4802-E-APDF. Opens in new Window.

157 Pages·2017·1.29 MB·English

STATE OF CALIFORNIA EDMUND G. BROWN JR., Governor
PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298

August 1, 2016
Advice Letters: 4802-E, 4802-E-A, 4802-E-B, 4802-E-C

Pacific Gas and Electric Company
Attn: Erik Jacobson, Director, Regulatory Relations
Senior Director, Regulatory Relations
77 Beale Street, Mail Code B10C
P.O. Box 770000
San Francisco, CA 94177

SUBJECT: Implementation of Net Energy Metering Successor Tariff Rate Schedules and
Various Filed Forms, and Modifying of Electric Rule 21

Dear Mr. Jacobson:

Advice Letters 4802-E, 4802-E-A, 4802-E-B, 4802-E-C are effective “when the NEM Cap in
PG&E’s service territory is reached,” per Resolution E-4792 Ordering Paragraphs.

Sincerely,

Edward Randolph
Director, Energy Division
Erik Jacobson Pacific Gas and Electric Company
Director 77 Beale St., Mail Code B10C

Regulatory Relations P.O. Box 770000
San Francisco, CA 94177

Fax: [phone]

May 16, 2016

Advice 4802-E-A
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

Subject: Supplemental: Implementation of California Public Utilities
Commission Decision 16-01-044 Creating Pacific Gas and Electric
Company’s New Net Energy Metering Successor Rate Schedules
NEM2, NEM2V and NEM2VMSH, and Various Associated Filed Forms,
and Modifying of Electric Rule 21

Purpose

The purpose of this advice filing is to supplement Advice 4802-E in order to clarify
language, address the outstanding interconnection fee, incorporate agreed upon
changes based on parties’ protests, and at the request of the Governor’s Office of
Planning and Research, to incorporate new provisions on two Forms.

This supplemental Advice filing supplements 4802-E, filed on February 29, 2016, but
does not replace it in its entirety.

Background

On July 10, 2014, the Order Instituting Rulemaking (OIR) for this proceeding
(Rulemaking R.14-07-002 or “NEM Successor OIR”) was issued by the California Public
Utilities Commission (Commission or CPUC) and is one part of the Commission’s
implementation of Assembly Bill (AB) 327 (Perea), Stats. 2013, ch. 611. NEM
Successor OIR addresses the legislative direction given by Public Utilities Code Section
2827.1 to develop a successor to the NEM program authorized in Section 2827. On
January 28, 2016, the Commission issued Decision (D.) 16-01-044 providing guidance
on the net energy metering successor tariffs.

Consistent with D.16-01-044, Ordering Paragraph (OP) 1, not later than 30 days after
the effective date of D.16-01-044, PG&E filed the Original Tier 2 advice letter (AL) on
February 29, 2016, with its net energy metering successor tariffs, including net metering
aggregation, and virtual net metering tariffs, in accordance with the decision. This
supplement makes additions and modifications to that advice letter.
Advice 4802-E-A - 2 - May 16, 2016

On March 21, 2016, PG&E received two protests to the original Advice Letter 4802-E,
one from the Solar Energy Industries Association (SEIA), the California Solar Energy
Industries Association (CALSEIA), The Alliance for Solar Choice (TASC) and Vote Solar
(collectively, the Joint Solar Parties or JSPs), and another from the California Farm
Bureau Federation (CFBF). PG&E responded to the protests, and agreed to make
several changes as discussed below.

March 18 Substitute Sheets

After filing the Original Tier 2 advice letter, PG&E discovered a minor error, where some
placeholder text was not updated. In Special Conditions 2.b, the word “NEW” was used
in earlier drafts and was inadvertently not updated to say “2.e” in the final version
submitted as part of the Original Tier 2 advice letter.

Also, on March 8, 2016, PG&E had a conference call with Energy Division. During this
call, Energy Division noted some extraneous and erroneous language in Schedule
NEM2 Special Conditions 2.f, which PG&E agreed to remove (“…and their allocated
credits.”). On Friday, March 18, PG&E filed substitute sheets to correct these errors.

Concurrent Substitute Sheets

Additional minor errors have come to light since the March 18 Substitute Sheets were
submitted. Additional substitute sheets will be submitted concurrently with this
Supplemental Advice Letter. The corrections include:

1) On Schedule NEM2, Special Conditions 1. METERING on Sheet 2, an out-of-place
insertion of the acronym “REGF” is removed at the end of the first paragraph.

