December 22 , 2017 Green Tariff Shared Renewables … Green Tariff Shared Renewables Program...

Erik Jacobson

Director Regulatory Relations

Pacific Gas and Electric Company 77 Beale St., Mail Code B13U P.O. Box 770000 San Francisco, CA 94177 Fax: 415-973-3582

December 22, 2017 Advice 3920-G/5206-E (Pacific Gas and Electric Company ID U 39 M) Public Utilities Commission of the State of California Subject: Green Tariff Shared Renewables Program Extension for Pacific Gas

and Electric Company Pacific Gas and Electric Company (PG&E) files this Advice Letter to extend beyond January 1, 2019, the Green Tariff Shared Renewables (GTSR) Program enacted by Senate Bill (SB) 43 in September 2013 and implemented by the California Public Utilities Commission (CPUC or Commission) in Decision (D.) 15-01-051. The GTSR Program approved by the Commission includes both a Green Tariff (GT) and Enhanced Community Renewables (ECR) option. Purpose PG&E hereby submits this Advice Letter (AL) in compliance with Ordering Paragraph (OP) 13 of D. 15-01-051. Background D.15-01-051 approved the implementation of Senate Bill (SB) 43. SB 43 set a formal requirement for the three large electrical utilities to implement the GTSR Program. The GTSR Program, as implemented by the CPUC, includes both a GT and ECR option. GT allows investor-owned utility customers to purchase energy from a portfolio of solar energy sources under contract with the IOU comprised of a greater share of renewables than is offered in the utility’s standard portfolio. ECR allows customers to subscribe to renewable energy from specific newly developed generation projects from which PG&E procures energy. D.15-01-051 OP 13 requires each IOU by no later than December 31, 2017 to file a Tier 3 Advice Letter or application to make changes to its GTSR program that would either extend it beyond January 1, 2019 (for new customers and/or resources), or terminate it as of that date. If the IOU desires the extended program to have a different structure or materially different capacity, an application must be filed instead of a Tier 3 Advice Letter.

Advice 3920-G/5206-E - 2 - December 22, 2017 In accordance with D.15-01-051 OP 13, PG&E is seeking approval to extend the GTSR program (including new enrollment and new procurement) beyond January 1, 2019. While PG&E is not seeking any changes to the program to have a different structure or materially different capacity, it is seeking the following modest modifications, discussed in greater detail below1.

1) Allow greenhouse gas emission reduction facts solely regarding the program to be provided to customers as part of marketing the program

2) Streamline and simplify the ECR program process, consistent with the existing structure:

a. Simplify community interest requirements b. Simplify the procurement process

3) Streamline reporting requirements to improve program effectiveness and efficiency

PG&E believes that the modifications proposed in this AL will greatly improve both programs. Since the proposed ECR program changes are designed to improve program effectiveness, PG&E respectfully requests that these modifications become effective immediately upon CPUC approval, and if possible prior to January 1, 2019.

1) Consistent with the Statute and the CCA Code of Conduct, The Green Tariff

Shared Renewables Program Should be Allowed to Include Facts About Its GHG Emissions As Part of GTSR Marketing

In D.16-05-006, the CPUC directed that “Until such time as a statewide methodology is adopted for calculating greenhouse gas emissions associated with a retail product, the Green Tariff Shared Renewables program may not be marketed by any retail seller to potential subscribers by making specific claims about portfolio greenhouse gas emissions for specific products.”2 Further, the Decision goes on to state “Thus all retail suppliers (including Investor Owned Utilities, Community Choice Aggregators, Electric Service Providers, and Enhanced Community Renewables Providers) will be treated consistently.”3 The prohibition on customer communications regarding the GHG emissions associated with the Green Tariff Shared Renewables program exclusively is neither fair nor necessary to achieve the Commission’s objectives of fair and accurate marketing communications across retail suppliers.

1 As such, PG&E is using a Tier 3 Advice Letter, in accordance with D.15-01-051. 2 D.16-05-006, OP 11 3 D.16-05-006, p.32

Advice 3920-G/5206-E - 3 - December 22, 2017

a. The basis for GHG emissions reductions quantification for GTSR is already established in statute and by CPUC Regulation .

PU Code 2833 (u) requires all renewable resources procured on behalf of participating GTSR customers to comply with the State Air Resources Board’s Voluntary Renewable Electricity (VRE) Program, and for allowances to be retired on behalf of participating customers as part of the board’s VRE program. In D.15-01-051, the CPUC directs the IOUs to comply with this requirement.4 PG&E has been dutifully fulfilling this requirement to retire GHG allowances in the Voluntary Renewable Electricity set-aside on behalf of participating GTSR customers, and attaches herewith as Attachment A5 to this filing the most recent letter from the California Air Resources Board (CARB) confirming such retirement. The CARB Regulatory Guidance Document on the process for retirement of allowances from the Voluntary Renewable Electricity reserve account provides clear direction on this issue.6 Chapter 7 provides guidance for Cap and Trade Regulation sections 95831(b)(6), 95841.1, and 95870(c). In particular, see Section 7.4.2.

