s CRR activity, will simplify the
reporting process and provide PRG participants with a complete summary of each month’s CRR
results.30 The Commission should grant SCE’s unopposed request to provide a more streamlined
approach to CRR reporting for the benefit of SCE’s PRG participants.
D. The Commission Should Adopt SCE’s Unopposed Additional Non-Standard
Products
The following new additions proposed by SCE to the list of authorized non-standard
products in Appendix O in Exhibit 201 were also unopposed by other parties: (1) Electricity
Transmission Products for non-CAISO transmission, and (2) Sales of Forward Energy from
Resources Located Outside the CAISO.31 By designating certain products as non-standard, SCE
can procure these products bilaterally, subject to adequate price support, for terms longer than
one calendar quarter and/or with delivery beginning longer than one calendar quarter forward.
Since SCE has contracted for significant amounts of renewable energy since the 2006
Conformed LTPP, these proposed products will enable SCE to more cost effectively mitigate
delivery cost risks associated with such renewable energy and therefore should be approved by
the Commission.
E. The Commission Should Adopt SCE’s Unopposed Changes To Its Authorized
Brokers And Exchanges Table
There was no opposition to SCE’s removal of the column, “Products Traded and/or
Information Provided,” from its list of “Authorized Brokers and Exchanges” in the 2006
Conformed LTPP to produce Appendix E in Exhibit 201, the Appendices to SCE’s proposed AB
57 Bundled PP, effectively de-linking a given authorized broker or exchange from a given
authorized product. This maximizes flexibility and efficiency in SCE’s procurement of products
30 SCE, Exhibit 202, p.65. 31 Id. at p.67; SCE, Exhibit 201, p. O-1; see also SCE, Exhibit 200, pp.47-48.
1815184 - 12 -
so that SCE can reach as many counterparties as possible for any authorized product. Thus, the
Commission should grant SCE authority to transact any product on SCE’s list of Authorized
Procurement Products for Energy and Energy Related Products (Appendix C of Exhibit 201)
through any broker or exchange on its list of Authorized Brokers and Exchanges (Appendix E of
Exhibit 201).32
III.
THE COMMISSION SHOULD ADOPT SCE’S REMAINING PROPOSED CHANGES
TO THE 2006 LTPP PROCUREMENT PLAN
Although most of SCE’s AB 57 Bundled PP was unopposed by other parties, a few
proposed changes were contested. As detailed below, these changes should nonetheless be
adopted by the Commission.
A. The Commission Should Adopt SCE’s New Hedging Proposals
There was no opposition to SCE’s new hedging proposals to calculate the Consumer Risk
Tolerance (CRT) based on system average rates and implement a revised methodology for SCE’s
procurement limits and ratable rates. However, DRA suggested revisions to these proposals and
the Commission should reject these revisions since they could result in higher costs for
ratepayers.
1. SCE’s Proposed CRT Appropriately Changes As Customer Rates Change
SCE’s proposed periodic calculation of the CRT using a fixed percentage risk factor
multiplied by SCE’s system average rate would be beneficial to SCE’s customers because it
would ensure that customer risk is managed proportionally as rates increase or decrease.33 In its
testimony, DRA recommended a similar proposal, except that DRA proposed that the CRT be
32 SCE, Exhibit 201, pp. C-1 to C-5, E-1 to E-2. 33 SCE, Exhibit 202, p.69.
1815184 - 13 -
indexed to 10 percent of the current system average rate for the IOU.34 SCE proposed that the
CRT should be updated at each biennial LTPP filing using the then-existing system average rate,
and remain fixed until the next LTPP filing.35 Continuously indexing the CRT to an IOU’s ever-
changing system average rate, as proposed by DRA, could destabilize SCE’s hedging program
and lead to perverse outcomes from a contemporaneous feedback loop between system average
rates, procurement costs, and hedging.36 For example, if power and gas prices increase, average
rates will increase, which, in turn, would raise a contemporaneously-indexed CRT and indicate
that less hedging is required. Thus, the Commission should adopt SCE’s more stable periodic
update approach which considers adjustments to the CRT only at each LTPP filing. SCE also
notes that DRA’s proposal to use a 10% CRT index will result in a CRT value that is almost 50%
higher than the current one-cent per kWh CRT and SCE’s proposed 7.04% index. Adoption of
DRA’s 10% CRT index will probably lead to significantly less hedging of the bundled customer
portfolio, which would result in more market exposure.
2. The Commission Should Adopt SCE’s Proposed Procurement Limits and
Ratable Rates Without Any Further Limitations
DRA supported SCE’s more restrictive approach to setting its electrical capacity annual
position limits and ratable rate limits than what is in SCE’s 2006 Conformed LTPP.37 SCE’s
revisions eliminated the load forecast error and generation outage contingencies, resulting in a
total reduction of 1,950 MW per year in SCE’s existing electric capacity annual position limits.38
SCE also proposed to eliminate the three-time ratable rate procurement construct altogether.39
However, DRA proposed to further restrict SCE’s proposed two-time ratable rate for forward
procurement in years two through five to only apply to year two (i.e., the maximum possible
34 DRA, Exhibit 400, p.27. 35 SCE, Exhibit 202, p.69. 36 SCE, Exhibit 207, p.13. 37 DRA, Exhibit 400, pp.44-45. 38 SCE, Exhibit 207, p.14. 39 Id.
1815184 - 14 -
procurement that SCE can engage in is a one-time ratable rate for year three and beyond).40
DRA’s further restriction may lead to higher costs for bundled customers because SCE may be
required to purchase significant quantities of scarce (and therefore pricier) Resource Adequacy
(RA) capacity on a “just-in-time” basis in year two to meet its year-ahead RA requirements,
rather than in years three through five which should have more competitive market conditions.41
Procuring more than a one-time ratable rate over a multiple year procurement window would
allow SCE to create more competition between the limited sellers of RA capacity. Accordingly,
DRA’s suggestion to further limit SCE to a two-time ratable rate for only year two should be
rejected.
With respect to all other proposed changes by SCE related to its procurement limits and
ratable rates, no further opposition was presented in parties’ testimony, and therefore all SCE’s
revisions should be adopted by the Commission. These proposed changes include those changes
to (1) SCE’s ratable rate limits methodology for electrical energy and natural gas to implement a
rolling 12-month ratable rate instead of a monthly ratable rate construct;42 (2) SCE’s
methodology for electrical energy monthly position limits to use the simulated net short
positions to set the monthly purchase position limit, use the simulated monthly net long positions
to set the monthly sales position limit, and calculate such limits separately for on-peak and off-
peak periods and on a gross volume basis;43 (3) allow SCE to file an annual (or more frequent, if
necessary) update to its position limits and ratable rate limits via a Tier 1 advice letter during
years in which SCE does not file an updated AB 57 Bundled PP;44 (4) allow SCE to sell any and
all of its sulfur dioxide (SO2) Title IV allowance portfolio, including rights to the 31-year
forward vintage allowances that the United States Environmental Protection Agency (EPA)
continues to issue on an annual basis;45 and (5) clarify for limits compliance purposes that SCE’s
40 DRA, Exhibit 400, p.46. 41 SCE, Exhibit 207, p.15. 42 SCE, Exhibit 202, pp.57-58. 43 Id. at pp.58-60. 44 Id. at p.60. 45 Id. at p.61.
1815184 - 15 -
position limits and ratable rate limits shall not apply to SCE’s transactions for preferred
resources46 or transactions that do not provide a hedge value (e.g., an index-priced contract), and
that “linked” transactions are considered to be one transaction.47
B. The Commission Should Adopt SCE’s New Renewable Procurement Proposals and
Corresponding Renewables Products
1. SCE’s Proposed Short-Term Renewable Procurement Authority Is An
Appropriate Mechanism To Assist In Meeting The State’s Renewable Energy
Goals
On April 12, 2011, Governor Jerry Brown signed into law Senate Bill (SB) x 1 2 which
established a goal whereby 33% of California’s electricity would come from Renewables
Portfolio Standard (RPS)-eligible renewable resources:48
In order to attain a target of generating 20 percent of total retail sales of electricity in California from eligible renewable energy resources by December 31, 2013, and 33 percent by December 31, 2020, it is the intent of the Legislature that the commission and the Energy Commission implement the California Renewables Portfolio, described in this article.49
The details of how the state will implement SB x 1 2 are yet to be determined. SCE’s
proposed AB 57 Bundled PP includes authorization to enter into a limited quantity of short-term
renewable energy transactions (for either bundled or Renewable Energy Credit (REC) only
products) using a pre-approval framework. This would give SCE flexibility for the procurement
of renewable energy products similar to that of all non-renewable energy products, covered by
the AB 57 Bundled PP.50 Center for Energy Efficiency and Renewable Technologies (CEERT)
supports SCE’s request, with one minor modification, and asserts that this type of flexibility is
46 Preferred resources include EE, DR, Renewable Projects, CHP, QFs, and DG. 47 SCE, Exhibit 202, p.61. 48 Senate Bill (SB) x 1 2 (2011); Renewables Portfolio Standard Program (RPS). 49 SB x 1 2, chaptered April 12, 2011, Pub. Util. Code § 399.11(a). 50 SCE, Exhibit 202, p.48, line 3-4.
1815184 - 16 -
necessary to “make renewable procurement a fully integrated part of long term procurement
planning.”51 SCE agrees that it needs this type of flexibility to ensure that it has the tools
necessary to procure enough renewable energy to meet the State’s 33% goal by December 31,
2020.
As SCE discussed in Exhibit 202, there are five primary factors that challenge
achievement of a 33% goal:
a) “permitting, sitting, approval, and construction of transmission and
renewable generation projects;
b) integrating intermittent renewables;
c) a heavily subscribed interconnection queue;
d) developer performance; and
e) lack of flexibility in the regulatory process governing procurement.”52
SCE’s proposal in this docket specifically addresses the challenge associated with “lack
of flexibility in the regulatory process” governing the procurement of renewable resources. In
SCE’s view, addressing the other four challenges listed above is beyond the scope of this Track
II proceeding.
Exhibit 1100, CEERT’s testimony, noted that “[t]he segregated review and approval of
RPS procurement plans and solicitations and the additional, separate advice letter filing for each
RPS contract, clearly add a level of regulatory process that is not required for conventional
fossil-fired procurement.”53 SCE agrees, as it stated in Exhibit 207: “Because of the need to
increase the flexibility of procurement of higher Preferred Loading Order resources, SCE
requests approval of upfront and achievable standards in this LTPP which can govern its
procurement of certain renewable resources.”54 SCE’s AB 57 Bundled PP included two new
51 CEERT, Exhibit 1100, p. II-4 (citing CEERT Comments on Preliminary Scoping Memo (March 16, 2006) in R.06-02-012, p.7).
