SCE - Document Library - Advice Letter 3871-E SUBJECT: … · 2021. 1. 7. · October 1, 2012, SCE submitted Advice 2783-E, which included data for 2012 and forecasted data for 2013,

STATE OF CALIFORNIA GAVIN NEWSOM, Governor

PUBLIC UTILITIES COMMISSION

505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102-3298

May 10, 2019

Advice Letter 3871-E

Gary A. Stern

Director, State Regulatory Operations

Southern California Edison Company

8631 Rush Street

Rosemead, CA 91770

SUBJECT: Submittal of Relevant Data for Determination of the Renewables

Portfolio Standard Adder Component of the Market Price Benchmark

Dear Mr. Stern:

Advice Letter 3871-E is withdrawn as requested per your letter dated March 26, 2019.

Sincerely,

Edward Randolph

Deputy Executive Director for Energy and Climate Policy/

Director, Energy Division

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations

P.O. Box 800 8631 Rush Street Rosemead, California 91770 (626) 302-9645 FAX (626) 302-6396

March 26, 2019 Energy Division Attn: Tariff Unit California Public Utilities Commission 505 Van Ness Avenue San Francisco, California 94102

Re:

Withdrawal of Southern California Edison Company’s Advice 3871-E

Dear Energy Division Tariff Unit: Pursuant to conversations with Energy Division staff, Southern California Edison Company (SCE) is requesting the withdrawal of Advice 3871-E, Submittal of Relevant Data for Determination of the Renewables Portfolio Standard Adder Component of the Market Price Benchmark.1 SCE is requesting this withdrawal because, pursuant to Decision 18-10-019, the data provided in the advice letter is no longer necessary for the Renewable Portfolio Standard Adder Component of the Market Price Benchmark. SCE submits this request for withdrawal in accordance with General Order (GO) 96-B, General Rule 5.3. SCE asks that a confirmation letter be returned regarding this withdrawal.

Should you have any questions, please contact me.

Sincerely, /s/ Gary A. Stern, Ph.D./s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D.

GAS:dm:jm Copy: Edward Randolph, Director, CPUC Energy Division

Kathleen Blake, CPUC Energy Division Service Lists GO 96-B and R.07-05-025

1 Advice 3871-E was submitted on October 1, 2018.

ADVICE LETTER (AL) SUSPENSION NOTICE

ENERGY DIVISION

* Note: reference – Decision D.02-02-049, dated February 21, 2002, and Rule 7.5 in appendix A of D.07-01-024

Utility Name: Southern California Edison

Company

Utility Number/Type: U 338-E

Advice Letter Number(s): 3871-E

Date AL(s) Filed: October 1, 2018

Utility Contact Person: Darrah Morgan

Utility Phone No.: (626) 302-2086

Date Utility Notified October 30, 2018

[ ] E-Mailed to: [email protected]

ED Staff Contact: Kathleen Blake

ED Staff Email: [email protected]

ED Staff Phone No.: (415) 703-3444

[X] INITIAL SUSPENSION (up to 120 DAYS from the expiration of the initial review period)

This is to notify that the above-indicated AL is suspended for up to 120 days beginning October 31,

2018 for the following reason(s) below. If the AL requires a Commission resolution and the

Commission’s deliberation on the resolution prepared by Energy Division extends beyond the

expiration of the initial suspension period, the advice letter will be automatically suspended for up to

180 days beyond the initial suspension period.

[ ] A Commission Resolution is Required to Dispose of the Advice Letter

[ ] Advice Letter Requests a Commission Order

[X] Advice Letter Requires Staff Review

The expected duration of initial suspension period is 120 days

[ ] FURTHER SUSPENSION (up to 180 DAYS beyond initial suspension period)

The AL requires a Commission resolution and the Commission’s deliberation on the resolution

prepared by Energy Division has extended beyond the expiration of the initial suspension period. The

advice letter is suspended for up to 180 days beyond the initial suspension period.

_____________________________________________

If you have any questions regarding this matter, please contact Kathleen Blake at

[email protected].>

cc:

EDTariffUnit

mailto:[email protected]

P.O. Box 800 8631 Rush Street Rosemead, California 91770 (626) 302-9645 Fax (626) 302-6396

October 1, 2018

ADVICE 3871-E (U 338-E)

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION

SUBJECT: Submittal of Relevant Data for Determination of the Renewables Portfolio Standard Adder Component of the Market Price Benchmark

Southern California Edison Company (SCE) hereby submits data to the Energy Division in compliance with Resolution E-4475.

PURPOSE

SCE herein submits for purposes of determining the Renewables Portfolio Standard (RPS) Adder, data pursuant to Ordering Paragraph (OP) 4 of Resolution E-4475. RPS-compliant resource cost data is included in the confidential version of this advice letter, and redacted in the public version.

BACKGROUND

Decision (D.)11-12-018 resolved Phase III issues in Rulemaking (R.)07-05-025 and addressed modifications to the calculation of the indifference amount, switching rules, financial security requirements for Energy Service Providers (ESPs), and handling of involuntary returns of Direct Access customers to bundled service. A California Public Utilities Commission (Commission) decision resolving Track 2 of the Power Charge Indifference Adjustment (PCIA) Order Instituting Rulemaking (OIR), R.17-06-026, is expected to be issued on or about October 11, 2018. Both the Proposed Decision and Alternate Proposed Decision issued in this proceeding would modify inputs for the green market price benchmark and the Resource Adequacy capacity value, as compared to the current market price benchmark methodology. Consequently, the data provided in this advice letter will be superseded by regulatory events in the PCIA OIR once a final decision has been issued.