7.4.2. Do I Need to Calculate the GHG Emissions from Voluntary Renewable Electricity Generation? No. CARB will perform this calculation. VRE program participants only need to report their qualified VRE generation pursuant to section 95841.1(b) of the Regulation. CARB staff will verify the eligibility and compute the number of allowances that will be retired. If applicants wish to calculate the avoided emissions for their own reference, the equation to convert megawatt-hours of VRE generation to metric tons of GHG emissions is in section 95841.1(c) of the Regulation.

The reduction in GHG emissions associated with purchases in the GTSR program is 100% tied to retirements of GHG allowances, and not to the particular emissions profile of any one load serving entity. Indeed, the reason that SB 43 and the Commission directed the IOUs to retire allowances in the ARB’s VRE program was to ensure accurate tracking of GHG reductions (See D.15-01-051 Finding of Fact 63).7

4 D.15-01-051, p.51, p. 166 FOF 63 5 See Attachment A 6 https://www.arb.ca.gov/cc/capandtrade/guidance/chapter7.pdf 7 D.15-01-051, FOF 63 “Compliance with CARB’s Voluntary Renewable Electricity Program is important to California’s goal to track reductions in GHG.”

Advice 3920-G/5206-E - 4 - December 22, 2017 Therefore, the quantification that the CARB uses to determine how many allowances it allocates to VRE entities for retirement for each MWh of eligible renewable electricity (i.e., the default CO2e emissions factor for unspecified power) is the only basis upon which GHG emissions reductions claims - for the VRE program - can accurately be made.

a. The current exclusive prohibition on factual claims regarding the GHG emissions reductions related to GTSR programs is not only unfair, but also detrimental to the increased use of voluntary renewable energy in California.

Renewable energy is an intangible commodity, and helping potential customers understand the quantified benefits of their purchase is key to facilitating a robust market for voluntary green power purchases. This often takes the form of translating purchases of green power megawatt hours into more understandable metrics, such as the number of cars off the road, or the number of trees planted. While the investor-owned utilities have been unable for almost two years to communicate any GHG-reduction benefits to their customers or would-be customers, the Community Choice Aggregators have been actively making such claims. For example:

Marin Clean Energy o “In just four years, MCE customers have eliminated 185,751 metric tons of

greenhouse gas emissions. It would take all of the trees in Muir Woods over 300 years to sequester that much carbon!”8

Sonoma Clean Power o “Since inception, SCP has saved 420,790 metric tons of carbon

dioxide. This is equivalent to planting nearly 11 million tree seedlings and letting them grow for a decade!”9

Peninsula Clean Energy o “Your energy makes a Difference. 680,000,000 Pounds of Carbon

Emissions Avoided Annually. 363,300 Emission Benefit Equivalent in Acres of US Forest Annual Carbon Sequestered.”10

In relation to its order prohibiting the IOUs from making GHG reduction claims related to their GTSR programs, D.16-05-006 stated “Thus all retail suppliers… will be treated consistently.”11 By definition, it is not consistent to prohibit providers of only one type of green power program, the GTSR, from making claims while other providers are free to continue to make claims and comparisons regarding their power content.

8 https://www.mcecleanenergy.org/energy-sources/, accessed on November 29, 2017. 9 https://sonomacleanpower.org/about-scp/power-sources/, accessed on November 29, 2017. 10 https://www.peninsulacleanenergy.com/, accessed on November 29, 2017. 11 D.16-05-006, p.32


b. The utilities are legally required by the Legislature to provide GHG emission reduction information to their GTSR customers. They must be allowed to comply with this requirement.

PU Code 2833(w) requires a utility participating in the GTSR program to publicly disclose, on a geographic and aggregated basis, consumption data and reductions in emissions of greenhouse gases achieved by participating customers in the utility’s GTSR program. The Commission directs the IOUs to fulfill this requirement in D.15-01-051.12 The Commission should eliminate or clarify the contradictory language in D.16-05-006 which prohibits such communication, and allow GHG emission reduction claims using the only basis which is allowed under statute and CPUC directive: the ARB’s Voluntary Renewable Electricity program formula.