52 SCE, Exhibit 202, pp.49-50, lines 15-2. 53 CEERT, Exhibit 1100, p. II-4. 54 SCE, Exhibit 207, pp.16-17, lines 22-1.
1815184 - 17 -
products: Forward Renewable Energy and RECs. The identification of these products and
establishment of a methodology to determine a confidential pre-approval cost limit is consistent
with the treatment of other non-renewable resources in the AB 57 Bundled PP. Granting SCE
this authority would remove barriers to procurement of renewables that do not exist for
procurement of non-renewable resources.
DRA opposed SCE’s proposal to increase flexibility of SCE’s procurement of renewables
while at the same time expressing concern that renewables are not sufficiently prioritized in
SCE’s compliance with the Preferred Loading Order.55 DRA’s objection is primarily procedural
that the issue is outside of the scope of the 2010 LTPP and that the Commission rejected
proposals like this one, in RPS proceedings. 56 “DRA’s procedural objection ignores the
recognized need for a pre-approval process for renewable resources in SCE’s AB 57 Bundled
PP, which requires upfront and achievable standards.”57 Moreover, it is inconsistent with DRA’s
own testimony that recommends the Commission “require the IOUs to develop analytically
rigorous strategies to incorporate the loading order into their day-to-day procurement operations,
per the EPA and Public Utilities Code 454.4”58
Women’s Energy Matters (WEM) and Californians for Renewable Energy (CARE) also
expressed concern that the IOUs were not sufficiently prioritizing purchases from renewables.59
That being said, WEM and CARE did not voice support for SCE’s proposal to increase
flexibility of SCE’s procurement of renewables even though it would facilitate their goals of
providing more flexibility for the IOUs to increase their purchases of renewable power.
SCE urges the Commission to adopt its proposed short-term renewable procurement
authority in this docket. That being said, as SCE notes in its rebuttal testimony, Exhibit 207, if
the Commission wants to make the necessary policy decisions in another proceeding, the
55 DRA, Exhibit 400, pp.18-19. 56 Id. at pp.41-44. 57 SCE, Exhibit 207, p.16, lines 9-11. 58 DRA, Exhibit 400, p.2, lines 25-27. 59 WEM, Exhibit 800, p.6; CARE, Exhibit 700-A, pp.5-6.
1815184 - 18 -
Commission should, at a minimum, approve the methodology SCE has proposed for use in this
docket, and then allow the policy issue of whether to implement the methodology to be
determined in another venue deemed more appropriate.60
2. The Commission Should Adopt SCE’s Proposed Renewable Integration
Products
The Commission should also add Renewable Integration Products to the AB 57 Bundled
PP list of approved procurement products. As discussed in the section above, SB x 1 2
established a 33% renewable energy goal by December 31, 2020. Most renewable resources are
intermittent resources which provide variable energy. SCE anticipates that the delivery of out-
of-state wind generation projects will significantly increase over the next few years.61 SCE will
need Renewable Integration Products to mitigate the operational and financial risks associated
primarily with these out-of-state wind contracts. These products may be highly structured and
result from negotiations between SCE as buyer and the generator as seller of the renewable
power to clarify whether the buyer or the seller of the renewable resource is responsible for
firming up the resource and related charges and/or operational orders by the balancing
authority.62 Alternatively, “these transactions could include products offered directly from the
balancing authority, such as Bonneville Power Administration’s proposed supplemental wind
balancing service.”63
60 SCE, Exhibit 207, p.18, lines 5-9. 61 As noted in Exhibit 207, p.21, footnote 47, “[t]he Shephards Flat project is located in the Columbia Gorge in
Northern Oregon and will increase SCE’s out-of-state wind generation portfolio from 125 MW (Goshen in Southeast Idaho) to 971 MW. The 104 MW Echanix project located in Central Oregon is scheduled to go online in September 2012.”
62 SCE, Exhibit 202, p.66, lines 2-4. 63 Id. at lines 6-8.
1815184 - 19 -
3. SCE’s Proposed Fixed Price For Short Run Avoided Cost Floating Swap Is
Useful And Appropriate
SCE’s proposed Fixed Price for SRAC floating swap was unopposed by other parties.
This product will provide SCE with another option to hedge customer “risk to volatile natural
gas prices resulting from the SRAC payment obligation.”64 This is because most QFs are paid
the CPUC-adopted SRAC price. At the present time, the CPUC-adopted SRAC price is the
Market Index Formula, which, in essence, multiplies a heat rate based 50% on market heat rates
and 50% on an administratively set heat rates by the price of natural gas.65 Thus, the Market
Index Formula fluctuates with the price of natural gas.
In D.10-12-035, the CPUC approved the QF/CHP Settlement Agreement which provides
for implementation of a new SRAC price upon the Settlement Effective Date, which occurs
when certain conditions are met. 66 SCE anticipates that the Settlement Effective Date may occur
as early as this summer.67 This new SRAC price will also fluctuate with the price of natural gas.
The Fixed Price for SRAC floating swap is a voluntary mechanism for QFs desiring the
certainty of a fixed price instead of a price which changes with the price of natural gas. SCE will
use this product solely within its proposed natural gas hedging plan.68 In the past, SCE
established a single fixed price through negotiations with market participants, and, then, offered
that price to all eligible QFs. SCE then submitted these agreements to the CPUC for its
approval, upon which they were contingent.69 The QFs who did not accept the offer or who were
64 SCE, Exhibit 202, p.66, line 21. 65 D.07-09-040. 66 The Settlement Effective Date is the date that the following conditions are met: (1) a final and non-appealable
Federal Energy Regulatory Commission (FERC) order approval the IOUs’ application to terminate their Public Utility Regulatory Policies Act (PURPA) purchase obligation (Section 16.2.1); (2) a final and non-appealable Commission decision approving the Settlement; and (3) CARB support for the Settlement.
67 D.11-03-051 resolved the Applications for Rehearing of D.10-12-035 and, therefore, met the requirement for the final and non-appealable Commission decision. CARB expressed support for the Settlement through an ex parte communication, and, therefore the requirement of CARB support for the Settlement has been met. The parties are awaiting issuance of a final and non-appealable FERC order approving thee IOUs’ application to terminate their PURPA purchase obligation.
68 SCE, Exhibit 207, p.19, lines 10-11. 69 Id. at p.19.
1815184 - 20 -
ineligible for it remained on the SRAC price.70 SCE then managed the natural gas price risk
associated with payments to those QFs “within the context of SCE’s total supply portfolio and
hedging program.”71 The Fixed Price for SRAC floating swap will work in much the same way
as the older single fixed price agreement, but “will allow SCE to hedge the SRAC price exposure
in a more effective manner and will allow market participants, that have the opposite financial
exposure and may find this product beneficial, to participate in these transactions.”72
Thus, the Commission should authorize the Fixed Price for SRAC floating swap as
providing an important hedge to SCE’s customers’ natural gas price exposure.
C. The Commission Should Adopt SCE’s Proposals For Modification Of Convergence
Bidding
With the exception of DRA, no other party opposed SCE’s proposals to modify its
convergence bidding authority to achieve potential benefits for ratepayers. DRA’s concerns
regarding SCE’s convergence bidding proposals should also be rejected, as explained in further
detail below, because SCE’s proposals can provide more benefit for bundled customers, while
still imposing sufficient protections.
1. Track II Of The LTPP Is The Appropriate Forum For Considering Changes
To Convergence Bidding
DRA argued that it is too soon to consider changes to SCE’s AB 57 convergence bidding
upfront standards and the Commission should wait one full year after the convergence bidding
market commenced (i.e., after February 1, 2012) before considering such revisions.73 This
recommendation by DRA has already been rejected by the Commission’s decision in D.10-12-
034 granting the IOUs the authority to engage in convergence bidding, as acknowledged in
70 Id. 71 Id. at lines 20-21. 72 Id. at p.20, lines 5-6. 73 DRA, Exhibit 400, p.47.
1815184 - 21 -
DRA’s own testimony.74 Since the Commission did not accept DRA’s recommendation for a
one-year waiting period and D.10-12-034 specifically stated that “subsequent review of the
[convergence bidding] interim authority . . . will be addressed in the normal course of the
underlying proceeding,”75 modifications to that interim authority should be addressed in Track II
of the underlying LTPP proceeding. Thus, SCE’s proposed revisions are appropriately brought
in Track II of this proceeding.
2. SCE’s Proposed Revisions To Its Convergence Bidding Have Sufficient
Protections For Bundled Customers
For its AB 57 Bundled PP, SCE proposed three revisions to the convergence bidding
authority provided under D.10-12-034:76 (1) remove the Commission-authorized strategy-
specific limitation on SCE’s participation in convergence bidding, but still subject SCE’s
strategies to PRG review prior to implementation; (2) revise the eligible locations for submission
of convergence bids to comport with SCE’s physical supply, physical load, transmission assets
(including CRRs), or transmission usage; and (3) limit SCE’s reporting requirements to
information associated with its cleared (as opposed to all submitted) convergence bidding
transactions.77
Alternatively, if the Commission rejects the first proposed revision and limits SCE to
only Commission-approved strategies, SCE requested that the Commission authorize a fourth
“diversification” strategy to more effectively reduce risk.78 Examples of the diversification
strategy include managing a day-ahead long position by submitting a convergence bid so that a
portion of the long position is settled at the Real-Time Market price, or submitting convergence
bids at CRR source/sink locations so that the CRR settles at Real-Time Market prices rather than
74 SCE, Exhibit 207, p.34 (citing D.10-12-034, pp.11-12; DRA, Exhibit 400, p.47, lines 16-18.). 75 D.10-12-034, p.44. 76 All other upfront standards adopted in D.10-12-034 would become a part of SCE’s AB 57 Bundled PP, except
those proposed to be revised in this filing. 77 See SCE, Exhibit 200, p.56; SCE, Exhibit 201, p. H-1; SCE, Exhibit 202, pp.63-64. 78 SCE, Exhibit 202, pp.64-65.
1815184 - 22 -
the Day-Ahead Market prices. This alternate recommendation also includes the revisions to
convergence bidding locations and reporting requirements. Under a strategy-specific standard,
SCE also proposed to be authorized to file a Tier 3 Advice Letter to request additional strategies,
similar to what SCE uses to modify other elements of its AB 57 Bundled PP.