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations

ADVICE 3871-E (U 338-E) - 2 - October 1, 2018

RPS-COMPLIANT RESOURCE DATA OP 4 of D.11-12-018 required that Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), and SCE each submit a Tier 2 advice letter with the Energy Division within 30 calendar days following the issuance of D.11-12-018, providing the data necessary to revise the PCIA, Competition Transition Charge (CTC), and Transitional Bundled Service tariffs, in accordance with the decision. For purposes of the RPS Adder, each Investor-Owned Utility (IOU) was required to provide:

a. Most recent 12 months figures derived from United States (US) Department of Energy (DOE) survey of Western US renewable energy premiums in calculating a weighted proxy for the Market Price Benchmark (MPB) compiled by the National Renewable Energy Laboratory (NREL). This data is used to set the DOE Green Adder portion of the MPB; and

b. All RPS-compliant resources that are used to serve IOU customers during the next year that began deliveries in the current year (i.e., 2018) or are forecast to begin deliveries during the next year (i.e., 2019), including the projected costs together with the net qualifying capacity (NQC) and energy produced by each of these resources (providing relevant costs in dollars and volumes in MWh and qualifying capacity in kW). Confidential data submitted to the Energy Division will be protected from public disclosure. This data is used to set the IOU RPS Premium portion of the MPB.

SCE complied with the data submittal requirement by submitting Advice 2688-E on January 6, 2012, which included data for both 2011 and 2012. Resolution E-4475, OP 4, established that there would be an annual update on October 1 of each year of the RPS-compliant resources and the DOE renewable energy premium. On October 1, 2012, SCE submitted Advice 2783-E, which included data for 2012 and forecasted data for 2013, on October 1, 2013, SCE submitted Advice 2944-E, which included data for 2013 and forecasted data for 2014, on October 1, 2014, SCE submitted Advice 3111-E, which included data for 2014 and forecasted data for 2015, and on October 1, 2015, SCE submitted Advice 3280-E which included data for 2015 and forecasted data for 2016. SCE filed Advice 3484-E which included data for 2016 and forecasted data for 2017 and SCE submitted Advice 3667-E which included data for 2017 and forecasted data for 2018. SCE herein submits the data required in OP 4 which includes data for 2018 and forecasted data for 2019. DOE Green Adder: DOE Renewable Premium for Voluntary Programs in the Western US Pursuant to D.11-12-018 and Resolution E-4475, the “DOE Green Adder” portion of the Renewable MPB should be determined using “the most recent DOE index figure” or a simple average of the “figures of reported contract premiums for renewable energy in


the Western U.S.”1 (DOE premium values). Attachment A to this advice letter includes the most recently published list of “voluntary” programs compiled by NREL for the DOE (NREL-published list).2 The table includes only those programs offered in Western Electricity Coordinating Council (WECC) member states that provide an identified $/kWh DOE premium value. SCE determines the 2019 DOE Green Adder to be $16.64 per MWh, which is equivalent to the 2018 value approved by the Commission in Advice 3667-E and is the most recently approved data that was officially published on the NREL website. IOU RPS Premium: RPS-Compliant Resource Data Attachment B to this advice letter includes confidential and non-confidential data for specific RPS-compliant resources serving bundled service SCE load. Attachment B also includes the Confidentiality Declaration. For the IOU RPS Premium, SCE first determines the portfolio of renewable generation resources which either: (1) first begin serving bundled service load in the current year (i.e., 2018), or (2) are forecast to begin serving load in the forecast year (i.e., 2019). Attachment B includes a listing of each generation resource that meets the criteria described above, the total energy (MWh) forecast to be supplied by each resource in the forecast year, the forecasted cost ($000) of the energy provided by the resource, and the NQC (MW) for each resource.3 The forecasted cost data for each resource is redacted in the public version of this advice letter. Resource Adequacy (RA) Capacity Adder The MPB methodology adopted in D.06-07-030 includes a capacity adder of 0.7 cents per kWh for SCE. D.11-12-018 adopted a proposal by SCE to update the capacity adder component of the MPB based on the most current calculation by the California Energy Commission (CEC) of the going-forward cost of a combustion turbine. Advice 2783-E, Advice 2944-E, and Advice 3111-E all proposed that the RA Capacity Adder be

1 D.11-12-018 at p. 23. 2 SCE accessed Http://apps3.eere.energy.gov/greenpower/markets/pricing.shtml?page=1 on

September 12, 2016 for purposes of submitting Advice 3484-E. 3 Resources that have not yet been assigned a California Independent System Operator

(CAISO) ID and corresponding NQC are assumed to have an NQC of 0 in Attachment B. Pursuant to D.11-12-018 and Resolution E-4475, the total forecasted cost of the resources included in Attachment B is first reduced by the “value of NQC” (i.e., NQC multiplied by the capacity benchmark), then divided by the forecasted energy to calculate the IOU RPS Premium. As such, all else being equal, assuming an NQC of 0 for all resources without a CAISO ID has the effect of increasing the IOU RPS Premium. SCE has utilized this assumption in all of its previous advice letters.