The following passages of D.16-05-006 should be modified as follows:

c. Ordering Paragraph 11

Until such time as a statewide methodology is adopted for calculating greenhouse gas emissions associated with a retail product, the Green Tariff Shared Renewables program may not be marketed by any retail seller to potential subscribers by making specific claims about portfolio greenhouse gas emissions for specific products. GHG-reduction claims associated with the Green Tariff Shared Renewables programs should be based on the California Air Resources Board’s current default emissions factor (EF) for the Voluntary Renewable Electricity Program.

d. Section 3.5.2: Calculating the Greenhouse Gas Emission Rate for

Retail Electricity Projects

The portion of Section 3.5.2 beginning on page 31 with “In the Self-Generation Incentive Program…” through the remainder of the section should be struck and replaced with:

PU Code 2833 (u) requires all renewable resources procured on behalf of participating GTSR customers to comply with the State Air Resources Board’s Voluntary Renewable Electricity Program, and for allowances to be retired on behalf of participating customers as part of the board’s VRE program. In D.15-01-051, the CPUC directs the IOUs to comply with this requirement (p. 51). Thus, the greenhouse gas emissions reductions associated with the GTSR program occur in the retirement of those allowances.

12 D.15-01-051, p.134 and p.142


Indeed, the reason that SB 43 and the Commission directed the IOUs to retire allowances in the ARB’s VRE program was to ensure accurate tracking of GHG reductions (See D.15-01-051 Finding of Fact 63). Therefore, the quantification that the ARB uses to determine how many allowances it allocates to VRE entities for retirement for each MWh of eligible renewable electricity is the only basis upon which GHG emissions reductions claims - for programs that retire allowances through the VRE program - can accurately be made. Any claims made regarding the GHG emissions reduction content of the GTSR program should be made using the ARB’s current default emissions factor for the Voluntary Renewable Electricity program.

2) Streamline and Simplify the Enhanced Community Renewables Program

Requirements Consistent with the Existing Structure

The IOUs and the CPUC held a Developer Forum in April 2017 to hear from developers in regards to their experience with the Enhanced Community Renewables aspect of the GTSR program. The concerns that were expressed generally fell into two categories: concerns with the level and variability of the bill credit, driven largely by the Power Charge Indifference Adjustment (PCIA), and concerns with the administrative program requirements, especially in regards to the demonstration of community interest. Since there is a separate proceeding addressing the PCIA, PG&E does not propose any modifications to that bill credit element here. The rest of this discussion is focused on the administrative requirements of the program.

The ECR program has a number of rules and requirements in regards to demonstration of community interest which collectively complicate a developer’s ability to submit a viable project through the IOUs’ ECR Request for Offers process. The extensive set of requirements, while established for good reasons, makes for a highly complex program that can be costly and burdensome to work with. The specific requirements are summarized in Attachment B and include:

Within 60 days of PPA award notification, developers must:

o Demonstrate expressions of interest for 51% of project capacity, or commitments to enroll for 30% of project capacity

The demonstration of community interest must show:

o As many subscribers as MWs (e.g. 20 MWs = 20 subscribers) o At least 50% (by number of customers) and at least 1/6 (by load) should

come from residential customers


o Customers must come from within 10 miles or the same county as the project

o Individual subscribers are limited to 2 MW of load and no single customer may enroll more than 20% of a single year’s generating capacity

PG&E believes that the underlying objectives of ensuring community support and ongoing residential participation for the projects can be maintained, while streamlining and simplifying the process of engaging with the program. Accordingly, PG&E proposes the following modifications:

a. Eliminate completely the demonstration of community interest requirements at 60 days post-award notification, and instead move the two most critical enrollment requirements to the time of commercial operation. o Eliminate the demonstration of community interest 60 days post-award

notification o Eliminate completely the # of subscribers requirement (20 MW = 20

subscribers) o Eliminate at 60 days post-award notification – and move to the time of

commercial operation - the % residential requirement o Eliminate completely the locational requirement o Eliminate at 60 days post-award notification – and move to the time of

commercial operation - the customer size limitations

b. Simplify the procurement process. Explore creation of a year-round accessible procurement process.

The rationale for each of the modifications is described below.

a. Simplify community interest requirements

o Eliminate the demonstration of community interest 60 days post-award notification

Currently, a developer must demonstrate either expression of interest for 51% of project capacity, or commitment to enroll for 30% of project capacity within 60 days of PPA award notification.13 Developers have informed the utilities that the 60 day timeframe is unworkable from their perspective.14 It is also the case that the intention of ensuring that developers enroll subscribers in the project is already captured in the payment structure at the time of commercial

13 D.16-05-006 p. 17 14 GTSR Program Forum, April 5th, 2017


delivery.15 Furthermore, customer expression of interest at the point of PPA award, which can often be at least 24 months prior to commercial delivery, has little relevance for the actual customer decision to enroll two or more years later. For this reason, PG&E believes it is reasonable to eliminate completely the demonstration of community interest requirement that is currently enforced 60 days post award notification. The requirement for enrollment of customers will be captured through the payment structure at the time of commercial delivery.