DRA argued that SCE’s “proposed revisions would effectively remove all limitations
imposed by the upfront standards developed in the decision, except for the $20 million stop-loss
limit.”79 DRA also asserted that “without a strategy specific authorization, there is no ratepayer
protection from an IOU engaging in speculative convergence bidding behavior.”80 DRA’s
arguments are without merit. As SCE stated in its testimony, since “[a]ll other upfront standards
adopted in D.10-12-034 would become a part of SCE’s AB 57 Bundled PP, except those
proposed to be revised in this filing,”81 all protections are still in place under SCE’s proposed
revisions.82 For example, SCE’s proposal to submit convergence bids at locations that comport
with its physical supply, physical load, transmission assets (including CRRs), or transmission
usage83 is a similar standard to the “physical use of the grid” standard for CRRs, and does not
permit any “speculative behavior.” More importantly, the unrevised $20 million stop-loss limit
provides a very high level of cost protection for bundled customers, which is why adoption of
strategy-specific authorizations for the IOUs is unnecessary.84 Nothing in SCE’s proposals
prevents the Commission from restricting the IOUs from engaging in a particular convergence
bidding practice if it determines that is necessary. Moreover, as reflected in a confidential data
request response provided to DRA, experience with the convergence bidding market has already
shown that the very limited set of authorized strategies have not allowed SCE customers to
receive certain benefits of convergence bidding.85 In that response, SCE identified several
79 DRA, Exhibit 400, p.49, lines 4-6. 80 Id. at p.49, lines 13-15. 81 SCE, Exhibit 202, p.63, n.108. 82 SCE, Exhibit 207, p.36. 83 SCE, Exhibit 202, p.63. 84 SCE, Exhibit 207, p.36. 85 Id. at p.35.
1815184 - 23 -
examples of how convergence bidding outside of the current three authorized strategies could
have been used by SCE to benefit its bundled customers if SCE had been authorized to submit
such convergence bids.86
DRA also objected to SCE’s alternate recommendation to approve a fourth
“diversification” strategy if the Commission is not willing to eliminate the strategy-specific
limitations.87 However, DRA has not provided any arguments against the diversification strategy
based on merit, and therefore its objection should be afforded no weight.88 Accordingly, the
Commission should reject DRA’s arguments and approve SCE’s proposed changes to its
convergence bidding upfront standards for the benefit of bundled customers.
IV.
THE COMMISSION SHOULD ADOPT SCE’S PREFERRED PLANNING ANALYSIS
FOR PURPOSES OF SETTING PROCUREMENT LIMITS
Many parties raised concerns about SCE’s Preferred Assumptions used in its Track II
planning analysis. The purpose of the Track II planning analysis for SCE was to set position
limits and ratable rates (i.e., maximum rates of transaction) to provide an upper boundary on the
amount of procurement SCE can engage in without prior Commission approval. The forecast
forming the basis for the position limits should be reasonable, but should not use the most
optimistic and aggressive assumptions possible. SCE’s Preferred Assumptions were largely
based on the CPUC Standardized Planning Assumptions. No party challenged SCE’s use of the
CPUC Standardized Planning Assumptions.
However, SCE made a few changes from the CPUC Standardized Planning Assumptions
to provide a more realistic basis for its position limits, which are based on the results of SCE’s
86 SCE Responses, Questions 5 and 6 of DRA Data Request R.10-05-006-SCE-002, confidential and public versions in Attachment E to SCE, Exhibits 208 and 208-C. SCE’s response to Question 5 provides examples of convergence bidding outside of the current three authorized strategies. SCE’s response to Question 6 provides examples of SCE’s alternative “diversification” strategy.
87 DRA, Exhibit 400, p.50, lines 8-10. 88 See id. at p.50, lines 8-20; SCE, Exhibit 207, p.37.
1815184 - 24 -
Preferred Analysis. Certain CPUC Standardized Planning Assumptions were too optimistic and
aggressive for purposes of setting maximum forward procurement limits, and could lead to a
situation where SCE has too much market exposure because its position limits for forward
procurement activity could be too low. Thus, the changes to the input assumptions in SCE’s
Preferred Analysis make it a more realistic basis for the establishment of SCE’s position limits.
The reasonableness of SCE’s Preferred Analysis is described in more detail below.
SCE also explains below why its assumptions about the implementation of the QF/CHP
Settlement Agreement, which was not addressed in the CPUC Standardized Planning
Assumptions, were reasonable. In addition, SCE discusses the reasonableness of its GHG
emissions results.
A. For the Most Part, SCE Used CPUC Standardized Planning Assumptions And
Methodology
Table III-189 from Exhibit 202 below summarizes the major assumptions used to perform
both the CPUC Standardized Planning Analysis and the SCE Preferred Analysis.
89 SCE, Exhibit 202, p.15.
1815184 - 25 -
Table III-1 Key Input Assumptions
CPUC Standardized
Planning Analysis
SCE Preferred Analysis
Demand Forecast Updated 2009 IEPR90 SCE Current Forecast Load Migration 2009 IEPR Assumption SCE DA Reopening Renewables Compliance
33% Physical Delivery Flexible Compliance
Natural Gas Prices Forward prices averaged using Market Price Referent (MPR) methodology
GHG Prices Synapse Mid-Case Forecast CO2 Emission Rates As specified in proposed CARB regulations Capacity Price Capacity Procurement Mechanism (CPM) Power Prices Power price forecast developed using a production cost
simulation of the Western Electricity Coordinating Council (WECC) region
Cost Assumptions General Rate Case (GRC) Revenue Requirement (RR), existing portfolio costs and market prices
As can be seen from Table III-1, SCE used the same assumption in its SCE Preferred
Analysis as in the CPUC Standardized Planning Analysis for: (1) natural gas prices, (2) GHG
prices, (3) CO2 emission rates; (4) capacity price; (5) power prices, and (6) cost assumptions.
No party objected to SCE’s use of these assumptions. Therefore, the Commission should find
that SCE’s use of these assumptions was reasonable.
90 In the ALJ’s Ruling, dated December 23, 2010, Appendix B, the IOUs are required to adjust the 2009 IEPR forecast using updated information from the California Energy Commission (CEC). See pp.3-5.
1815184 - 26 -
B. To The Extent That SCE’s Preferred Assumptions Deviated From the CPUC
Standardized Planning Assumptions, SCE’s Preferred Assumptions Were More
Reasonable Than The CPUC Standardized Planning Assumptions For Purposes Of
Establishing SCE’s Position Limits For Forward Procurement Activity
Table III-1 from Exhibit 202, reproduced above, shows that SCE used different
assumptions in the SCE Preferred Analysis about: (1) demand forecast; (2) load migration of
SCE customers to Direct Access (DA); and (3) renewables compliance. As discussed below,
these were all reasonable and appropriate changes to the CPUC Standardized Planning
Assumptions.
1. SCE Used Appropriate Assumptions About the Demand Forecast
a) SCE Fully Supported Its EE Assumption
SCE Preferred Assumptions on EE are more realistic than the CPUC Standardized
Planning Assumptions for two key reasons: (1) the EE savings are consistent with D.08-07-047
and the most realistic case identified in the California Energy Commission’s (CEC’s) 2009
Integrated Energy Policy Report (IEPR) Report on EE savings; and (2) the SCE Preferred
Assumptions appropriately implicitly include the energy savings from building codes and
appliance standards, rather then explicitly including them as the CPUC Standardized Planning
Assumptions do.91 As discussed above, the Commission should not adopt the most aggressive
and optimistic EE savings assumptions for purposes of setting position limits and ratable rates in
the AB 57 Bundled PP because of the increased risk to customers of market exposure if the
aggressive and optimistic assumptions are not realized.
91 Id. at pp.26-28.
1815184 - 27 -
(1) SCE Preferred Assumptions Are Consistent With Commission
Decisions and A CEC Forecast That Will Require An
Aggressive Approach
As required in D.08-07-047,92 SCE utilized 100% of the Total Market Gross (TMG)
goals in its LTPP process. SCE’s Preferred Assumptions reflect SCE’s strong commitment to
develop cost effective and achievable EE, and SCE developed its EE forecast assuming that it
will meet or exceed the TMG interim EE goals.
Since the issuance of D.08-07-047, the CEC issued the 2009 IEPR Report which included
the Committee Report on the “Incremental Impacts of Energy Efficiency Initiatives Relative to
the 2009 Integrated Energy Policy Report Adopted Demand Forecast (CEC Report).”93 The
CEC Report identified low, mid, and high EE cases. “The mid and high cases forecast energy
savings from EE that are significantly higher than the TMG goals.”94 In the CEC Report, the
CEC warns that if significant EE savings do not materialize, there may not be sufficient
resources to meet customer demand resulting in reduced system reliability and increased
consumer costs.95 The CPUC Standardized Planning Assumptions assumed the EE savings
projected by the mid case, except that the low case was used for the Big Bold Energy Efficiency
Strategy (BBEES) component. As SCE noted in Exhibit 207, the EE savings in the mid-case
may not be cost effective and achievable in the present economic environment in which
consumers are less able and willing to make capital investments in EE.96 The Commission
should adopt the aggressive, but achievable, CEC Report low case based on achievement of the
TMG goals.
92 D.08-07-047, Ordering Paragraph 3. 93 CEC-200-2009-001-CTF available at http://www.energy.ca.gov/2010publications/CEC-200-2010-001/CEC-
200-2010-001-CTF.PDF. 94 SCE, Exhibit 207, p.27, lines 2-3 (emphasis added). 95 Id. at lines 4-6. 96 Id. at lines 7-10.
1815184 - 28 -
(2) SCE Preferred Assumptions Appropriately Implicitly Include
Energy Savings From Building Codes and Appliance
Standards
The CPUC Standardized Planning Assumptions explicitly included anticipated energy
savings from the building codes and appliance standards that are not part of the TMG goals. The
SCE Preferred Analysis implicitly included the building codes and appliance standards by taking
them into account in its load forecast:97
. . . SCE’s econometric load forecast methodology implicitly captures the savings from building and appliance standards in the overall load forecast as those savings cannot be explicitly identified. This is because SCE’s overall load forecast is based on historical data and trends that include the effect of past improvements in building codes and appliance standards.98
SCE’s Preferred Assumptions forecasted that “the future implementation of building
codes and appliance standards will generally mirror improvements captured in the historical data
forming the basis of SCE’s load forecast.”99 The CPUC Standardized Planning Assumptions
explicitly capture variables with respect to the timing and magnitude of energy savings building
codes and appliance standards.100 As a result, the energy savings in SCE’s Preferred Analysis
are not readily comparable to the energy savings in the CPUC Standardized Planning
Assumptions. That being said, the CPUC Standardized Planning Assumptions may also be too
optimistic as they are not necessarily adjusted for how building codes and appliance standards
have historically resulted in energy savings. The CPUC should not adopt the most optimistic and
aggressive EE savings assumptions for purposes of setting position limits and ratable rates in
SCE’s AB 57 Bundled PP because of the increased risk to customers of market exposure if the
aggressive and optimistic assumptions are not realized.