$50.17 based on the going-forward fixed cost components for a small simple cycle merchant plant from the CEC’s “Comparative Costs of California Central Station Electricity Generation - Final Staff Report,” issued January 2010.4 On March 9, 2015, the CEC released the “Estimated Cost of New Renewable and Fossil Generation in California Final Staff Report,” which included an update to the going-forward cost of a combustion turbine. Attachment C to this advice letter includes the Mid Case Component Levelized Cost of Equity for a small simple cycle (Generation Turbine – 49.9 MW) merchant plant from the report. Based on the data provided, SCE calculates an RA Capacity Adder of $58.27 per kW-year.5 TIER DESIGNATION

Pursuant to Resolution E-4475, this advice letter is submitted with a Tier 1 designation.

EFFECTIVE DATE

This advice letter will become effective on October 1, 2018, the date of advice letter.

NOTICE

Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to:

CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: [email protected]

Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above).

In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of:

4 http://www.energy.ca.gov/2009publications/CEC‐200‐2009‐017/CEC‐200‐2009‐017‐

SF.PDF (Page B‐5). 5 http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-

03/TN203798_20150309T154237_Estimated_Cost_of_New_Renewable_and_Fossil_Generation_in_Califo.pdf (Page E-5).


Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770

Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: [email protected] Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: [email protected]

There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above.

In accordance with General Rule 4 of General Order (GO) 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and R.07-05-025 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to [email protected] or at (626) 302-4039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at [email protected].

Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters.

For questions, please contact Alexander Echele at (626) 302-4856 or by electronic mail at [email protected].

Southern California Edison Company

/s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D.

GAS:ae:jm Enclosures

ADVICE LETTER S U M M A R YENERGY UTILITY

Company name/CPUC Utility No.:

Utility type:Phone #:

EXPLANATION OF UTILITY TYPE

ELC GAS

PLC HEAT

MUST BE COMPLETED BY UTILITY (Attach additional pages as needed)

Advice Letter (AL) #:

WATERE-mail: E-mail Disposition Notice to:

Contact Person:

ELC = ElectricPLC = Pipeline

GAS = GasHEAT = Heat WATER = Water

(Date Submitted / Received Stamp by CPUC)

Subject of AL:

Tier Designation:

Keywords (choose from CPUC listing):AL Type: Monthly Quarterly Annual One-Time Other:If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:

Does AL replace a withdrawn or rejected AL? If so, identify the prior AL:

Summarize differences between the AL and the prior withdrawn or rejected AL:

Confidential treatment requested? Yes NoIf yes, specification of confidential information:Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information:

Resolution required? Yes No

Requested effective date: No. of tariff sheets:

Estimated system annual revenue effect (%):

Estimated system average rate effect (%):

When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting).

Tariff schedules affected:

Service affected and changes proposed1:

Pending advice letters that revise the same tariff sheets:

1Discuss in AL if more space is needed.

CPUC, Energy DivisionAttention: Tariff Unit505 Van Ness AvenueSan Francisco, CA 94102 Email: [email protected]

Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx:Facsimile (xxx) xxx-xxxx:Email:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx:Email:

Zip:

Zip:

mailto:EDTariffUnit%40cpuc.ca.gov?subject=

ENERGY Advice Letter Keywords

Affiliate Direct Access Preliminary StatementAgreements Disconnect Service ProcurementAgriculture ECAC / Energy Cost Adjustment Qualifying FacilityAvoided Cost EOR / Enhanced Oil Recovery RebatesBalancing Account Energy Charge RefundsBaseline Energy Efficiency ReliabilityBilingual Establish Service Re-MAT/Bio-MATBillings Expand Service Area Revenue AllocationBioenergy Forms Rule 21Brokerage Fees Franchise Fee / User Tax RulesCARE G.O. 131-D Section 851CPUC Reimbursement Fee GRC / General Rate Case Self GenerationCapacity Hazardous Waste Service Area MapCogeneration Increase Rates Service OutageCompliance Interruptible Service SolarConditions of Service Interutility Transportation Standby ServiceConnection LIEE / Low-Income Energy Efficiency StorageConservation LIRA / Low-Income Ratepayer Assistance Street LightsConsolidate Tariffs Late Payment Charge SurchargesContracts Line Extensions TariffsCore Memorandum Account TaxesCredit Metered Energy Efficiency Text ChangesCurtailable Service Metering TransformerCustomer Charge Mobile Home Parks Transition CostCustomer Owned Generation Name Change Transmission LinesDecrease Rates Non-Core Transportation ElectrificationDemand Charge Non-firm Service Contracts Transportation RatesDemand Side Fund Nuclear UndergroundingDemand Side Management Oil Pipelines Voltage DiscountDemand Side Response PBR / Performance Based Ratemaking Wind PowerDeposits Portfolio Withdrawal of ServiceDepreciation Power Lines

Attachment A

NREL Website Sep 2016State Utility Information Enrollment Information Type Start Date Premium Premium (cents/kWh)

AZ Arizona Public Service Green Choice wind, biomass, landfill gas, geothermal, and solar 2007 1.02¢/kWh 1.02AZ Salt River Project EarthWise Energy PV for non-profits 1998/2001 Contribution NA

AZTri-State Generation & Transmission: Columbus Electric Cooperative, Inc.