2) EML was incorrectly included as a rate with no corresponding Time-of-Use (TOU)
rate on page 6 of the Original Tier 2 advice letter. This is incorrect, as the EML rate
does have a corresponding TOU rate. The reference to EML was removed.

3) On the cover letter, on page 12, in the description of forms under Section E
(Modification to Existing Filed Forms), subsection 4 (> 1 MW Forms), there are two sub-
subsection “a”, and under the second, the form number is correct, but the description is
incorrect. The second sub-subsection was corrected.

On May 11, 2016 PG&E had a discussion with Energy Division and agreed to make
certain changes in addition to changes already identified by PG&E. All of these are
discussed in the following section.
Advice 4802-E-A - 3 - May 16, 2016

Revisions in this Supplemental Advice Letter

A. Interconnection Fee

This supplemental filing corrects and clarifies additional sections of the NEM2 and
Electric Rule 21 tariffs, and forms. As noted in Advice Letter 4802-E, Section A.1,
footnote 10, PG&E omitted the inclusion of a NEM Interconnection Fee because in
preparing the NEM2 filing it was discovered that the data relied on in Advice Letter
4660-E1, Appendix A, Table 3, Metering Installation/Inspection and Commissioning did
not accurately capture all of the costs that were associated with NEM projects. PG&E
has determined that the interconnection fee is $145 as calculated according to the
Commission’s guidance in Decision (D.)16-01-044. PG&E will submit this correction to
Table 3 shortly after this supplemental Advice Letter, in a new Advice Letter to correct
Advice Letter 4660-E. Accordingly, in this supplemental filing, PG&E submits a
correction to Electric Rule 21, Sheet 47 to reflect the $145 interconnection fee.

B. Modifications In Response to Protests

PG&E responded to the two protests on March 28, 2016 and agreed to make three
changes:

1. To include in Schedules NEM2 grandfathering provisions to allow customers to
use the NEM successor tariff as it existed at the time they completed their
interconnection application for 20 years from the year of the interconnection of
their system, and to include the grandfathering provisions consistent with D.14-
03-041, including provisions for modification, ownership transfer, and/or paired
energy storage into proposed Schedules NEM2, NEM2V and NEM2VMSH;

2. To note in our supplemental Advice Letter that PG&E would work towards
incorporating a line item for Non-Bypassable Charges (NBC) charges on
customer’s bills; and

3. To note in our supplemental Advice Letter that PG&E would work towards
incorporating electronic interconnection fee invoicing.

PG&E hereby proposes adding the following grandfathering provisions in Schedule
NEM2 as Special Condition 9. NEM2 Grandfathering Provisions:

9. NEM2 Grandfathering Provisions
This Special Condition is applicable to all Customers receiving service on
Schedules NEM2, NEM2V, and NEM2VMSH (“the NEM-2 Schedules”) and

1 AL 4660-E “Information-Only Filing Regarding Net Energy Metering Costs” filed June 30,
2015. http://www.pge.com/nots/rates/tariffs/tm2/pdf/ELEC_4660-E.pdf
Advice 4802-E-A - 4 - May 16, 2016

who have submitted all documentation necessary to receive service on the
NEM-2 schedules.
a. 20-Year Transition Period. Pursuant to D.16-01-044, Customers who are
receiving service on the NEM-2 schedules, or who have submitted all
documentation necessary to receive service on a NEM-2 Schedule, are
eligible to continue receiving service on that NEM-2 Schedule for a period
of 20 years from the original year in which their Generating Facility was
interconnected to PG&E’s grid, indicated by and measured from the date
on which the Customer originally received permission to operate (PTO)
the Generating Facility from PG&E and ending at the conclusion of the
Customer’s applicable Relevant Period that ends immediately on or after
the 20th anniversary of the original PTO date. For example, if a
Customer initially received PTO on April 1, 2018, the Customer is eligible
to continue receiving service on this Schedule through the conclusion of
the Relevant Period ending immediately on or after March 31, 2038.
Customers served on Schedule NEM, NEMV, or NEMVMASH who elect
to make a one-time switch to the corresponding NEM-2 Schedule prior to
the conclusion of their Schedule NEM, NEMV or NEMVMASH 20-year
transition period can continue service under the corresponding NEM-2
Schedule from the date of their original Schedule NEM, NEMV or
NEMVMASH PTO date; these Customers may not restart their 20-year
transition period by electing to move to this Schedule. Customers
electing to switch to the corresponding NEM-2 Schedule prior to the
conclusion of their Schedule NEM, NEMV or NEMVMASH 20-year
transition period permanently forfeit any of their Generating Facility’s
remaining transition period eligibility on Schedule NEM, NEMV or
NEMVMASH and may not later change back to receiving service under
Schedule NEM, NEMV or NEMVMASH.