97 Id. at p.26, lines 1-3. 98 Id. at p. 26, lines 1-4. 99 Id. at lines 5-6. 100 SCE, Exhibit 202, pp.22-23.
1815184 - 29 -
b) SCE Used Appropriate DR Assumptions
For the demand forecast, the SCE Preferred Assumptions also differed from the CPUC
Standardized Planning Assumptions because they assumed that: (1) 280 MW of bilateral DR
contracts will expire by 2012 and should not count beyond that point in time; and (2) there will
be 653 MW less Advanced Metering Infrastructure (AMI)-enabled DR.101 It is not necessary to
use these very aggressive DR assumptions in the CPUC Standardized Planning Assumptions to
establish SCE’s maximum procurement limits.
With regard to the 280 MW of bilateral DR contracts, “[i]t is not appropriate for SCE to
assume that these existing DR programs will remain in SCE’s portfolio given the activity
underway to create third-party demand response providers.”102 SCE’s application for the 2012-
2014 DR program cycle, Application (A.) 11-03-003, assumes that it will not seek renewal of the
280 MW of bilateral DR contracts because of the creation of third-party DR providers. “SCE’s
forecast is more realistic about the level of DR that SCE can reasonably achieve because of the
opening up of direct participation of DR programs in the wholesale market with third party DR
providers capturing some DR savings.”103
With regard to the 653 MW reduction in AMI-enabled DR, there are considerable
uncertainties surrounding AMI-enabled DR at this time.104 The SCE Preferred Analysis
excluded capacity from the following AMI-enabled DR programs: “Programmable
Communicating Thermostat (PCT), Residential Time-Of-Use (TOU), medium C&I Critical Peak
Pricing (CPP), and medium C&I TOU programs.”105 SCE assumed that the only AMI-enabled
DR program remaining in place would be the Save Power Day (previously known as the Peak
Time Rebate program).106
101 SCE, Exhibit 207, p.28. 102 Id. at lines 11-13. 103 SCE, Exhibit 202, p.24, lines 6-8. 104 SCE, Exhibit 207, p.28, lines 20-21. 105 Id. at p.29, lines 1-2. 106 Id. at lines 3-4.
1815184 - 30 -
The Commission should adopt the more realistic SCE Preferred Assumptions for
purposes of setting procurement limits and ratable rates. DR maintains a priority in SCE’s
procurement under the Preferred Loading Order.107 As a result, SCE will account for any DR
that materializes above the forecasted load impact in considering SCE’s incremental Resource
Adequacy (RA) requirements and net energy requirements. To the extent that increases in
realized DR relative to SCE’s forecast of DR occur, the increases in realized DR will reduce
SCE’s residual procurement.108
2. SCE Used Appropriate Assumptions About DA
The SCE Preferred Analysis assumptions about DA migration differed from the CPUC
Standardized Planning Assumptions. SCE’s “DA load forecast includes the maximum allowable
phase-in of new DA sales permitted under SB 695, and this is why it deviates from the DA
forecast underlying the CPUC Standardized Planning Assumptions.”109 The CPUC Standardized
Planning Assumptions assumed less DA penetration.
SB 695, at Public Utilities Code Section 365.1(b) states that:
The commission shall allow individual retail nonresidential end-use customers to acquire electric service from other providers in each electrical corporation’s distribution service territory, up to a maximum allowable total kilowatt hours annual limit.
SB 695, also in Public Utilities Code Section 365.1(b), established the maximum allowable total
kilowatt hours annual limit as “the maximum total kilowatt hours supplied by all other providers
to distribution customers of that electric corporation during any sequential 12-month period
between April 1, 1998 and the effective date of this section.” In D.10-03-022, dated March 11,
2010, the Commission phased in increased DA allowances over a four-year period beginning in
107 Id. at p.29, lines 4-5. 108 Id. at lines 7-8. 109 Id. at p.24, lines 18-20.
1815184 - 31 -
2011, “subject to annual caps in the maximum DA increase allowed each year.”110 By February
2011, the 2012 DA allowance for SCE was fully subscribed.111
The SCE Preferred Analysis assumed that the authorized increase for DA would be fully
subscribed in each year up until 2013. “Starting in 2014, SCE’s forecast of DA sales remains
constant at the 2013 level except for inclusion of a proportional share of the growth in electric
vehicle and electro-technology energy use.”112 SCE’s assumption of the maximum allowable
phase-in of new DA sales is consistent with state law, D.10-03-022, and recent experience in
implementation of both state law and D.10-03-022. Since the SCE Preferred Assumptions about
DA sales are more realistic than the CPUC Standardized Planning Assumptions, the SCE
Preferred Assumptions should be utilized for purposes of establishing position limits and ratable
rates for SCE’s Track II Bundled PP.
3. SCE Used Appropriate Flexible Compliance Assumptions for Renewables
Both the SCE Preferred Analysis and the CPUC Standardized Planning Analysis assumed
that 100% of SCE’s expiring renewable contracts are re-contracted.113 Both analyses also
assumed that all new renewable projects that SCE has signed and the Commission has approved
on or by December 31, 2010 are built with a project success rate of 100%.114 “Renewable
projects that SCE has signed, but the Commission has not yet approved, are not included in
either analysis.”115 The only difference between the two analyses is that “SCE’s Preferred
Analysis assumes RPS flexible compliance while the CPUC Standardized Planning Analysis
assumes physical compliance with a 33% renewables target.”116 The use of flexible compliance
110 D.10-03-022, p.2. 111 http://www.sce.com/b-db/esp/SB695.html SCE requests that the Commission take official notice, pursuant to
Rule 13.9 of the Rules of Practice and Procedure, of the full subscription of its 2012 DA allowance noted on the attached SCE website link.
112 SCE, Exhibit 207, p.25, lines 4-6. 113 SCE, Exhibit 202, p.26, lines 7-9. 114 Id. at lines 10-12. 115 Id. at lines 12-13. 116 Id. at lines 14-15.
1815184 - 32 -
assumptions for renewables eliminates the need to assume acquisition of additional generic
renewable resources in 2020 and 2021 in the SCE Preferred Analysis as compared to the CPUC
Standardized Planning Analysis. The use of SCE Preferred Assumptions about renewable
development is appropriate to determine procurement limits and ratable rates for filling SCE’s
net open position. To the extent that SCE has underestimated the need to purchase renewable
resources to meet the 33% goal, it will enter into additional contracts for the purchase of
renewable resources.
a) Passage Of Recently Enacted SB x 1 2 Does Not Call Into Question
The Use of Flexible Compliance for Renewables In SCE’s Preferred
Analysis
Furthermore, the passage of the new legislation SB x 1 2 establishing a 33% renewables
goal should not call into question the results of the Track II planning analyses. Contrary to
Communities for a Better Environment’s (CBE’s) assertions, there is no need to update SCE’s
proposed plan to comply with the new renewables law enacted in SB x 1 2. The renewables goal
in both the CPUC Standardized Planning Analysis and the SCE Preferred Analysis was 33%.
Moreover, “[t]he implementation details for the new renewables legislation have yet to be
determined.”117 SB x 1 2 was signed by Governor Jerry Brown on April 12, 2011, long after the
Track II planning analyses began with the issuance of the December 3, 2010 Scoping Memo on
December 3, 2010. The Commission has opened a rulemaking for issues related to its
implementation, but has not yet issued any decisions in that docket. 118 It is premature to try to
determine the extent the final regulatory rules will change the current flexible compliance rules
in effect. To the extent that the flexible compliance rules result in significant changes to its AB
57 Bundled PP, SCE can update its AB 57 Bundled PP through an Advice Letter. For these
117 SCE, Exhibit 207, p.32, lines 8-9. 118 R.08-08-009.
1815184 - 33 -
reasons, the Commission should adopt the SCE Preferred Analysis for purposes of establishing
procurement limits and ratable rates in this Track II of the LTPP.
b) SCE Used Appropriate RES Compliance Assumptions
CBE raised a concern about SCE’s reported renewable energy being at 29% in 2021
based on SCE’s Figure B-9 of its testimony.119 The difference identified by CBE is the result of
differences in where the measurement of the delivery of energy occurs. Contrary to CBE’s
assertions, there is no basis for concern because the Exhibit SCE-4 pie chart labeled “Figure B-9
CPUC Standardized Planning Analysis – Energy Mix 2021” shows energy from renewable
energy at 29% and not 33%. The reason for this discrepancy is that Figure B-9 measures the
energy mix at the CAISO grid interface and, therefore, accounts for transmission losses for the
generated renewable energy and distribution losses for the retail sales. In contrast, the 33%
renewables goal is calculated as the renewable energy generated and measured at the generator
busbar divided by the total energy consumed measured at the retail customer meter. So, the
renewables goal of 33% does not take into account transmission and distribution losses.
“Therefore, the proportion of renewable generation in the portfolio energy mix will be less than
33% when measured at the CAISO grid interface,”120 even though the projected renewable
energy deliveries meet the 33% requirement when measured as percentage of busbar generation
relative to retail sales.
C. SCE Used Appropriate CHP Assumptions
SCE also made reasonable assumptions about procurement of CHP resources pursuant to
the QF/CHP Settlement Agreement in this 2010 LTPP planning analysis. In D.10-12-035, the
CPUC approved the QF/CHP Settlement Agreement which provides for implementation of a
new SRAC price upon the Settlement Effective Date, which occurs when certain conditions are
119 SCE, Exhibit 203, p.B-9. 120 SCE, Exhibit 207, p.33, lines 14-15.
1815184 - 34 -
met.121 SCE anticipates that the Settlement Effective Date may occur as early as this summer.122
The CPUC Standardized Planning Assumptions were first developed in the Commission’s
December 3, 2010 Scoping Memo which was issued before the Commission issued D.10-12-035
adopting the QF/CHP Settlement on December 16, 2010. Thus, the CPUC Standardized
Planning Assumptions did not specifically incorporate assumptions concerning the QF/CHP
Settlement Agreement, which is why SCE made reasonable assumptions about its
implementation to meet certain MW targets to purchase QF/CHP power.123
The QF/CHP Settlement Agreement has two program periods. The first program period
establishes MW targets for procurement of QF/CHP power for each IOU. SCE’s MW target for
the first program period is 1402 MW. SCE assumed that it would meet the MW target for
QF/CHP power of 1402 MW by 2015 in its Track II planning analyses. This is an appropriate
assumption, especially since it is consistent with the QF/CHP Settlement Agreement.
The second program period, which will likely begin in 2015, establishes GHG targets
which are subject to change for each IOU. The GHG targets can change: (1) as CARB
requirements for GHG reduction from CHP change, (2) as SCE’s share of retail sales of energy
change; and (3) as SCE acquires CHP resources during the first program period that reduce
GHG. SCE did not make any assumptions about what would be needed to meet the GHG targets
past December 31, 2020, through the purchase of QF/CHP power. The QF/CHP Settlement
Agreement has yet to become effective. If the settlement becomes effective, SCE will have an
opportunity to determine how much QF/CHP power it will likely need to meet the GHG targets
121 The Settlement Effective Date is the date that the following conditions are met: (1) a final and non-appealable FERC order approval the IOUs’ application to terminate their PURPA purchase obligation (Section 16.2.1); (2) a final and non-appealable Commission decision approving the Settlement; and (3) CARB support for the Settlement.