The following passage (D.16-05-006 p. 17) should be revised as follows:

Enhanced Community Renewables project must demonstrate fulfillment of its community interest requirements within 60 days of notification of contract award through the Renewable Auction Mechanism or the awarded capacity will be assigned to the next highest ranking least-cost best-fit Enhanced Community Renewables project in the queue.

o Eliminate the # of subscribers requirement (20 MW = 20 subscribers)

Currently, developers must demonstrate that there are as many customers as MWs in the project.16 For example, a 20 MW project must have at least 20 subscribers, and a 5 MW project must have at least 5 subscribers. While PG&E appreciates the simplicity of this requirement, the more important requirement that PG&E believes must be adhered to is an appropriate mix of residential and non-residential load. Since there is already a requirement regarding % of residential enrollment in terms of MWhs, PG&E proposes that # of customer requirement, which is less stringent, is superfluous and should be eliminated.


To ensure that larger projects do not target only a few large commercial or industrial customers and to promote the community aspect of these projects, for projects between 3 and 20 MW, we adopt SEIA’s recommendation that we increase the minimum number of required subscribers as project size increases (i.e., 3 subscribers for 3 MW projects but 20 subscribers for 20 MW projects).

o Eliminate at 60 days the % residential requirement

15 See D.15-01-051 p. 61-63 16 D.16-05-006 p. 17


Currently, within 60 days of award notification, developers must demonstrate that at least 50% of number of customers, and 1/6 by load must be from residential customers.17 As discussed previously, the timing for this requirement has been deemed unreasonable by developers. PG&E suggests instead moving this requirement to the time of commercial operation. How this would be implemented is that customer enrollments in the project would be calibrated to maintain the requirement that at least 1/6 of load is represented by residential customers. Given the size of residential load relative to commercial load, the 50% residential customer requirement is a virtual certainty in the event that the load requirement is satisfied, and can be eliminated. In the event there are insufficient residential customer enrollments to meet this requirement, non-residential enrollments would simply be curtailed until such time as the required balance of enrollments is obtained. In summary, this requirement would be eliminated at 60 days, but enforced from the time of customer enrollment.


Enhanced Community Renewables project must demonstrate fulfillment of its community interest requirements within 60 days of notification of contract award through the Renewable Auction Mechanism or the awarded capacity will be assigned to the next highest ranking least-cost best-fit Enhanced Community Renewables project in the queue. The following passage (D.16-05-006 p. 17) should be revised as follows: At least 1/6th (by load) of the demonstrated community interest enrollment in the project should come from residential customers.

o Eliminate the locational requirement

Currently, at the time of demonstration of community interest, the customers interested in the project must come from within 10 miles or the same county as the project.18 However, at the time of actual enrollment in the project, customers may come from anywhere within the IOU’s service territory. Based on comments received from developers over the last two years, PG&E believes that this differentiated requirement has produced significant misunderstanding on the part of developers. Since PG&E is proposing to eliminate completely the demonstration of community interest, PG&E is also willing to eliminate the locational requirement of customers in relation to the project for which they are enrolling.

17 D.16-05-006 p. 17



For purposes of this evaluation, we adopt PG&E’s suggested definition of “community” as customers within the same municipality or county, or within ten miles of the customer’s address.

The following passage (Resolution E-4734 p. 29) should be revised as follows:

In the stage before an ECR project is developed, the ECR project developer must show that the project has a “sufficient demonstration of community interest” from customers within 10 miles of, or in the same county as, a proposed ECR project. After an ECR project is developed, Subscribers may come from anywhere in an IOU’s territory.

b. Simplify the procurement process. Explore creation of a year -round accessible procurement process.

PG&E would like to explore an alternative procurement process that would give developers more control over the timing of their project development cycle. PG&E believes that a year-round accessible procurement process could allow developers to match the timing of their bids with their own project’s unique development cycles and constraints. The developer would not have to wait until an open solicitation period, but rather could offer a bid at any time while MWs remain under the program. All of the existing project bid package and eligibility requirements would remain, and projects that meet the Environmental Justice requirements would continue to have preference as they do today.

PG&E believes that the details of this concept could be fleshed out in a workshop format with the IOUs, developers, and CPUC staff. The annual developer Program Forum required by D.15-01-051 OP 11, which could be held as early as Q1 2018, could also be used for this purpose.