b. Modifications1. REGFs eligible for the 20-year transition period outlined
above that are modified and/or repaired shall remain eligible for the
remainder of their 20-year transition period as long as the modifications
and/or repairs do not increase the REGF by more than the greater of:
(1) 10 percent of the REGF’s nameplate rating capacity, as established
when the REGF was originally interconnected, or
(2) 1 kW;
and provided the modifications and/or repairs do not result in the REGF
exceeding the Customer’s annual onsite load.
c. Transferability. REGF eligible for the 20-year transition period shall not
lose their eligibility if transferred to a new owner, operator, or PG&E
account, provided the REGF remains at its original location.2
Advice 4802-E-A - 5 - May 16, 2016

d. Paired Energy Storage Systems. To the extent that eligible energy
storage systems are considered an addition or enhancement to the
REGF served under a NEM-2 Schedule, the energy storage systems
shall be treated in the same way, and subject to the same transition
period, as the REGFs to which they are connected.

1 Customers making modifications and/or additions to their REGF that
exceed the 10 percent or 1 kW limit referenced above have the option of
either metering the additions and/or modifications separately under
another eligible tariff or other authorized process, or having the entire
REGF served under another eligible tariff, subject to the terms and
conditions contained therein.
2 The transfer of an existing REGF to a new location is considered a new
installation requiring a new Interconnection Agreement that is subject to
the applicable tariffs in place at the time the new Interconnection Request
is completed

PG&E also proposes to include a reference to the NEM2 Grandfathering Provisions in
Schedules NEM2V and NEM2VMSH:

• Customers on this Schedule NEM2V will be covered under Special
Condition 9, NEM2 Grandfathering Provisions, in Schedule NEM2.

• Customers on this Schedule NEM2VMSH will be covered under Special
Condition 9, NEM2 Grandfathering Provisions, in Schedule NEM2.

PG&E would also like to affirm its commitment to work toward: (1) incorporating a line
item on customers’ bills showing their NBC charges; and (2) offering an online payment
functionality.

C. Modifications For the Governor’s Office of Planning and Research

PG&E has also been collaborating with the Governor’s Office of Planning and Research
to include a new provision at the end of the indemnity section on Form 79-1161-02 and
Form 79-1144-02 to address the requirements of California Constitution Article XVI,
Section 6. PG&E hereby proposes a new section with additional language:

1. New Section 18.1.4 on Form 79-1161-02:

“This entire Section 18.1 does not apply to either Party where the
Interconnection Customer is prohibited from providing Distribution
Provider the indemnity contained herein by CA Constitution Article XVI,
Section 6, and where no law expressly authorizes such indemnity.”
Advice 4802-E-A - 6 - May 16, 2016

2. New Section 7.3.6 on Form 79-1144-02:

“This entire Section 7.3 does not apply to either Party where the
Interconnection Customer is prohibited from providing Distribution
Provider the indemnity contained herein by CA Constitution Article XVI,
Section 6, and where no law expressly authorizes such indemnity.”

PG&E also proposes to add in two commas to Section 7.3.2. on Form 79-1144-02, in
order to provide additional clarity:

“…third parties arising out of or resulting from the other Party’s action, or
failure to meet its obligations, under this Agreement…” (new commas in
bold)

D. Modifications to Schedules NEMBIO and NEMFC

PG&E added to the Multiple Tariff Facilities Special Condition in both NEMBIO and
NEMFC the sentence, “For Multiple Tariff Facilities involving NEM2 NEM-eligible
Constituent Generator Groups, see the special condition for MULTIPLE TARIFF
FACILITIES in schedule NEM2.”

E. Modification at the Request of Energy Division

PG&E agreed to incorporate Southern California Edison Company’s definition of
premises in its NEM2V advice letter. This changes its NEMV applicability to read:

This virtual net energy-metering schedule is applicable to a multi-tenant or multi-
Meter1 Eligible NEM2V installation on a single eligible Property, as defined
below…

And includes SCE’s definitions of “Property”, and incorporated in that, SCE’s Electric
Rule 1 definition of “Single Enterprises”:

A Property is defined as: A cluster of multi-tenant and multi-meter buildings,
facilities or structures that are under the control of a single Owner or Operator
built to serve a common function, such as a housing complex or a multi-tenant
complex, on an integral parcel of land undivided, unless the division is a street,
highway, or similar public thoroughfare, which is permissible provided no other
unrelated Single Enterprises (defined as a separate business or other individual
activity carried on by a customer but does not apply to associations or
combinations of customers) break up the otherwise integral parcel and cluster of
multi-tenant and multi-meter buildings, facilities or structures.
Advice 4802-E-A - 7 - May 16, 2016