122 D.11-03-051 resolved the Applications for Rehearing of D.10-12-035 and, therefore, met the requirement for the final and non-appealable Commission decision. CARB expressed support for the Settlement through an ex parte communication, and, therefore the requirement of CARB support for the Settlement has been met. The parties are awaiting issuance of a final and non-appealable FERC order approving thee IOUs’ application to terminate their PURPA purchase obligation.
123 SCE, Exhibit 207, pp.29-31.
1815184 - 35 -
in the second program period. At that time, it will be appropriate to incorporate new
assumptions about how SCE will meet its GHG target.
D. The GHG Emissions Results In SCE’s Preferred Analysis Are Appropriate
Contrary to DRA’s assertions, “SCE does not assume that it will use GHG-emitting
resources to fill its net short position.”124 Instead, SCE assumes that it will fill its net short
position with market purchase and imports from GHG-compliance-obligated entities.125 So, as a
simplifying assumption, SCE assumes that the market price will be determined by a gas-fired
marginal unit. As a result, the cost of all market purchases includes the marginal resource’s cost
of GHG compliance. This assumption appropriately estimates SCE’s market exposure to the
cost of GHG which will be embedded in the cost of all power sold in California.126 SCE utilizes
a least cost, best fit approach to its actual procurement, and will procure whichever resources are
least cost, best fit for its system consistent with the Preferred Loading Order and other applicable
regulatory mandates.
124 SCE, Exhibit 207, p.31, lines 5-6. 125 Id. at lines 7-8. 126 Id. at lines 10-12.
1815184 - 36 -
V.
CONCLUSION
For all of these reasons, SCE respectfully requests the Commission to issue an Order:
1. Adopting SCE’s AB 57 Bundled PP, set forth in Exhibits 200, 201, and 201-C,
without change or modification, including the use of the SCE Preferred Analysis
for the purpose of setting procurement limits and ratable rates.
Respectfully submitted, MICHAEL D. MONTOYA CAROL A. SCHMID-FRAZEE MELISSA HOVSEPIAN
/s/ Carol A. Schmid-Frazee By: Carol A. Schmid-Frazee
Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1337 Facsimile: (626) 302-1935 E-mail:Carol [email protected]
June 17, 2011
Appendix A
A-1
APPENDIX A
SCE’S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW
PROPOSED FINDINGS OF FACT
1. SCE’s AB 57 Bundled PP addresses the procurement required to serve the residual energy
requirements of SCE’s bundled customers, after first fully accounting for all of SCE’s
committed and forecasted preferred resources (i.e., EE, DR, renewables, QF contracts, CHP,
and DG) and UOG.
2. Since SCE’s resource acquisition strategy prioritizes preferred resources that reduce GHG
emissions from SCE’s bundled customer portfolio, and SCE’s AB 57 Bundled PP is
consistent with the GHG reduction goals of AB 32.
3. SCE has already reduced its GHG emissions to below its 1990 levels and forecasts to have an
average GHG emission rate of less than 500 lbs/MWh by 2015 due to SCE’s early GHG-
reducing actions and SCE’s compliance with the Preferred Loading Order.
4. SCE accounts for the GHG emissions reduction benefits prior to selecting supply offers in its
competitive procurement processes.
5. SCE’s financial natural gas hedging is a valuable tool for SCE’s customers because natural
gas is the single largest market-sensitive exposure and the natural gas market is the most
mature and liquid, offering numerous cost-effective hedging options.
6. How much rate volatility customers are able to accept is a decision that should be based on
longer-term expectations of price volatility, not whether hedges have been “in the money” or
not in any particular period.
7. SCE’s proposal to procure contracts of “5 years or less” in duration, instead of contracts
limited to “less than 5 years,” is reasonable because the “less than five-year” contract
limitation causes unnecessary and inefficient procurement constraints to the detriment of its
bundled customers.
A-2
8. SCE’s proposal to submit to SCE’s PRG a single monthly CRR allocation and auction results
report within five (5) business days after completion of the last monthly CRR process,
instead of within three (3) business days of each monthly allocation and auction tier result, is
reasonable. SCE’s proposed change will simplify the reporting process and provide PRG
participants with a complete summary of each month’s CRR results.
9. All new additions proposed by SCE to the list of authorized non-standard products in
Appendix O in Exhibit 201 are reasonable.
10. SCE’s proposal to transact any product on SCE’s list of Authorized Procurement Products
for Energy and Energy Related Products (Appendix C of Exhibit 201) through any broker or
exchange on its list of Authorized Brokers and Exchanges (Appendix E of Exhibit 201) is
reasonable.
11. SCE’s proposed calculation of the CRT using a fixed percentage risk factor multiplied by
SCE’s system average rate would be beneficial to SCE’s customers because it would ensure
that customer risk is managed proportionally as rates increase or decrease.
12. The CRT should be updated at each biennial LTPP filing using the then-existing system
average rate, and remain fixed until the next LTPP filing.
13. SCE’s more restrictive approach to setting its electrical capacity annual position limits and
ratable rate limits than what is in its 2006 Conformed LTPP is reasonable.
14. SCE’s revisions eliminate the load forecast error and generation outage contingencies,
resulting in a total reduction of 1,950 MW per year in SCE’s existing electric capacity annual
position limits.
15. SCE also proposed to eliminate the three-time ratable rate procurement construct altogether
and limit the two-time ratable rate for forward procurement to years two through five.
Procuring up to a two-time ratable rate over a multiple year procurement window will allow
SCE to create more competition between the limited sellers of RA capacity.
16. The following additional proposed changes by SCE are reasonable: (1) SCE’s ratable rate
limits methodology for electrical energy and natural gas to implement a rolling 12-month
A-3
ratable rate instead of a monthly ratable rate construct; (2) SCE’s methodology for electrical
energy monthly position limits to use the simulated net short positions to set the monthly
purchase position limit, use the simulated monthly net long positions to set the monthly sales
position limit, and calculate such limits separately for on-peak and off-peak periods and on a
gross volume basis; (3) clarification for limits compliance purposes that SCE’s position
limits and ratable rate limits shall not apply to SCE’s transactions for preferred resources or
transactions that do not provide a hedge value (e.g., an index-priced contract), and that
“linked” transactions are considered to be one transaction; (4) SCE is allowed to file an
annual (or more frequent, if necessary) update to its position limits and ratable rate limits via
a Tier 1 advice letter during years in which SCE does not file an updated AB 57 Bundled PP;
and (5) SCE is allowed to sell any and all of its SO2 Title IV allowance portfolio, including
rights to the 31-year forward vintage allowances that the EPA continues to issue on an annual
basis.
17. SCE’s request for authorization to enter into a limited quantity of short-term renewable
energy transactions (for either bundled or REC only products) using a pre-approval
framework is reasonable. This would give SCE flexibility for the procurement of renewable
energy products similar to that of all non-renewable energy products and to procure enough
renewable energy to meet the State’s 33% goal by December 31, 2020.
18. SCE’s proposed Renewable Integration Products are beneficial additions to the AB 57
Bundled PP list of approved procurement products.
19. SCE’s proposed Fixed Price for SRAC floating swap is a beneficial addition to the AB 57
Bundled PP list of approved procurement products as it would provide an important hedge to
SCE’s customers’ natural gas price exposure.
20. SCE’s proposed three revisions to the convergence bidding authority provided under D.10-
12-034 are reasonable and beneficial to SCE’s bundled customers while still providing a high
level of cost protection: (1) remove the Commission-authorized strategy-specific limitation
on SCE’s participation in convergence bidding, but still subject SCE’s strategies to PRG
A-4
review prior to implementation; (2) revise the eligible locations for submission of
convergence bids to comport with SCE’s physical supply, physical load, transmission assets
(including CRRs), or transmission usage; and (3) limit SCE’s reporting requirements to
information associated with its cleared (as opposed to all submitted) convergence bidding
transactions. All other upfront standards adopted in D.10-12-034 will remain a part of SCE’s
AB 57 Bundled PP.
21. The SCE Preferred Assumptions, which were largely based on the CPUC Standardized
Planning Assumptions, are reasonable for the purpose of setting SCE’s position limits and
ratable rates.
22. SCE’s changes to the input assumptions in the SCE Preferred Analysis make it a more
realistic basis for the establishment of SCE’s position limits and ratable rates.
23. SCE used the same assumption in its SCE Preferred Analysis as in the CPUC Standardized
Planning Analysis for: (1) natural gas prices, (2) GHG prices, (3) CO2 emission rates; (4)
capacity price; (5) power prices, and (6) cost assumptions. Therefore, we find that SCE’s use
of these assumptions was reasonable.
24. SCE’s different assumptions in the SCE Preferred Analysis about: (1) demand forecast; (2)
load migration of SCE customers to DA; and (3) renewables compliance were all reasonable
and appropriate changes to the CPUC Standardized Planning Assumptions for the purpose of
setting procurement limits.
25. SCE made reasonable assumptions about procurement of CHP resources pursuant to the
QF/CHP Settlement Agreement in its 2010 LTPP planning analysis.
26. The GHG emissions results in SCE’s Preferred Analysis are reasonable and appropriate.
A-5
PROPOSED CONCLUSIONS OF LAW
1. As required by AB 57, SCE’s AB 57 Bundled PP sets forth the upfront, achievable standards
and criteria by which SCE’s procurement activity will be deemed per se reasonable and
therefore eligible for cost recovery.
2. SCE fully complies with the Preferred Loading Order and AB 32 by accounting for preferred
resources in its procurement planning and transaction activity covered by SCE’s proposed
transaction position limits and ratable rates.
3. Parties’ specific concerns regarding procurement of preferred resources should be addressed
in the proceedings dealing with such preferred resources.
4. SCE’s proposed revisions to its convergence bidding authority are appropriately considered
in Track II of this LTPP proceeding.
5. D.10-12-034 should be modified to: (1) remove the Commission-authorized strategy-specific
limitation on SCE’s participation in convergence bidding, but still subject SCE’s strategies to
PRG review prior to implementation; (2) revise the eligible locations for submission of
convergence bids to comport with SCE’s physical supply, physical load, transmission assets
(including CRRs), or transmission usage; and (3) limit SCE’s reporting requirements to
information associated with its cleared (as opposed to all submitted) convergence bidding
transactions. All other upfront standards adopted in D.10-12-034 will remain a part of SCE’s
AB 57 Bundled PP.