The following passage (D.16-05-006 p.10) should be adapted as follows:

In order to accomplish this balancing act, we direct PG&E, SCE, and SDG&E to hold a developer workshop in 2018 that explores creation of a more flexible procurement process, and in the meantime, to each hold two Renewable Auction Mechanism solicitations each year to procure Enhanced Community Renewables and Enhanced Community Renewables-Environmental Justice projects while MWs remain under the program cap until the program sunsets in December 31, 2018. The first auction should occur no later than August 31, 2016. The minimum capacity offered at each solicitation should be 75 MW for PG&E and SCE, and 20 MW for SDG&E, up to the total remaining unsubscribed capacity


for each utility’s GTSR program at that point in time at the utility’s discretion. The final solicitation of 2018 shall offer all remaining unsubscribed capacity up for bid.

3) Streamline reporting requirements to improve effectiveness and efficiency for all parties

Data sharing is necessary for understanding the GTSR Program, for enabling its success, and for helping to improve the design of future programs. However, the IOUs are currently required to submit twenty six GTSR reports or other filings each year. PG&E believes that these objectives can still be achieved efficiently and effectively while consolidating filings and reducing the total number to eleven. Streamlining the reporting requirement by over half will promote efficient use of resources by all parties, will enable effective organization of reporting mechanisms, will enable the GTSR program to more efficiently and effectively share data and will minimize the administrative costs that are borne by GTSR customers. Attachment C to this advice letter summarizes the proposed consolidation outlined in this reporting section. Additionally, PG&E believes that a minor modification is needed to the language regarding locational grid benefits, to accommodate recent regulatory decisions. This change is described below in section f.

a. D. 15-01-051 OP 10 Making the IOUs Responsible for GTSR Program Progress Reports Should be Changed from Monthly to Quarterly. The required content of the report includes “available capacity” data and a summary of the monthly advisory group activities or consultation with CBOs, if any.19 Providing the progress report quarterly instead of monthly will continue to provide high levels of transparency while allowing for more substantial program progress data to be shared. The following passage (D.15-01-051 OP 10) should be revised as follows: Each of Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company shall file or make available, as applicable, the monthly quarterly and annual reports listed in Section 8 of this decision.

b. Advice Letter 4637-E-A Text Approved by Resolution E-4734 Making

the IOUs Responsible for Reporting Requirements on Generation Transfer Report Should be Consolidated with the Quarterly GTSR Program Progress Report.

19 D.15-01-051, p.141


PG&E seeks to submit this report as an attachment to the Q3 Quarterly GTSR Program Progress Report in order to minimize the number of separate filings and reports, to enable more efficient preparation and effective review. The following passage (Advice Letter 4637-E and 4637-E-A, p.24) should be revised as follows: The IOUs propose to file this report as an attachment to the Q3 Quarterly GTSR Program Progress Report on September 1st annually following the launch of each IOUs GTSR Program. A Q3 report September 1st filing date is one month after the August 1st filing date for the annual RPS compliance reports and enables the IOUs to best operationalize the GTSR reporting function in conjunction with RPS reporting functions.

c. The 20-year Rate Forecast Required by D.16-05-006, OP 7, Should Continue. Pursuant to D.16-05-006, OP 7, the IOUs were required to file 20-year forecasts in mid-2016 and to update and publish a forecast in February 2017 and February 2018. There was no mandate to continue publishing forecasts beyond 2018.

Since PG&E is requesting approval to extend the GTSR program beyond January 1, 2019 for new customers, continuation of the 20-year Rate Forecast would be beneficial as it provides potential subscribers with a forecast of bill credits and charges they might expect under the GTSR program. Therefore, PG&E requests that it be allowed to continue produce and publish the 20-year, as long as it provides value to potential subscribers. Starting in December of 2018, PG&E proposes to include the 20-year forecast it plans to publish as an attachment to the Annual GTSR Program Progress Report to streamline reporting mechanisms. The following passage (D.16-05-006, OP 7) should be revised as follows:

Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company must prepare and publicly file a 20-year forecast of bill credits and charges via Tier 1 Advice Letter, and upon approval by the Commission must publish the forecasts online within 60 days of the date of this Decision using the methodology described in Section 3.4. Forecasts for 2017 and 2018 must be published no later than February each year. For years 2019 and beyond, PG&E should submit an updated forecast as part of the Annual GTSR Program Progress Report, as needed, and publish the forecast no later than March of each year.


d. D.15-01-051 Text Making the IOUs Responsible for Annual Tier 2 Advice Letter Regarding Rate Design Should be Consolidated into the Energy Resource Recovery Account Proceeding.

PG&E requests to consolidate the rate change advice letter as part of the Energy Resource Recovery Account (ERRA) Forecast Proceeding. The ERRA proceeding is the more appropriate venue to fulfil the annual requirement to provide the true-up of costs and revenues against charges and credits to GTSR customer bills. The rate information provided, including applicable workpapers, will remain the same. Consolidating the rate filing into a more applicable proceeding will promote efficient use of utility resources and Commission review.