Renewable Resource Power Rider wind, hydro 2001 1.25¢/kWh 1.25

AZ Tucson Electric Bright Tucson Community Solar Program local PV 2010 2.0¢/kWh 2.00AZ UniSource Energy Services Bright Arizona Community Solar Program local PV 2004 2.0¢/kWh 2.00CA Alameda Municipal Power Alameda Green wind, solar 2012 1.5¢/kWh 1.50CA Anaheim Public Utilities Green Power Program various renewables 2002 2.0¢/kWh 2.00CA Anaheim Public Utilities Sun Power for the Schools PV 2002 Contribution NACA Los Angeles Department of Water and Power Green Power for a Green LA wind, hydro and PV 1999 3.0¢/kWh 3.00

CAMarin Clean Energy: City of Belvedere, Town of Fairfax, County of Marin, City of Mill Valley, Town of San Anselmo, City of San Rafael, City of Sausalito, Town of Tiburon

Local Sol 100% local solar 2014 6.0¢/kWh 6.00


Light Green 50% renewable 2008 0.0¢/kWh 0.00


Deep Green 100% renewable 2010 1.0¢/kWh 1.00

CA PacifiCorp: Pacific Power Blue Sky Block wind 2000 1.95¢/kWh 1.95CA Pasadena Water & Power Green Power wind 2003 2.5¢/kWh 2.50CA Roseville Electric Green Roseville wind, PV 2005 0.5¢/kWh 0.50CA Sacramento Municipal Utility District SolarShares PV 2007 $10.75/mo 1.79CA Sacramento Municipal Utility District Greenergy 100% wind, PV, landfill gas, hydro, geothermal 1997 $6/month 1.00CA Silicon Valley Power / 3Degrees Santa Clara Green Power wind, PV 2004 1.5¢/kWh 1.50CA Sonoma Clean Power Clean Start 36% biomass, geothermal, wind 2014 0.0¢/kWh 0.00CA Sonoma Clean Power Evergreen 100% geothermal 2014 3.5¢/kWh 3.50CA Southern California Edison Green Rate 50% and 100% local solar 2015 3.5¢/kWh 3.50CO Colorado Springs Utilities Renewable Energy Certificates Program wind and geothermal 2008 0.34¢/kWh 0.34CO Colorado Springs Utilities Green Power wind 1999 3.0¢/kWh 3.00CO Holy Cross Energy Wind Power Pioneers wind 1998 0.5¢/kWh-1.25¢/kWh 0.88CO Holy Cross Energy Local Renewable Energy Pool small hydro 2002 2.33¢/kWh 2.33

COPlatte River Power Authority: Estes Park, Fort Collins Utilities, Longmont Power & Communications, Loveland Water & Power

Nature's Energy wind 1999 1.3¢/kWh-2.96¢/kWh 2.13

CO

Tri-State Generation & Transmission : Delta-Montrose Electric Association, Empire Electric Association, Inc., Gunnison County Electric Association, Inc., Highline Electric Association, La Plata Electric Association, Inc., Morgan County Rural Electric Association, Mountain Parks Electric, Inc., Mountain View Electric Association, Inc., Poudre Valley Rural Electric Association, Inc., San Isabel Electric Association, Inc., San Luis Valley Rural Electric Cooperative, Inc., San Miguel Power Association, Inc., Sangre de Cristo Electric Association, Inc., Southeast Colorado Power Association, United Power, Inc., White River Electric Association, Inc., Y-W Electric Association, Inc.

Green Power Program wind, solar, and hydro 1998 0.09¢/kWh 0.09

CO Xcel Energy WindSource wind 1997 2.16¢/kWh 2.16CO Yampa Valley Electric Association Green Power Options wind and solar 1999 0.6¢/kWh 0.60ID Avista Utilities Buck-A-Block wind, solar and biomass 2002 0.35¢/kWh 0.35ID Idaho Power Green Power Program wind 2001 ContributionID PacifiCorp: Rocky Mountain Power Blue Sky wind 2003 1.95¢/kWh 1.95ID Vigilante Electric Cooperative Alternative Renewable Energy Program wind 2003 1.1¢/kWh 1.10

State Specific Utility Green Pricing Programs. Western US Only.Accessed on 9/12/2016 and used in SCE Advice Letter 3667-E.

State Specific Utility Green Pricing Programs




MTBasin Electric Power Cooperative: Flathead Electric Coop, Lower Yellowstone, Powder River Energy

Prairie Winds wind 2000 varies by utillity NA

MT Northwestern Energy E+ Green wind, PV 2003 2.0¢/kWh 2.00MT Park Electric Cooperative Green Power Program various renewables 2002 0.09¢/kWh 0.09

MTTri-State Generation & Transmission: Big Horn Rural Electric Company

Renewable Resource Power Service wind, hydro 2001 1.25¢/kWh 1.25

MT Vigilante Electric Cooperative Alternative Renewable Energy Program wind 2003 1.1¢/kWh 1.10NV Deseret Power: Mt. Wheeler Power Cooperative GreenWay various 2005 1.95¢/kWh 1.95

NV NV EnergyDesert Research Institute's GreenPower Program

PV on schools Unknown Contribution NA

NV NV Energy NV Green Energy Rate 50% or 100% renewables 2013 varies quarterly NANM El Paso Electric Company Renewable Energy Tariff solar, wind, geothermal, hydro and biomass 2003 5.84¢/kWh 5.84NM Los Alamos Department of Public Utilities LA Green wind, solar and hydro 2013 0.5¢/kWh 0.50NM Public Service of New Mexico PNM Sky Blue solar and wind 2003 1.7¢/kWh 1.70

NM

Tri-State Generation & Transmission: Central New Mexico Electric Cooperative, Inc., Columbus Electric Cooperative, Inc., Continental Divide Electric Cooperative, Inc., Jemez Mountains Electric Cooperative, Inc., Kit Carson Electric Cooperative, Inc., Mora-San Miguel Electric Cooperative, Inc., Navopache Electric Cooperative, Northern Rio Arriba Electric Cooperative, Otero County Electric Cooperative, Inc., Sierra Electric Cooperative, Inc., Socorro Electric Cooperative, Inc., Southwestern Electric Cooperative, Inc., Springer Electric Cooperative, Inc.