CERTIFICATE OF SERVICE
I hereby certify that, pursuant to the Commissioner’s Rules of Practice and Procedure, I
have this day served a true copy of OPENING BRIEF OF SOUTHERN CALIFORNIA
EDISON COMPANY (U 338-E) ON TRACK II on all parties identified in the attached service
list(s).
Transmitting the copies via e-mail to all parties who have provided an e-mail address.
First class mail will be used if electronic service cannot be effectuated.
Executed this 17th day of June, 2011, at Rosemead, California.
/s/ Christina A. Sanchez Christina A. Sanchez Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Ave. Post Office Box 800 Rosemead, California 91770
PROCEEDING: R1005006 - CPUC - OIR TO INTEGR FILER: CPUC LIST NAME: LIST LAST CHANGED: JUNE 10, 2011
DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES
Back to Service Lists Index
AUDREY CHANG DANIEL W. DOUGLASS CA ENERGY EFFICIENCY INDUSTRY COUNCIL DOUGLASS & LIDDELL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: CALIFORNIA ENERGY EFFICIENCY FOR: WESTERN POWER TRADING FORUM / INDUSTRY COUNCIL DIRECT ACCESS CUSTOMER COALITION/ALLIANCE FOR RETAIL ENERGY MARKETS/ MARIN ENERGY AUTHORITY DONALD C. LIDDELL JOSHUA ARCE DOUGLASS & LIDDELL BRIGHTLINE DEFENSE PROJECT EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: THE CALIFORNIA ENERGY STORAGE FOR: BRIGHTLINE DEFENSE PROJECT ALLIANCE JULIE GILL KENNETH SAHM WHITE AES SOUTHLAND FIT COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: AES FOR: FIT COALITION L. JAN REID SIERRA MARTINEZ EMAIL ONLY NATURAL RESOURCES DEFENSE COUNCIL EMAIL ONLY, CA 00000 EMAIL ONLY FOR: L. JAN REID EMAIL ONLY, CA 00000 FOR: NATURAL RESOURCES DEFENSE COUNCIL SUE MARA TAM HUNT RTO ADVISORS, LLC HUNT CONSULTING EMAIL ONLY EMAIL ONLY
CPUC Home
CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists
Parties
Page 1 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: RTO ADVISORS, LLC FOR: CLEAN COALITION LAURA WISLAND MARTIN HOMEC UNION OF CONCERNED SCIENTISTS EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000-0000 EMAIL ONLY, CA 00000-0000 FOR: WOMEN'S ENERGY MATTERS FOR: UNION OF CONCERNED SCIENTISTS NANCY RADER ABRAHAM SILVERMAN EXECUTIVE DIRECTOR SR. COUNSEL, REGULATORY CALIFORNIA WIND ENERGY ASSOCIATION NRG ENERGY, INC. EMAIL ONLY 211 CARNEGIE CENTER DRIVE EMAIL ONLY, CA 00000-0000 PRINCETON, NJ 08540 FOR: CALIFORNIA WIND ENERGY ASSOCIATION FOR: NRG ENERGY, INC. B. MARIE PIENIAZEK MELISSA DORN DEMAND RESPONSE & ENERGY CONSULTING, LLC MCDERMOTT WILL & EMERY LLP 1328 BOZENKILL ROAD 600 13TH ST. NW DELANSON, NY 12053 WASHINGTON, DC 20005 FOR: ENERGY CURTAILMENT SPECIALISTS INC. FOR: MORGAN STANLEY CAPITAL GROUP INC. JAMES P. WHITE JASON ARMENTA TRANSCANADA CORPORATION CALPINE POWERAMERICA-CA, LLC 4547 RINCON PLACE 717 TEXAS AVENUE, SUITE 1000 MONTCLAIR, VA 22025 HOUSTON, TX 77002 FOR: ZEPHYR POWER TRANSMISSION, LLC FOR: CALPINE POWERAMERICA-CA, LLC BO BUCHYNSKY JERRY R. BLOOM DIAMOND GENERATING CORPORATION WINSTON & STRAWN, LLP 333 SOUTH GRAND AVE., SUITE 1570 333 SOUTH GRAND AVENUE, 38TH FLOOR LOS ANGELES, CA 90071 LOS ANGELES, CA 90071-1543 FOR: DIAMOND GENERATING CORPORATION FOR: CALIFORNIA COGENERATION COUNCIL CAROL SCHMID-FRAZEE MARY C. HOFFMAN SOUTHERN CALIFORNIA EDISON CO. PRESIDENT 2244 WALNUT GROVE AVE./PO BOX 800 SOLUTIONS FOR UTILITIES, INC. ROSEMEAD, CA 91770 1192 SUNSET DRIVE FOR: SOUTHERN CALIFORNIA EDISON COMPANY VISTA, CA 92081 FOR: SOLUTIONS FOR UTILITIES, INC. AIMEE SMITH DANIEL A. KING SAN DIEGO GAS & ELECTRIC COMPANY SEMPRA GENERATION 101 ASH STREET, HQ-12 101 ASH STREET, HQ 14 SAN DIEGO, CA 92101 SAN DIEGO, CA 92101 FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: SEMPRA GENERATION MONA TIERNEY-LLOYD EVELYN KAHL SENIOR MANAGER WESTERN REG. AFFAIRS ALCANTAR & KAHL, LLP ENERNOC, INC. 33 NEW MONTGOMERY STREET, SUITE 1850 PO BOX 378 SAN FRANCISCO, CA 94015 CAYUCOS, CA 93430 FOR: ENERGY PRODUCERS AND USERS FOR: ENERNOC, INC. COALITION MARC D. JOSEPH NOEL OBIORA ADAMS BROADWELL JOSEPH & CARDOZO CALIF PUBLIC UTILITIES COMMISSION 601 GATEWAY BLVD. STE 1000 LEGAL DIVISION SOUTH SAN FRANCISCO, CA 94080 ROOM 4107 FOR: COALITION OF CALIFORNIA UTILITY 505 VAN NESS AVENUE EMPLOYEES SAN FRANCISCO, CA 94102-3214 FOR: DIVISION OF RATEPAYER ADVOCATES MARYBELLE C. ANG TIM LINDL STAFF ATTORNEY ALCANTAR & KAHL THE UTILITY REFORM NETWORK 33 NEW MONTGOMERY ST., STE. 1850
Page 2 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
115 SANSOME STREET, STE. 900 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94104 FOR: COGENERATION ASSOCIATION OF FOR: TURN CALIFORNIA/ENERGG PRODUCERS AND USERS COALITION DEBORAH N. BEHLES BRIAN T. CRAGG GOLDEN GATE UNIVERSITY SCHOOL OF LAW GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY 536 MISSION STREET 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94105-2968 SAN FRANCISCO, CA 94111 FOR: PACIFIC ENVIRONMENT FOR: INDEPENDENT ENERGY PRODUCERS ASSOCIATION VIDHYA PRABHAKARAN JEFFREY P. GRAY DAVIS WRIGHT & TREMAINE LLP DAVIS WRIGHT TREMAINE, LLP 505 MONTGOMERY STREET, SUITE 800 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111-6533 FOR: CALIFORNIA PACIFIC ELECTRIC FOR: CALPINE CORPORATION COMPANY LLC STEVEN F. GREENWALD LISA A. COTTLE ATTORNEY AT LAW WINSTON & STRAWN LLP DAVIS WRIGHT TREMAINE LLP 101 CALIFORNIA STREET, 39TH FLOOR 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94114 SAN FRANCISCO, CA 94111-6533 FOR: MIRANT CALIFORNIA, LLC FOR: CAPITAL POWER CORPORATION CHARLES R. MIDDLEKAUFF SARA STECK MYERS PACIFIC GAS AND ELECTRIC COMPANY ATTORNEY AT LAW 77 BEALE STREET, B30A 122 - 28TH AVENUE SAN FRANCISCO, CA 94120 SAN FRANCISCO, CA 94121 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE TECHNOLOGIES (CEERT) MICHAEL ROCHMAN JENNIFER CHAMBERLIN MANAGING DIRECTOR LS POWER DEVELOPMENT, LLC SCHOOL PROJECT UTILITY RATE REDUCTION 5000 HOPYARD ROAD, SUITE 480 1850 GATEWAY BLVD., STE. 235 PLEASANTON, CA 94588 CONCORD, CA 94520 FOR: LS POWER ASSOCIATES, L.P. FOR: SCHOOL PROJECT FOR UTILITY RATE REDUCTION WILLIAM H. BOOTH JOSEPH F. WIEDMAN LAW OFFICES OF WILLIAM H. BOOTH KEYES & FOX LLP 67 CARR DRIVE 436 14TH STREET, SUITE 1305 MORAGA, CA 94596 OAKLAND, CA 94612 FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: INTERSTATE RENEWABLE ENERGY COUNCIL ASSOCIATION (CLECA) PAUL CORT SHANA LAZEROW EARTHJUSTICE ATTORNEY 426 17TH STREET, 5TH FLOOR COMMUNITIES FOR BETTER ENVIRONMENT OAKLAND, CA 94612 1904 FRANKLIN STREET, STE 600 FOR: SIERRA CLUB CALIFORNIA OAKLAND, CA 94612 FOR: COMMUNITIES FOR A BETTER ENVIRONMENT WILLIAM B. ROSTOV GREGG MORRIS EARTHJUSTICE DIRECTOR 426 17TH STREET, 5TH FLOOR GREEN POWER INSTITUTE OAKLAND, CA 94612 2039 SHATTUCK AVE., SUITE 402 FOR: SIERRA CLUB CALIFORNIA BERKELEY, CA 94704 FOR: GREEN POWER INSTITUTE JASMIN ANSAR LINDA AGERTER UNION OF CONCERNED SCIENTISTS 51 PARKSIDE DRIVE 2397 SHATTUCK AVENUE, SUITE 203 BERKELEY, CA 94705
Page 3 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
BERKELEY, CA 94704 FOR: LARGE-SCALE SOLAR ASSOCIATION FOR: UNION OF CONCERNED SCIENTISTS R. THOMAS BEACH MICHAEL E. BOYD CALIFORNIA COGENERATION COUNCIL PRESIDENT 2560 NINTH STREET, SUITE 213A CALIFORNIANS FOR RENEWABLE ENERGY, INC. BERKELEY, CA 94710-2557 5439 SOQUEL DRIVE FOR: CALIFORNIA COGENERATION COUNCIL SOQUEL, CA 95073-2659 (CCC) / CALIFORNIA WIND ENERGY FOR: CALIFORNIANS FOR RENEWABLE ENERGY ASSOCIATION JUDITH B. SANDERS KELLY M. FOLEY SR. COUNSEL ATTORNEY CALIF. INDEPENDENT SYSTEM OPERATOR CORP THE VOTE SOLAR INITIATIVE 151 BLUE RAVINE ROAD 2089 TRACY COURT FOLSOM, CA 95630 FOLSOM, CA 95630 FOR: CALIFORNIA INDEPENDENT SYSTEM FOR: THE VOTE SOLAR INITIATIVE OPERATOR CORPORATION SYDNEY MANHEIM DAVIES ROBERT E. BURT CALIFORNIA INDEPENDENT SYSTEM OPERATOR INSULATION CONTRACTORS ASSN. 151 BLUE RAVINE ROAD 3479 ORANGE GROVE AVE., STE. A FOLSOM, CA 95630 NORTH HIGHLANDS, CA 95660 FOR: CALIFORNIA INDEPENDENT SYSTEM FOR: INSULATION CONTRACTORS ASSN. OPERATOR CAROLYN M. KEHREIN ANDREW B. BROWN ENERGY MANAGEMENT SERVICES ELLISON SCHNEIDER & HARRIS, L.L.P. 2602 CELEBRATION WAY 2600 CAPITAL AVENUE, SUITE 400 WOODLAND, CA 95776 SACRAMENTO, CA 95816-5905 FOR: ENERGY USERS FORUM FOR: CONSTELLATION NEWENERGY, INC. KRISTIN BURFORD KAREN NORENE MILLS LARGE-SCALE SOLAR ASSOCIATION ATTORNEY AT LAW 2501 PORTOLA WAY CALIFORNIA FARM BUREAU FEDERATION SACRAMENTO, CA 95818 2300 RIVER PLAZA DRIVE FOR: LARGE SCALE SOLAR ASSOCIATION SACRAMENTO, CA 95833 FOR: CALIFORNIA FARM BUREAU FEDERATION DONALD E. BROOKHYSER ATTORNEY AT LAW ALCANTAR & KAHL 1300 S.W. FIFTH AVENUE, SUITE 1750 PORTLAND, OR 97201 FOR: COGENERATION ASSN. OF CALIFORNIA