F. Erroneous Footnotes Referring to the EML Rate Schedule

PG&E also corrects erroneous footnotes in Schedules NEM2, NEM2V, and
NEM2VMSH and Filed Forms 79-1151A-02. EML was incorrectly included as a rate
with no corresponding Time-of-Use (TOU) rate. This is incorrect, as the EML rate does
have a corresponding TOU rate. Therefore, PG&E proposes the following corrections:
• Removing the reference to EML in footnote 2 of Schedule NEM2;
• Removing the reference to EML in footnote 3 of Schedule NEM2V;
• Removing the reference to EML in footnote 4 of NEM2VMSH; and
• Removing the reference to EML in footnotes A and F of Form 79-1151A-02.

PG&E will file additional supplemental advice letters if necessary to make any additional
modifications or clarifications necessary to implement D.16-01-044.

Protests

Pursuant to CPUC General Order 96-B, Section 7.5.1, PG&E respectfully request that
the Commission maintain the original protest and comment period designated in the
Original Tier 2 Advice Letter and not reopen the protest period for this supplemental
advice filing.

Effective Date

In Advice Letter 4802-E, PG&E requested that this Tier 2 advice filing become effective
when the NEM cap in PG&E’s service territory is reached.2 PG&E reiterates that
request in this Supplement.

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 lists for R.14-07-002, R.12-11-005, R.11-09-011. 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 [phone] 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/.

2 The NEM successor tariff cap will be reached the earlier of:
i. July 1, 2017, or
ii. such time as the Total Rated Generating Capacity used by eligible customer-generators
and Qualified Customers on Rate Schedules NEM, NEMV and NEMVMASH exceeds the
larger of five (5) percent of PG&E’s Aggregate Customer Peak Demand or 2409
megawatts of nameplate generating capacity.
Advice 4802-E-A - 8 - May 16, 2016

/S/
Erik Jacobson
Director, Regulatory Relations

Attachments

cc: Service Lists R.14-07-002, R.12-11-005, R.11-09-011
Sara Kamins, Energy Division
Elizabeth Curran, Energy Division
Karen Norene Mills, Counsel for California Farm Bureau Federation
Jeanne B. Armstrong, Counsel for Solar Energy Industries Association
Sandy Goldberg, Governor’s Office of Planning and Research
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 E)
Utility type: Contact Person: Kingsley Cheng
 ELC  GAS Phone #: [phone]
 PLC  HEAT  WATER E-mail: [email protected] and [email protected]
EXPLANATION OF UTILITY TYPE (Date Filed/ Received Stamp by CPUC)
ELC = Electric GAS = Gas
PLC = Pipeline HEAT = Heat WATER = Water
Advice Letter (AL) #: 4802-E-A Tier: 2
Subject of AL: Supplemental: Implementation of California Public Utilities Commission Decision 16-01-044 Creating
Pacific Gas and Electric Company’s New Net Energy Metering Successor Rate Schedules NEM2,
NEM2V and NEM2VMSH, and Various Associated Filed Forms, and Modifying of Electric Rule 21
Keywords (choose from CPUC listing): Compliance, Metering, Forms, Rules
AL filing type:  Monthly  Quarterly  Annual  One-Time  Other _____________________________
If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D.16-01-044
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: N/A
Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential
information: __________________________________________________________________________________________________
Resolution Required? Yes No
Requested effective date: When the NEM Cap in PG&E’s Service Territory No. of tariff sheets: 18
is Reached
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).
Tariff schedules affected: See Attachment 1
Service affected and changes proposed: See Attachment 1
Pending advice letters that revise the same tariff sheets: N/A
Pursuant to CPUC General Order 96-B, Section 7.5.1, PG&E respectfully request that the Commission maintain the original protest and
comment period designated in the Original Tier 2 Advice Letter and not reopen the protest period for this supplemental advice filing.
California Public Utilities Commission Pacific Gas and Electric Company
Energy Division Attn: Erik Jacobson
Director, Regulatory Relations
EDTariffUnit
c/o Megan Lawson
505 Van Ness Ave., 4th Flr.
77 Beale Street, Mail Code B10C
San Francisco, CA 94102
P.O. Box 770000
E-mail: [email protected] San Francisco, CA 94177
E-mail: [email protected]