Renewable Resource Power Service wind, hydro 2001 varies by utility Varies by Utility

NM Xcel Energy WindSource wind 1999 4.12¢/kWh 4.121.5 City of Ashland / Bonneville Environmental Foundation Renewable Pioneers PV, wind 2003 2.0¢/kWh 2.00OR Columbia River PUD Choice Energy wind 2005 1.5¢/kWh 1.50OR Emerald People's Utility District GREEN for Homes wind and landfill gas 2011 0.8¢/kWh 0.80OR Eugene Water & Electric Board EWEB Greenpower various renewables 2007 1.0¢/kWh-1.5¢/kWh 1.25OR Idaho Power Green Power Program wind 2001 Contribution NAOR Midstate Electric Cooperative Environmentally-Preferred Power wind 1999 2.5¢/kWh 2.50OR Oregon Trail Electric Cooperative Green Power wind 2002 1.5¢/kWh 1.50

OR

Pacific Northwest Generating Cooperative: Blachly-Lane Electric Cooperative, Central Electric Cooperative, Clearwater Power, Consumers Power, Coos-Curry Electric Cooperative, Douglas Electric Cooperative, Fall River Rural Electric Cooperative, Lost River Electric Cooperative, Raft River Rural Electric Cooperative, Umatilla Electric Cooperative, West Oregon Electric Cooperative, (11 of 15 coops offer program)

Green Power landfill gas 1998 1.8¢/kWh-2.0¢/kWh 1.90

OR PacifiCorp: Pacific Power Blue Sky QS (Commercial Only) wind 2004 Sliding scale depending on size NAOR PacifiCorp: Pacific Power Blue Sky Block wind 2000 1.95¢/kWh 1.95OR Portland General Electric / Green Source wind, landfill gas, low-impact hydro 2002 0.8¢/kWh 0.80

OR Portland General Electric /Clean Wind for Medium to Large Commercial & Industrial Accounts

wind 2002 0.3¢/kWh 0.30

OR Portland General Electric / Clean Wind wind 2002 1.25¢/kWh 1.25OR Springfield Utility Board ECOchoice various 2007 1.0¢/kWh 1.00UT City of St. George Clean Green Power wind, small hydro 2005 2.95¢/kWh 2.95

UTDeseret Power: Bridger Valley Electric, Dixie Escalante Rural Electric, Flowell Electric, Garkane Energy, Moon Lake Electric, Mt. Wheeler Power

GreenWay various 2004 1.95¢/kWh 1.95

UT PacifiCorp: Rocky Mountain Power Blue Sky wind 2003 1.95¢/kWh 1.95UT PacifiCorp: Utah Power Blue Sky wind 2000 1.95¢/kWh 1.95




UTTri-State Generation & Transmission: Empire Electric Association, Inc.

Renewable Resource Power Service wind, hydro 2001 1.25¢/kWh 1.25

WA Avista Utilities Buck-A-Block wind, solar and biomass 2002 0.35¢/kWh 0.35WA Benton County Public Utility District Green Power Program landfill gas, wind, hydro 1999 Contribution NA

WA Chelan County PUDSustainable Natural Alternative Power (SNAP)

PV, wind, micro hydro 2001 Contribution NA

WA Clallam County PUD Watts Green landfill gas 2001 1.7¢/kWh 1.70WA Clark Public Utilities Green Lights PV, wind 2002 1.5¢/kWh 1.50WA Cowlitz PUD/Bonneville Environmental Foundation Renewable Resource Energy wind, PV 2002 0.8¢/kWh 0.80WA Lewis County PUD Green Power Energy Rate wind 2003 2.0¢/kWh 2.00WA Mason County PUD No. 3 Mason Evergreen Power wind 2003 1.0¢/kWh 1.00WA Northen Wasco County PUD Pure Power wind 2007 2.5¢/kWh 2.50WA Orcas Power & Light Go Green wind, hydro 1999 4.0¢/kWh 4.00WA Pacific County PUD Green Power landfill gas 2002 1.05¢/kWh 1.95WA PacifiCorp: Pacific Power Blue Sky Block wind 2000 1.95¢/kWh 1.05WA Peninsula Light Renewable Option Program wind 2002 1.5¢/kWh 1.50WA Puget Sound Energy Green Power Program wind, hydro, biogas, solar 2002 1.25¢/kWh 1.25WA Seattle City Light Green Up geothermal, biomass, wind, hydro 2005 1.5¢/kWh 1.50WA Seattle City Light Seattle Green Power PV, biogas 2002 Contribution ContributionWA Snohomish County Public Utility District Planet Power wind 2002 Contribution ContributionWA Tacoma Power EverGreen Options wind 2000 1.2¢/kWh 1.20WY Basin Electric Power Cooperative: Powder River Energy Prairie Winds wind 2000 varies by utillity Varies by UtilityWY Black Hills Corporation Renewable Premium Program 99% new wind, 1% new solar 2006 1.24 NA