AMBER MAHONE ANDRA PLIGAVKO ENERGY AND ENVIRONMENTAL ECONOMICS FIRST SOLAR DEVELOPMENT, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 ANDRES PACHECO BETH VAUGHAN RECURRENT ENERGY CALIFORNIA COGENERATION COUNCIL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 DANIEL PATRY GENE VARANINI PACIFIC GAS AND ELECTRIC COMPANY SPECIAL COUNSEL EMAIL ONLY DEMAND RESERVES PARTNERSHIP EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000
Information Only
Page 4 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
JESSIE BAIRD JOHN W. LESLIE, ESQ. EARTHJUSTICE LUCE, FORWARD, HAMILTON & SCRIPPS, LLP EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 LAKSHMI ALAGAPPAN MALCOLM D. AINSPAN ENERGY AND ENVIRONMENTAL ECONOMICS, INC. ENERGY CURTAILMENT SPECIALISTS EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, NY 00000 FOR: ENERGY AND ENVIRONMENTAL ECONOMICS, INC. (E3) MATTHEW FREEDMAN NOAH LONG THE UTILITY REFORM NETWORK NATURAL RESOURCES DEFENSE COUNCIL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 STEVEN KELLY LEGAL & REGULATORY DEPARTMENT INDEPENDENT ENERGY PRODUCERS ASSOCIATION CALIFORNIA ISO EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 DAVIS WRIGHT TREMAINE LLP MRW & ASSOCIATES, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 CURTIS KEBLER CYNTHIA BRADY SEMPRA GENERATION CONSTELLATION ENERGY RESOURCES, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000-0000 EMAIL ONLY, IL 00000-0000 DONALD GILLIGAN IAN MCGOWAN NATIONAL ASSC. OF ENERGY SVC. COMPANIES MANAGER - REGULATORY AFFAIRS EMAIL ONLY 3DEGREES EMAIL ONLY, DC 00000-0000 EMAIL ONLY FOR: NATIONAL ASSOCIATION OF ENERGY EMAIL ONLY, CA 00000-0000 SERVICE COMPANIES JOHN NIMMONS MELISSA SCHARY JOHN NIMMONS & ASSOCIATES, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000-0000 EMAIL ONLU, CA 00000-0000 MICHAEL O'KEEFE MICHELLE GRANT CAL. ENERGY EFFICIENCY INDUSTRY COUNCIL DYNEGY, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000-0000 EMAIL ONLY, TX 00000-0000 STEVEN HUHMAN MICHAEL A. YUFFEE MORGAN STANLEY CAPITAL GROUP INC. HOGAN LOVELLS 2000 WESTCHESTER AVENUE 555 13TH ST., N.W. PURCHASE, NY 10577 WASHINGTON, DC 20004 STEVEN A. WEILER KEVIN J. SIMONSEN LEONARD STREET AND DEINARD, PA ENERGY MANAGEMENT SERVICES 1350 I STREET, NW, STE. 800 646 E. THIRD AVE. WASHINGTON, DC 20005 DURANGO, CA 81301 FOR: ZEPHYR POWER TRANSMISSION, LLC CAITLIN COLLINS LIOTIRIS JUSTIN FARR ENERGY STRATEGIES, LLC ENERGY STRATEGIES, LLC 215 SOUTH STATE STREET, STE 200 215 SOUTH STATE ST., STE. 200
Page 5 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
SALT LAKE CITY, UT 84111 SALT LAKE CITY, UT 84111 CYNTHIA K. MITCHELL HANS LAETZ, J.D. ENERGY ECONOMICS, INC. ZUMA IMPACT LLC 530 COLGATE COURT 6402 SURFSIDE WAY RENO, NV 89503 MALIBU, CA 90265 FRED MOBASHERI AMBER DEAN WYATT CONSULTANT SOUTHERN CALIFORNIA EDISON COMPANY ELECTRIC POWER GROUP, LLC 2244 WALNUT GROVE AVENUE 201 SOUTH LAKE AVE., SUITE 400 ROSEMEAD, CA 91770 PASADENA, CA 91101 CASE ADMINISTRATION MELISSA HOVSEPIAN AMBER WYATT SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. 2244 WALNUT GROVE AVE. / PO BOX 800 ROSEMEAD, CA 91770 ROSEMEAD, CA 91770 RICH METTLING GREG BASS SOUTHERN CALIFORNIA EDISON COMPANY NOBLE AMERICAS ENERGY SOLUTIONS LLC 2244 WALNUT GROVE AVENUE 401 WEST A STREET, SUITE 500 ROSEMEAD, CA 91770 SAN DIEGO, CA 92101-3017 JOHN A. PACHECO WENDY KEILANI ATTORNEY REGULATORY CASE MGR SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 101 ASH STREET, HQ12B 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92101-3017 SAN DIEGO, CA 92123 CENTRAL FILES RORY COX SAN DIEGO GAS AND ELECTRIC COMPANY RATEPAYERS FOR AFFORDABLE CLEAN ENERGY 8330 CENTURY PARK CT, CP32D, RM CP31-E 251 KEARNY STREET, 2ND FLOOR SAN DIEGO, CA 92123-1530 SAN FRANCISCO, CA 94102 FOR: PACIFIC ENVIRONMENT CHARLYN A. HOOK KAREN P. PAULL CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION LEGAL DIVISION ROOM 4107 ROOM 4300 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: DIVISION OF RATEPAYER ADVOCATES FOR: DRA MARCEL HAWIGER ALEX BECK ENERGY ATTY COMPETITIVE POWER VENTURES, INC. THE UTILITY REFORM NETWORK 55 2ND STREET, SUITE 525 115 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94104 ALICE GONG CASE COORDINATION PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE ST. MC B9A 77 BEALE ST., PO BOX 770000 MC B9A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 CHRISTINE MUNCE EVAN HOUSE PACIFIC GAS AND ELECTRIC COMPANY GOLDEN GATE UNIVERSITY SCHOOL OF LAW 77 BEALE ST., MC B9A 536 MISSION STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 GEORGE ZAHARIUDAKIS GLORIA D. SMITH PACIFIC GAS AND ELECTRIC COMPANY SIERRA CLUB ENVIRONMENTAL LAW PROGRAM 77 BEALE STREET, RM. 904, MC B9A 85 SECOND STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105
Page 6 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
KAREN TERRANOVA KEVIN HIETBRINK ALCANTAR & KAHL PACIFIC GAS AND ELECTRIC COMPANY 33 NEW MONTGOMERY STREET, SUITE 1850 77 BEALE ST., MC B9A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 KIMBERLY C. JONES LUCAS WILLIAMS PACIFIC GAS AND ELECTRIC COMPANY GOLDEN GATE UNIVERSITY SCHOOL OF LAW 77 BEALE STREET, MC B9A, ROOM 904 536 MISSION STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: PACIFIC ENVIRONMENT MATTHEW GONZALES MICHAEL P. ALCANTAR PACIFIC GAS AND ELECTRIC COMPANY ALCANTAR & KAHL LLP 77 BEALE STREET, ROOM 918 33 NEW MONTGOMERY STREET, SUITE 1850 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: COGENERATION ASSOCIATION OF CALIFORNIA WILLIAM MITCHELL ADAM BROWNING COMPETITIVE POWER VENTURES, INC. THE VOTE SOLAR INITIATIVE 55 2ND STREET, SUITE 525 300 BRANNAN STREET, SUITE 609 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94107 FOR: THE VOTE SOLAR INITIATIVE STEPHANIE WANG DEVIN MCDONELL ATTORNEY AT LAW BINGHAM MCCUTHCHEN PACIFIC ENVIRONMENT THREE EMBARCADERO CENTER 251 KEARNY STREET, 2ND FLOOR SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94108 FOR: PACIIFIC ENVIRONMENT JAMES D. SQUERI, ESQ. JAMES L. FILIPPI GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY NEXTLIGHT RENEWABLE POWER, LLC 505 SANSOME STREET, SUITE 900 353 SACRAMENTO STREET, SUITE 2100 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: POWEREX CORPORATION RAFI HASSAN ROBERT GEX SUSQUEHANNA FINANCIAL GROUP, LLLP DAVIS WRIGHT TREMAINE LLP 101 CALIFORNIA STREET, SUITE 3250 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 TODD EDMISTER DIANE I. FELLMAN ATTORNEY AT LAW DIR - REGULATORY & GOV'T AFFAIRS BINGHAM MCCUTCHEN LLP NRG WEST & SOLAR THREE EMBARCADERO CENTER 73 DOWNEY STREET SAN FRANCISCO, CA 94111-4067 SAN FRANCISCO, CA 94117 CALIFORNIA ENERGY MARKETS REGULATORY FILE ROOM 425 DIVISADERO ST. STE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94117-2242 PO BOX 7442 SAN FRANCISCO, CA 94120 RYAN HEIDARI BRAD WETSTONE ENDIMENSIONS LLC ALAMEDA MUNICIPAL POWER 1670 SOUTH AMPHLETT BLVD., SUITE 105 2000 GRAND STREET, PO BOX H SAN MATEO, CA 94402 ALAMEDA, CA 94501-0263 GOPAL SHANKER SEAN P. BEATTY PRESIDENT GENON CALIFORNIA NORTH LLC RECOLTE ENERGY 696 WEST 10TH STREET 3901 LAKE COUNTY HIGHWAY PITTSBURG, CA 94565 CALISTOGA, CA 94515