The following passage (D.15-01-051, p.142) should be revised as follows: Tier 2 Advice Letter File Summarize true-up of costs and revenue against charges and credits applied to GTSR customer bills in the Energy Resource Recovery Account Forecast Proceeding. Include workpapers. File annually.

e. D.15-01-051 Text and Ordering Paragraph 6 Making the IOUs

Responsible for Annual Tier 2 Advice Letter Regarding a Marketing and Budget Plan as well as a Separate Annual Marketing Report Should Be Consolidated.

Currently, PG&E provides assessments of marketing campaigns twice per year: in the Marketing Report affiliated with the Annual GTSR Program Progress Report, and in the required annual Tier 2 Marketing Implementation Advice Letter. Starting in Q4 2018, PG&E proposes consolidating the Marketing Report into the Marketing Implementation Advice Letter (Marketing and Budgeting Plan) Tier 2 Advice Letter. This would minimize any confusion and eliminate the need for a separate filing for the Marketing Report starting in March 2019. Moving forward all marketing effectiveness data for the current filing year and planned marketing activities for the following calendar year will be included in the same Tier 2 Advice Letter filing. The following passage (D.15-01-051 p.141) should be revised as follows:

Marketing Report, containing the elements listed in Section 7 above. Additionally, the following passage (D.15-01-051 OP 6) should be revised as follows: Each of Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company shall file an annual marketing and budget plan to be approved via a Tier 2 Advice Letter. The Tier 2 Advice Letter


must include a Marketing Report (as described in Section 7), including a quantitative assessment of the effectiveness of the prior current year’s marketing campaign.

f. D.15-01-051 Text Making the IOUs Responsible for a Tier 2 Advice Letter Regarding Locational Grid Benefits Should be Changed.

There have been multiple decisions in R.14-08-013 to date, none of which has adopted locational grid benefits that could be used in GTSR. According to the most recent such decision, D.17-09-026, a 2018 decision will likely set a deadline for IOUs to calculate locational grid benefits, after which point those calculations could be used to inform GTSR. In this case, it would only be possible for the calculations to inform GTSR within 60 days of the deadline to calculate them rather than within 60 days of the anticipated decision adopting such a deadline. The following passage (D.15-01-051 p. 126) should be revised as follows:

We direct the three IOUs to propose a methodology for incorporating calculating locational grid benefits into the GTSR program via a Tier 2 Advice Letter within 60 days of a decision in R.14-08-013 or within 60 days of a deadline for LNBA implementation established by such a decision. Any additional bill credits should be vetted through the Tier 3 Advice Letter process.

Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or E-mail, no later than January 11, 2018, which is 20 days after the date of this filing. Protests must be submitted to:

CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: [email protected]

Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission:


Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: [email protected]

Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date PG&E requests that this Tier 3 advice filing become effective upon Commission approval. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list [and the parties on the service list for A.12-01-008, A.12-04-020, and A.14-01-007. Address changes to the General Order 96-B service list should be directed to PG&E at email address [email protected]. For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at [email protected]. Send all electronic approvals to [email protected]. Advice letter filings can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations Attachments cc: Service List A.12-01-008, A.12-04-020 and A.14-01-007

CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY

ENERGY UTILITY

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

Company name/CPUC Utility No. Pacific Gas and Electric Company (ID U39 M)

Utility type: Contact Person: Yvonne Yang

ELC GAS Phone #: (415) 973-2094

PLC HEAT WATER E-mail: [email protected] and [email protected]

EXPLANATION OF UTILITY TYPE

ELC = Electric GAS = Gas

PLC = Pipeline HEAT = Heat WATER = Water

(Date Filed/ Received Stamp by CPUC)

Advice Letter (AL) #: 3920-G/5206-E Tier: 3

Subject of AL: Green Tariff Shared Renewables Program Extension for Pacific Gas and Electric Company

Keywords (choose from CPUC listing): Compliance

AL filing type: Monthly Quarterly Annual One-Time Other _____________________________

If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D.15-01-051

Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No

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

Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: No

Confidential information will be made available to those who have executed a nondisclosure agreement: Yes No

Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential

information: N/A

Resolution Required? Yes No

Requested effective date: Upon Commission approval N No. of tariff sheets: N/A

Estimated system annual revenue effect (%): N/A

Estimated system average rate effect (%): N/A

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). N/A

Tariff schedules affected: N/A

Service affected and changes proposed: N/A

Pending advice letters that revise the same tariff sheets: N/A

Protests, dispositions, and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless

otherwise authorized by the Commission, and shall be sent to:

California Public Utilities Commission Pacific Gas and Electric Company

Energy Division

EDTariffUnit

505 Van Ness Ave., 4th

Flr.