WYCheyenne Light, Fuel and Power Company/Bonneville Environmental Foundation

Renewable Premium Program 99% new wind, 1% new solar 2006 1.24¢/kWh 1.24

WY Lower Valley Energy Green Power wind 2003 1.2¢/kWh 1.20WY PacifiCorp: Pacific Power Blue Sky wind 2000 1.95¢/kWh 1.95WY Tri-State Generation & Transmission: Carbon Power & Light, Inc. Renewable Resource Power Service wind, hydro 2001 1.25¢/kWh 1.25WY Yampa Valley Electric Association Green Power Options wind and solar 1999 0.6¢/kWh 0.60

Average Cents/kWh 1.664Average $/MWh 16.64

Attachment B Public Version

Payments EnergyProject Number Project Name Online Date 2019 Costs ($000) 2019 Energy (MWh) Jan-19 Feb-19 Mar-19 Apr-19 May-19 Jun-19 Jul-19 Aug-19 Sep-19 Oct-19 Nov-19 Dec-19 Annual Average

3118 Geysers Power Company, LLC 1/1/2018 438,000 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.006372 Tule Wind LLC 1/12/2018 309,718 14.42 22.07 23.35 40.07 39.05 60.61 37.90 33.81 33.81 11.23 10.72 19.40 28.875819 Luz Solar Partners Ltd., V 2/1/2018 62,516 0.00 0.72 3.12 9.96 9.15 13.44 12.51 12.30 10.02 8.82 1.23 0.00 6.774226 Desert Water Agency (Snow Creek) 2/2/2018 436 0.07 0.11 0.11 0.19 0.19 0.29 0.18 0.16 0.16 0.05 0.05 0.09 0.145245 Re Gaskell West 1 3/23/2018 59,273 0.00 0.48 2.08 6.64 6.10 8.96 8.34 8.20 6.68 5.88 0.82 0.00 4.525226 Caliente Springs, LLC 5/18/2018 1,976 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.003106 Terra-Gen Dixie Valley, LLC 7/5/2018 417,852 57.13 57.83 57.06 54.62 53.64 48.55 54.95 54.30 53.57 49.73 56.93 56.82 54.595258 Green Beanworks C, LLC 8/21/2018 8,838 0.00 0.07 0.31 1.00 0.92 1.34 1.25 1.23 1.00 0.88 0.12 0.00 0.685268 Green Beanworks D, LLC 8/24/2018 8,611 0.00 0.07 0.31 1.00 0.92 1.34 1.25 1.23 1.00 0.88 0.12 0.00 0.685414 Neenach Solar 1B South, LLC 10/15/2018 4,662 0.00 0.04 0.16 0.50 0.46 0.67 0.63 0.62 0.50 0.44 0.06 0.00 0.345747 AVS Phase 2, LLC 11/6/2018 8,013 0.00 0.07 0.31 1.00 0.92 1.34 1.25 1.23 1.00 0.88 0.12 0.00 0.681251 Two Fiets 11/15/2018 4,290 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.005890 Calcity Solar I, LLC 11/16/2018 9,101 0.00 0.07 0.31 1.00 0.92 1.34 1.25 1.23 1.00 0.88 0.12 0.00 0.685178 Green Beanworks B, LLC 12/1/2018 8,610 0.00 0.07 0.31 1.00 0.92 1.34 1.25 1.23 1.00 0.88 0.12 0.00 0.685814 North Rosamond Solar, LLC 1/1/2019 502,553 0.00 3.84 16.64 53.12 48.80 71.68 66.72 65.60 53.44 47.04 6.56 0.00 36.125816 Panoche Valley Solar, LLC 1/1/2019 389,115 0.00 3.36 14.56 46.48 42.70 62.72 58.38 57.40 46.76 41.16 5.74 0.00 31.615892 CED Wistaria Solar, LLC 1/1/2019 307,088 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.006362 Rising Tree Wind Farm, LLC 1/1/2019 187,696 9.04 13.84 14.64 25.12 24.48 38.00 23.76 21.20 21.20 7.04 6.72 12.16 18.101247 Organic Energy Solutions Inc. 1/31/2019 8,260 1.45 1.49 1.40 1.22 1.41 1.50 1.48 1.50 1.47 1.38 1.41 1.46 1.431252 Central CA Fuel Cell 2, LLC 2/1/2019 20,311 2.53 2.60 2.45 2.14 2.47 2.62 2.59 2.63 2.56 2.41 2.47 2.56 2.505808 93LF 8me LLC 2/1/2019 648,108 0.00 6.06 26.24 83.77 76.96 113.04 105.22 103.45 84.27 74.18 10.35 0.00 56.965883 Willow Strings Solar, LLC 4/1/2019 270,880 0.00 2.59 11.23 35.86 32.94 48.38 45.04 44.28 36.07 31.75 4.43 0.00 24.381250 Decade Energy LLC 5/3/2019 3,100 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.005262 Antelope DSR 3, LLC 6/20/2019 31,073 0.00 0.48 2.08 6.64 6.10 8.96 8.34 8.20 6.68 5.88 0.82 0.00 4.526361 Rising Tree Wind Farm III, LLC 7/1/2019 105,746 11.30 17.30 18.30 31.40 30.60 47.50 29.70 26.50 26.50 8.80 8.40 15.20 22.631246 Santa Barbara County Public Works Department 11/29/2019 1,628 2.06 2.11 1.99 1.73 2.01 2.13 2.11 2.14 2.08 1.96 2.00 2.08 2.035261 Windhub Solar A, LLC 12/1/2019 2,757 0.00 0.48 2.08 6.64 6.10 8.96 8.34 8.20 6.68 5.88 0.82 0.00 4.525811 RE Tranquillity LLC 12/1/2019 22,806 0.00 4.94 21.42 68.39 62.83 92.29 85.90 84.46 68.80 60.56 8.45 0.00 46.505886 Valentine Solar, LLC 12/1/2019 15,726 0.00 2.67 11.56 36.92 33.92 49.82 46.37 45.59 37.14 32.69 4.56 0.00 25.10