Page 7 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
FOR: RECOLTE ENERGY AVIS KOWALEWSKI MATTHEW BARMACK CALPINE CORPORATION DIR 4160 DUBLIN BLVD., SUITE 100 CALPINE CORPORATION DUBLIN, CA 94568 4360 DUBLIN BLVD., SUITE 100 DUBLIN, CA 94568 REN ORANS DOCKET COORDINATOR E3 KEYES & FOX LLP 101 MONTGOMERY STREET, STE. 1600 436 14TH STREET, SUITE 1305 SAN FRANCISCO, CA 94611 OAKLAND, CA 94612 SKY C. STANFIELD DAVID MARCUS KEYES & FOX LLP ADAMS BROADWELL & JOSEPH 436 14TH STREET, SUITE 1305 PO BOX 1287 OAKLAND, CA 94612 BERKELEY, CA 94701-1287 REED V. SCHMIDT PATRICK G. MCGUIRE BARTLE WELLS ASSOCIATES CROSSBORDER ENERGY 1889 ALCATRAZ AVENUE 2560 NINTH STREET, SUITE 316 BERKELEY, CA 94703-2714 BERKELEY, CA 94710 FOR: CALIFORNIA CITY-COUNTY STREET LIGHT ASSOCIATION (CAL-SLA) ELIZABETH RASMUSSEN PHILLIP MULLER PROJECT MGR. SCD ENERGY SOLUTIONS MARIN ENERGY AUTHORITY 436 NOVA ALBION WAY 781 LINCOLN AVENUE, SUITE 320 SAN RAFAEL, CA 94903 SAN RAFAEL, CA 94901 BRUCE PERLSTEIN, PH.D BARBARA GEORGE MANAGING DIRECTOR WOMEN'S ENERGY MATTERS STRATEGY, FINANCE & ECONOMICS, LLC PO BOX 548 366 EDGEWOOD AVENUE FAIRFAX, CA 94978-0548 MILL VALLEY, CA 94941 PUSHKAR WAGLE, PH.D. DEVRA WANG FLYNN RESOURCE CONSULTANTS INC. STAFF SCIENTIST 2900 GORDON AVENUE, SUITE 100-3 NATURAL RESOURCES DEFENSE COUNCIL SANTA CLARA, CA 95051 111 SUTTER STREET, 20TH FLOOR SAN FRANCISCO, CA 95104 BARRY F. MCCARTHY BARBARA R. BARKOVICH MCCARTHY & BERLIN, LLP 44810 ROSEWOOD TERRACE 100 WEST SAN FERNANDO ST., STE. 501 MENDOCINO, CA 95460 SAN JOSE, CA 95113 JAMES WEIL WILLIAM B. MARCUS DIRECTOR CONSULTING ECONOMIST AGLET CONSUMER ALLIANCE JBS ENERGY, INC. PO BOX 1916 311 D STREET, SUITE A SEBASTOPOL, CA 95473 WEST SACRAMENTO, CA 95605 BETH ANN BURNS BRIAN THEAKER SR. COUNSEL - LEGAL & REGULATORY DEPT NRG ENERGY CALIFORNIA ISO 3161 KEN DEREK LANE 250 OUTCROPPING WAY PLACERVILLE, CA 95667 FOLSOM, CA 95630 MARY LYNCH GRANT ROSENBLUM CONSTELLATION ENERGY COMMODITIES GRP CALIF. INDEPENDENT SYSTEM OPERATOR CORP. 2377 GOLD MEADOW WAY, STE 100 151 BLUE RAVINE ROAD GOLD RIVER, CA 95670 FOLSOM, CA 95678
Page 8 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
MARK ROTHLEDER UDI HELMAN CALIF. INDEPENDENT SYSTEM OPERATOR CORP. CALIF. INDEPENDENT SYSTEM OPERATOR CORP. 151 BLUE RAVINE ROAD 151 BLUE RAVINE ROAD FOLSOM, CA 95678 FOLSOM, CA 95678 RAY PINGLE DANIEL KIM 7140 STEEPLE CHASE DR. THE ANTHEM GROUP SHINGLE SPRINGS, CA 95682 PO BOX 582844 ELK GROVE, CA 95758-0051 DANIELLE OSBORN MILLS DAVID MILLER POLICY DIRECTOR RENEWABLE TECHNOLOGIES CEERT CENTER FOR ENERGY EFFICIENCY AND 1100 11TH STREET, SUITE 311 1100 ELEVENTH ST., SUITE 311 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE TECHNOLOGIES (CEERT) DOUGLAS DAVIE GWENNETH O'HARA WELLHEAD ELECTRIC COMPANY CALIFORNIA POWER LAW GROUP 650 BERCUT DRIVE, SUITE C 1215 K STREET, 17TH FLOOR SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 JIM METROPULOS KEVIN WOODRUFF SR. ADVOCATE WOODRUFF EXPERT SERVICES SIERRA CLUB CALIFORNIA 1100 K STREET, SUITE 204 801 K STREET, SUITE 2700 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 MEGAN COX SCOTT BLAISING CALIFORNIA POWER LAW GROUP BRAUN BLAISING MCLAUGHLIN, P.C. 1215 K STREET, 17TH FLOOR 915 L STREET, SUITE 1270 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 SHANNON EDDY ASHLEY SPALDING EXECUTIVE DIRECTOR ASPEN ENVIRONMENTAL GROUP LARGE SCALE SOLAR ASSOCIATION 8801 FOLSOM BLVD., STE. 290 2501 PORTOLA WAY SACRAMENTO, CA 95826-3250 SACRAMENTO, CA 95818 FOR: LARGE-SCALE SOLAR ASSOCIATION CARL LINVILL ANN L. TROWBRIDGE ASPEN ENVIRONMENTAL GROUP ATTORNEY AT LAW 8801 FOLSOM BLVD., STE. 290 DAY CARTER MURPHY LLC SACRAMENTO, CA 95826-3250 3620 AMERICAN RIVER DRIVE, SUITE 205 SACRAMENTO, CA 95864 FOR: CALIFORNIA CLEAN DG COALITION. DIANA SANCHEZ JACK ELLIS DAY CARTER & MURPHY LLP PO BOX 6600/1425 ALPINE WAY 3620 AMERICAN RIVER DRIVE, STE. 205 TAHOE CITY, CA 96145 SACRAMENTO, CA 95864 CALIFORNIA PACIFIC ELECTRIC COMPANY, LLC ANNIE STANGE 933 ELOISE AVENUE ALCANTAR & KAHL LLP SOUTH LAKE TAHOE, CA 96150 1300 SW FIFTH AVE., SUITE 1750 PORTLAND, OR 97201 DONALD W. SCHOENBECK JOHN DUNN RCS, INC. TRANSCANADA CORPORATION 900 WASHINGTON STREET, SUITE 780 450 1ST ST. S.W. VANCOUVER, WA 98660 CALGARY, AB T2P 5H1 CANADA
Page 9 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
MEREDITH LAMEY DANIEL JURIJEW TRANSCANADA CORPORATION SR. MGR - REGULATORY AFFAIRS WEST 450 1ST STREET S.W. CAPITAL POWER CORPORATION CALGARY, AB T2P 5H1 10065 JASPER AVENUE CANADA EDMONTON, AB T5J 3B1 CANADA FOR: CAPITAL POWER CORPORATION SHAUN PILLOTT GIFFORD JUNG REG. AFFAIRS WEST-SENIOR ADVISOR POWEREX CORPORATION CAPITAL POWER CORPORATION 666 BURRARD STREET, SUITE 1400 10065 JASPER AVENUE VANCOUVER, BC V5R 4Y2 EDMONTON, AB T5J 3B1 CANADA CANADA FOR: POWEREX CORPORATION
ANNE GILLETTE CHERYL LEE CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 SARA KAMINS CONNIE LENI CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA ENERGY COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000-0000 JAMES ROSS ARAM SHUMAVON RCS INC. CALIF PUBLIC UTILITIES COMMISSION 500 CHESTERFIELD CENTER, SUITE 320 ENERGY DIVISION CHESTERFIELD, MO 63017 AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 BISHU CHATTERJEE CHLOE LUKINS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4101 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 DAVID PECK DIANA L. LEE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH LEGAL DIVISION ROOM 4103 ROOM 4107 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: DRA JASON SIMON JORDAN PARRILLO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4104 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 KARL MEEUSEN KE HAO OUYANG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5217 ROOM 4104 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214
State Service
Page 10 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
LILY CHOW MARY JO STUEVE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4101 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 MEGHA LAKHCHAURA MICHAEL COHEN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4102 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 NATHANIEL SKINNER NIKA ROGERS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4101 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 PAUL DOUGLAS PETER SPENCER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4104 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 PETER V. ALLEN REBECCA TSAI-WEI LEE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION ENERGY DIVISION ROOM 5031 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 ROBERT L. STRAUSS SEAN A. SIMON CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ENERGY DIVISION AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 WILLIAM DIETRICH YULIYA SHMIDT DRA-ELECTRICITY PRICING & CUST. PROGRAMS CALIF PUBLIC UTILITIES COMMISSION CPUC ELECTRICITY PLANNING & POLICY BRANCH 505 VAN NESS AVE., RM. 4101 ROOM 4104 SAN FRANCISCO, CA 94102-3214 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 CLARE LAUFENBER GALLARDO JIM WOODWARD STRATEGIC TRANSMISSION INVESTMNT PROGRAM CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS 20 1516 NINTH STREET, MS 17 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 LISA DECARLO MICHAEL JASKE STAFF COUNSEL CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS-39 1516 9TH STREET MS-14 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 MICHAEL NYBERG IVIN RHYNE CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION PROCUREMENT UNIT, ELECTRICITY ANALYSIS 1516 9TH STREET, MS 20
Page 11 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm
1516 NINTH STREET, MS-20 SACRAMENTO, CA 95814-5512 SACRAMENTO, CA 95814
TOP OF PAGE BACK TO INDEX OF SERVICE LISTS
Page 12 of 12CPUC - Service Lists - R1005006
6/17/2011http://docs.cpuc.ca.gov/published/service_lists/R1005006_79130.htm