San Francisco, CA 94102

E-mail: [email protected]

Attn: Erik Jacobson

Director, Regulatory Relations

c/o Megan Lawson

77 Beale Street, Mail Code B13U

P.O. Box 770000

San Francisco, CA 94177

E-mail: [email protected]

Advice 3920-G/5206-E December 22, 2017

Attachment A

Voluntary Renewable Electricity (VRE) Letter

California Air Resources Board (CARB)


October 26, 2017

Mr. William Reinwald

Pacific Gas and Electric Company

[email protected]

Dear Mr. Reinwald:

Thank you for applying for retirement of Cap-and-Trade Program greenhouse gas

emissions allowances through the Voluntary Renewable Electricity (VRE) program.

California Air Resources Board (CARB) staff has reviewed your application and

approved 21,524 megawatt hours of 2016 generation. Pursuant to sections 95831 and

95841.1 of the Cap-and-Trade Regulation (Regulation), CARB has retired 9,212

allowances on behalf of Pacific Gas and Electric Company. With the existence of a cap

on California’s greenhouse gas emissions, reductions from voluntary renewable

electricity generated for California only occur if allowances are retired.

If you wish to be eligible for CARB retirement of allowances for voluntary renewable

electricity in future years, you must submit a complete application with all documentation

by July 1 of the year following the year of generation. Allowances will not be retired for

claimed generation that is not fully documented by the due date or does not fully meet

the requirements of section 95841.1 of the Regulation. CARB recommends submitting

your application early. Application forms are available on the VRE web page. Please

note that 2016 amendments to the Regulation, including changes to VRE provisions,

went into effect October 1, 2017.

Thank you for participating in the VRE program and helping to reduce California's

greenhouse gas emissions. If you have any questions or need further information,

please contact me at [email protected] or (916) 322-7554.

Sincerely,

/s/

Mary Jane Coombs

Manager Industrial Strategies Division


Attachment B

ECR Community Interest Requirements


THE WAY IT IS TODAY PROPOSAL

Timing What

TO QUALIFY FOR PPA

1 % Subscription Within 60 days of PPA award notification

Developer must demonstrate either expressions of interest for 51% of project capacity, or commitments to enroll for 30% of project capacity.

Eliminate Completely.

2 # of Subscribers (same) As many subscribers as MW (e.g. 20 MW = 20 subscribers)

Eliminate Completely.

3 % Residential / Non-Residential

(same) At least 50% (by number of customers) and at least 1/6th (by load) should come from residential customers.

Eliminate here - Move only 1/6 of load requirement to

commercial operation period.

4 Locational Requirement

(same) Within 10 miles or same county Eliminate Completely.

5 Customer Caps (same) Individual subscribers are limited to 2 MW of load (2833(h)) and no single customer may enroll more than 20% of a single year’s generating capacity (2833(i))

Eliminate here - Move to commercial operation period.

AT TIME OF COMMERCIAL OPERATION

1 % Subscription In order to get paid PPA price on unsubscribed power, the project must meet the following subscription levels (D.15-01-051, p.63):

No change requested.

First year 50%

Second year 75%

Third year 95%

2 # of Subscribers N/A No Requirement No change requested.

3 % Residential / Non-Residential

N/A No Requirement At least 1/6th (by load) should come from residential

customers.

4 Locational Requirement

N/A No Requirement No change requested.

5 Customer Caps Customer enrollment

Individual subscribers are limited to 2 MW of load (2833(h)) and no single customer may enroll more than 20% of a single year’s generating capacity (2833(i))

No change requested.


Attachment C

GTSR Proposed Reporting Requirement Changes


Reports Contents

Current Name

Proposed Name

Decision Location

Current Report Information Proposed Report Changes

Monthly GTSR Program Progress Report

Quarterly GTSR Program Progress Report

D.15-01-051 at 140 and 182, OP 10

Available capacity data and summary of advisory group activities, if any

Change cadence to quarterly

Attach ECR Contract Report

Attach Generation Transfer Report

Quarterly ECR Contract Report

D.15-01-051 at 142-143

Summary of ECR contracts to date and required documentation for new PPAs.

Attach to Quarterly GTSR Program Progress Report

Generation Transfer Report

D.15-01-051 at 141 AL 4637-E-A at 24

A summary of the transfer of RECs between RPS and GTSR.

Attach to Quarterly GTSR Program Progress Report

Annual GTSR Program Progress Report

No change D.15-01-051 at 141 and 182, OP 10

Enrollment Reporting

Cost of generation transferred between the RPS and GTSR Program

GTSR Revenue and Cost Reporting

Advisory Group Activities

Marketing Report

CCA Code of Conduct Report

Supplier diversity

CARE Enrollment

Reports of fraud or misleading ads

Enrollment figures for low-income customers and subscribers who speak a language other than English at home.

Remove Marketing Report (move to MIAL)

Attach Annual GTSR 20-Year Forecast


Reports Contents

Current Name

Proposed Name

Decision Location

Current Report Information Proposed Report Changes

Annual GTSR 20-year Forecast

Annual GTSR Program Progress Report

D.16-05-006 at 27-28 and 43, OP 7

20-year forecast of GT and ECR bill credits and charges, required through 2018

Continue to publish after 2018

Attach to Annual GTSR Program Progress Report

Marketing Implementation Advice Letter (MIAL)

No change D.15-01-051 at 180, OP 6

Assessment of the effectiveness of the prior year’s marketing campaign

Include Marketing Report to assess effectiveness of current year’s marketing campaign

Annual Tier 2 Advice Letter Regarding Rate Design

ERRA Forecast Proceeding

D.15-01-051 at 141

Summarize true-up of costs and revenue against charges and credits

Remove Annual Tier 2 Advice Letter Regarding Rate Design (Incorporate into ERRA Forecast Proceeding)

GTSR Chapter of ERRA Forecast Proceeding

No change Pub. Util. Code 454.5(d)(3)

Requests approval for electric procurement cost forecast and Non-Bypassable Charges for departing load customers

Add Annual GTSR Rate Design request


Other filings with no requested changes:

Reports Contents

Name Decision Location

Report Information

CARE Report D. 15-01-051 at 132 Summary of average bill discounts (in percentage terms) of CARE-enrolled GTSR customers in annual CARE/ESA program reports.

RPS Plan D.15-01-051, OP 9 Each IOU shall use its annual Renewables Portfolio Standard Procurement Plan filing to update its progress toward its Green Tariff Shared Renewables goal.

RPS Compliance Report

D. 12-06-038, OP 34 PG&E’s progress towards achieving the statutory RPS compliance targets, as implemented by the Commission. Provide an update on the RPS-eligible projects designated for the GTSR Program.

VRE Allowance Filing

D. 15-01-051 at 51 Application to the California Air Resources Board for retirement of Cap-and-Trade Program greenhouse gas emissions allowances through the Voluntary Renewable Electricity (VRE) program.

PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV

AT&T Don Pickett & Associates, Inc. Office of Ratepayer Advocates Albion Power Company Douglass & Liddell OnGrid Solar Alcantar & Kahl LLP Downey & Brand Pacific Gas and Electric Company Anderson & Poole Ellison Schneider & Harris LLP Praxair Atlas ReFuel Energy Management Service Regulatory & Cogeneration Service, Inc. BART Evaluation + Strategy for Social

Innovation SCD Energy Solutions

Barkovich & Yap, Inc. G. A. Krause & Assoc. SCE Braun Blaising Smith Wynne P.C. GenOn Energy, Inc. SDG&E and SoCalGas CalCom Solar Goodin, MacBride, Squeri, Schlotz &

Ritchie SPURR

California Cotton Ginners & Growers Assn Green Charge Networks San Francisco Water Power and Sewer California Energy Commission Green Power Institute Seattle City Light California Public Utilities Commission Hanna & Morton Sempra Utilities California State Association of Counties ICF Southern California Edison Company Calpine International Power Technology Southern California Gas Company Casner, Steve Intestate Gas Services, Inc. Spark Energy Cenergy Power Kelly Group Sun Light & Power Center for Biological Diversity Ken Bohn Consulting Sunshine Design City of Palo Alto Leviton Manufacturing Co., Inc. Tecogen, Inc. City of San Jose Linde TerraVerde Renewable Partners Clean Power Research Los Angeles County Integrated Waste

Management Task Force Tiger Natural Gas, Inc.

Coast Economic Consulting Los Angeles Dept of Water & Power TransCanada Commercial Energy MRW & Associates Troutman Sanders LLP County of Tehama - Department of Public Works

Manatt Phelps Phillips Utility Cost Management

Crossborder Energy Marin Energy Authority Utility Power Solutions Crown Road Energy, LLC McKenna Long & Aldridge LLP Utility Specialists Davis Wright Tremaine LLP McKenzie & Associates Verizon Day Carter Murphy Modesto Irrigation District Water and Energy Consulting Defense Energy Support Center Morgan Stanley Wellhead Electric Company Dept of General Services NLine Energy, Inc. Western Manufactured Housing

Communities Association (WMA) Division of Ratepayer Advocates NRG Solar Yep Energy

December 22 , 2017 Green Tariff Shared Renewables … Green Tariff Shared Renewables Program...

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