Totals 3,858,744 97.99 143.36 232.03 516.39 484.49 686.83 604.70 586.69 503.41 401.30 133.14 109.77 425.01

SCE 2019 RPS Adder (Initial Resource Service for 2018 or 2019 (Forecasted)) - Total NQC

Capacity (MW)

Attachment B

DECLARATION OF ERIC LAVIK REGARDING THE CONFIDENTIALITY OF

CERTAIN DATA

I, Eric Lavik, declare and state:

1. I am a Manager in the Power Supply Organization Unit at Southern California

Edison Company (“SCE”). As such, I have reviewed the information in Attachment B

Confidential of SCE’s Advice 3871-E. I make this declaration in accordance with California

Public Utilities Commission (“Commission” or “CPUC”) Decisions (“D.”) 06-06-066 and D.08-

04-023, issued in Rulemaking (“R.”) 05-06-040. I have personal knowledge of the facts and

representations herein and, if called upon to testify, could and would do so, except for those facts

expressly stated to be based upon information and belief, and as to those matters, I believe them

to be true.

2. Listed below are the data in the attached data request response for which SCE is

seeking confidentiality protection and the categories of the Matrix of Allowed Confidentiality

Treatment Investor Owned Utility Data (“Matrix”) appended to D.06-06-066 to which these data

correspond.

Data Location Matrix Category Limitations on Confidentiality Specified in Matrix

Contract evaluation information regarding forecasted online dates

Attachment B Confidential Spreadsheet: Column C of all data tabs for projects that are not yet online (as indicated by cells shaded in gray)

VII.G RPS Contracts

VII.H Score sheets, analyses, evaluations of proposed RPS projects

RPS contracts confidential for three years, or until one year following expiration, whichever comes first.

Score sheets, analyses, evaluations of proposed RPS projects confidential for three years.

Attachment B

Contract-specific forecasted annual payments

Attachment B Confidential Spreadsheet: Columns D and E for contracts that have not been delivering for three years (as indicated by cells shaded in gray)

VII.G RPS Contracts

RPS contracts confidential for three years, or until one year following expiration, whichever comes first.

3. I am informed and believe and thereon allege that SCE is complying with the

limitations on confidentiality specified in the Matrix that pertain to the data listed in the table

above.

4. I am informed and believe and thereon allege that the data in the table above has

never been made publicly available.

5. I am informed and believe and thereon allege that the data contained in the

Attachment B Confidential of SCE’s Advice 3871-E cannot be aggregated, redacted,

summarized, masked or otherwise protected in a manner that would allow partial disclosure of

the data while still protecting confidential information.

6. Additionally, SCE is seeking confidential treatment of certain data that is market-

sensitive, but may not fall into a category on the Matrix.

7. Additionally, SCE is seeking confidential treatment of certain data that is market-

sensitive, but may not fall into a category on the Matrix. Providing the on-line dates is

confidential and market-sensitive and should not be disclosed to the public. Public disclosure of

SCE’s forecast of a project’s on-line date may impair the project developer’s ability to secure

financing, attract investors, or raise capital. Obviously, a project’s failure to gain funding of any

type could result in the project failing. The Commission should be as concerned about the effect

on the project developer of releasing SCE’s assessment of the projects overall viability as it is

about the effect on SCE and its customers. Disclosure of this type of information in the hope of

Attachment B

providing greater public access to RPS data may actually have the opposite of the presumably

desired effect by causing or contributing to project failure. SCE maintains the confidentiality of

this information not only from the public at large, but from its counterparties as well. If this

information were to be released and result in the failure of a contract based on an inability to

acquire financing because of publicly released negative information from SCE, then SCE could

be exposed to potential litigation from developers for the release of such information. SCE could

be damaged by the long-term effect of the loss of trust between SCE and prospective renewable

generators that would be engendered by such a disclosure. This “loss of trust” would create a

competitive disadvantage for SCE in its procurement efforts on behalf of its customers.

Disclosure of the status of an RPS project would also hinder SCE’s contract administration of all

of its yet to be completed RPS projects. By revealing that certain milestones have not been

reached or revealing that delays have occurred, a “floor” is created as to what SCE is willing to

allow a future developer to do during the development of a project. This “floor” will

disadvantage SCE in the development of RPS projects by allowing such parties to exploit

concessions that SCE provided under unique circumstances even though such concessions would

not be appropriate in a different context or under different facts. Simply stated, publically

revealing this information may impair SCE’s ability to actively manage milestones and

administer contracts for projects in development, a result that would appear to be directly

contrary to the desire of policy makers to bring as much renewable power on-line as soon as

possible.

Attachment B

8. Information identified in paragraph 7 is protected under Public Utilities Code

Section 454.5(g) and General Order 66-C.

9. Public Utilities Code Section 454.5(g) requires the Commission to maintain the

confidentiality of “market sensitive information.” It provides: “The commission shall adopt

appropriate procedures to ensure the confidentiality of any market sensitive information

submitted in an electrical corporation’s proposed procurement plan or resulting from or related to

its approved procurement plan, including, but not limited to, proposed or executed power

purchase agreements, data request responses, or consultant reports, or any combination, provided

that the Office of Ratepayer Advocates and other consumer groups that are nonmarket

participants shall be provided access to this information under confidentiality procedures

authorized by the commission.”

10. General Order 66-C requires the Commission to protect confidential information

that would place a utility at an “unfair business disadvantage” if it were publicly disclosed. It

categorizes as information that is “not open to public inspection,” those “[r]eports, records, and

information requested or required by the Commission which, if revealed, would place the

regulated company at an unfair business disadvantage.” General Order 66-C, § 2.2(b).

11. Public disclosure of SCE’s forecasted success rate for a particular project may

impair the project developer’s ability to secure financing, attract investors, or raise capital. The

Commission should be as concerned about the effect on the project developer of releasing SCE’s

forecasted project success rates as it is about the effect on SCE and its customers. Disclosure of

this type of information in the hope of providing greater public access to RPS data may actually

have the opposite of the presumably desired effect by causing or contributing to project failure.

12. SCE maintains the confidentiality of this information not only from the public at

large, but from its counterparties as well. If this information were to be released, it could lead to

potential disputes, including litigation.

Attachment B

13. SCE could be damaged by the long-term effect of the loss of trust between SCE

and prospective renewable generators that would be engendered by such a disclosure. This “loss

of trust” would create a competitive disadvantage for SCE in its procurement efforts on behalf of

its customers.

14. I am informed and believe and thereon allege that the information identified in

paragraph 7 cannot be aggregated, redacted, summarized, masked or otherwise protected in a

manner that would allow partial disclosure of the data while still protecting confidential

information.

15. I am informed and believe and thereon allege that the information identified in

paragraph 7 has never been made publicly available.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Executed on September 27, 2018 at Rosemead, California.

____________a

Eric Lavik

Attachment B Confidential Protected Materials – Public

Disclosure Prohibited

Attachment C

Proposed Resource Adequacy (RA) Adder

Pursuant to D.11-12-018, the utilities are to use the California Energy Commission’s (CEC) most recent estimate of the going forward cost of a combustion turbine to set the RA capacity adder. Since the implementation of D.11-12-018, the RA capacity adder has been determined using information from the CEC’s January 2010 “Comparative Costs of California Central Station Electricity Generation – Final Staff Report,” and has been set at $50.17 per kW-year, based on the information found in Table B-4 of the report. On March 9, 2015, the CEC issued the “Estimated Cost of New Renewable and Fossil Generation in California Final Staff Report,”1 based on an update to the Cost of Generation (COG) Model – the first update to the COG Model since the update used to inform its January 2010 report. Table E-4 of the March 2015 report, the “Mid Case Component Levelized Cost of Equity for Merchant Plants,” includes updates to the cost components of a simple-cycle combustion turbine used to establish the RA adder.

As described in Resolution E-4475, the going forward cost of a combustion turbine is defined as the sum of the insurance, ad valorem and fixed operations and maintenance cost components. Per Table E-4 of the 2015 CEC report, the RA capacity adder is: Insurance: $9.29 per kW-year Ad Valorem: $13.47 per kW-year Fixed O&M: $35.51 per kW-year Total Going Forward Costs: $58.27 per kW-year

1 http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-

03/TN203798_20150309T154237_Estimated_Cost_of_New_Renewable_and_Fossil_Generation_in_Califo.pdf

Company Name: Southern California Edison Company (U 338-E)Phone: (626) 302-2086ELC: YesGas: OffWater: OffEmail: [email protected]: OffHeat: OffEmail Disposition Notice: [email protected] Person: Darrah MorganDate Submitted: Advice Letter #: 3871-ETier Designation: 1Subject of AL: Submittal of Relevant Data for Determination of the Renewables Portfolio Standard Adder Component of the Market Price BenchmarkKeywords: ComplianceMonthly: OffQuarterly: OffAnnual: OffOne-Time: YesOther: OffOther text field: AL Commission Order: Resolution E-4475Prior AL: Confidential treat - NO: OffDifferences: Confidential treat - YES: YesConfidential info: See Attachment BConfidential contact: Resolution YES: OffResolution NO: YesEffective date_af_date: 10/1/18No: of Tariff Sheets: -0-

Estimated revenue effect: Estimated rate effect: Tariff Schedules Affected: NoneService affected: Pending advice letters: NoneTitle 1: Managing Director, State Regulatory OperationsUtility Name 1: Southern California Edison CompanyAddress 1: 8631 Rush StreetCity 1: RosemeadName 1: Gary A. Stern, Ph.D.State 1: [California]Zip 1: 91770Telephone 1: (626) 302-9645Fax 1: (626) 302-6396Email 1: [email protected] 2: [California]Name 2: Laura Genao c/o Karyn GanseckiTitle 2: Managing Director, State Regulatory AffairsUtility Name 2: Southern California Edison CompanyAddress 2: 601 Van Ness Avenue, Suite 2030City 2: San FranciscoZip 2: 94102Telephone 2: (415) 929-5515Fax 2: (415) 929-5544Email 2: [email protected] Form: