BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company (U 39-E) for Authorization to Procure Energy Storage Systems during the Biennial Procurement Period Pursuant to Decision Application of Southern California Edison Company (U 338-E) for Approval of Its 2016 Energy Storage Procurement Plan. Application of San Diego Gas & Electric Company (U 902 M) for Approval of Energy Storage Procurement Framework and Program As Required by Decision Application Application Application SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY BRIEF JANET S. COMBS AMBER DEAN WYATT Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: July 11, 2016

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company (U 39-E) for Authorization to Procure Energy Storage Systems during the Biennial Procurement Period Pursuant to Decision Application of Southern California Edison Company (U 338-E) for Approval of Its 2016 Energy Storage Procurement Plan. Application of San Diego Gas & Electric Company (U 902 M) for Approval of Energy Storage Procurement Framework and Program As Required by Decision Application Application Application SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY BRIEF I. INTRODUCTION Pursuant to Rule of the Rules of Practice and Procedure of the California Public Utilities Commission ( Commission ) and the schedule set forth in the Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judge issued June 3, 2016 ( Scoping Memo ), Southern California Edison Company ( SCE ) respectfully submits this Reply to the Opening Brief filed by ORA. Specifically, SCE replies to ORA s proposed showing for deferral projects and its statements concerning the manner in which Self Generation Incentive Program ( SGIP ) projects installed by Direct Access ( DA ) and Community Choice Aggregation ( CCA ) customers are counted. 1

3 II. REPLY A. ORA s Request to Require the Utilities to Confer with the DA and CCA Parties Concerning SGIP Counting is Consistent with SCE s Opening Testimony ORA states that it does not oppose SCE s approach to forecasting SGIP installations 1 by DA and CCA customers, but asks that the Commission require IOUs to confer with the CCAs and Energy Service Providers prior to filing their 2018 Procurement Plans. 2 This is consistent with SCE s Opening Testimony. Specifically, SCE s 2016 Plan included a forecast of what could count towards its 2016 target for purposes of determining its net short/long position with respect to the 2016 procurement target. 3 However, SCE will provide a true-up of the actual SGIP MW countable towards its 2016 procurement target when it files its 2018 Energy Storage Procurement Plan, and SCE indicated that it would confer with ESPs and CCAs to ensure an accurate and reasonable true-up of its forecast. 4 At that time, SCE will also provide another forecast of SGIP projects that will be installed during the procurement cycle. B. The Commission Should Reject ORA s Proposed Showing for Distribution Deferral Projects at this Time ORA argues in its Opening Brief that the Commission should require an affirmative showing of cost-effectiveness and grid reliability for deferral projects. Specifically, ORA requests that the IOUs should include the following information: 1) What purpose the upgrade will serve; 1 ORA slightly mischaracterizes SCE s forecasting methodology in its Opening Brief. For a description of SCE s methodology in forecasting SGIP projects that may be installed by DA and CCA customers, please see SCE-01, Opening Testimony of M. Wallenrod, at Chapter III.D, pp ORA Opening Brief, p See SCE-01, Opening Testimony of M. Wallenrod, at Chapter III.D, pp See id., footnote 33. 2

4 2) How the proposed energy storage system will meet the specific reliability needs of the area where it will be installed and operating; 3) A comparison between the costs of the deferred asset and the proposed energy storage system over the deferment period; 4) The length of the deferred asset s useful life; and 5) The deferred asset s online dates that are used to measure the deferral value of the energy storage system. 5 In principle, SCE finds ORA s proposed five-point showing on distribution deferral projects to be generally reasonable, and consistent with policy positions taken by parties in the Distribution Resources Plan ( DRP ) proceeding and the Integrated Distributed Energy Resources ( IDER ) proceedings namely, that distribution deferral via non-wires solutions should take place if the non-wires solutions are more cost-effective than conventional infrastructure, and provide the required attributes to maintain reliability. Although SCE does agree with the principle of ORA s statement, it is premature at this time to establish a required showing insofar as these issues are currently being addressed through the DRP and IDER proceedings. For example, in the DRP, a Locational Net Benefits Analysis ( LBNA ) and several working group meetings are underway to establish the actual benefits that energy storage and other distributed energy resources ( DERs ) provide. In the IDER proceeding, parties are similarly engaged in developing a Competitive Solicitation Framework, which will further inform the actual benefits of DERs, including energy storage. These proceedings will provide meaningful inputs for determining the comparison between the costs of 5 See ORA Opening Brief, pp Additionally, ORA states that [e]nergy storage used to defer or substitute a traditional asset should do so at an equivalent or lower cost than the traditional asset, such as a fossil-fuel generation facility. ORA Opening Brief, p. 5 (emphasis added). Although SCE agrees that energy storage should be cost effective relative to the cost of upgrading distribution infrastructure through a traditional, wires-based approach, SCE does not believe a fossil-fuel generation facility is the appropriate benchmark for distribution deferral. As such, SCE recommends modifying ORA s recommendation as follows: [e]nergy storage used to defer or substitute a traditional asset should do so at an equivalent or lower cost than the traditional asset, such as a fossil-fuel generation facility the cost of upgrading the distribution infrastructure. 3

5 the deferred asset and the proposed energy storage system over the deferral period. SCE believes that a better framework for comparing the benefits and the costs of energy storage projects can be developed after the Commission obtains information from the efforts underway in the DRP and IDER proceedings, including various working groups and demonstration projects. Therefore, it is premature to adopt ORA s proposal. III. CONCLUSION Through its Application, testimony, and briefing, SCE has demonstrated that its 2016 Energy Storage Procurement Plan is reasonable and consistent with the Commission s decisions. The Commission should approve SCE s Application in its entirety and grant the findings requested by SCE. Respectfully submitted, JANET S. COMBS AMBER DEAN WYATT /s/ Amber Dean Wyatt By: Amber Dean Wyatt Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) amber.wyatt@sce.com July 11,

6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company (U 39-E) for Authorization to Procure Energy Storage Systems during the Biennial Procurement Period Pursuant to Decision Application of Southern California Edison Company (U 338-E) for Approval of Its 2016 Energy Storage Procurement Plan. Application of San Diego Gas & Electric Company (U 902 M) for Approval of Energy Storage Procurement Framework and Program As Required by Decision Application Application Application CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY BRIEF on all parties identified on the attached service list(s) A et al. Service was effected by one or more means indicated below: Transmitting the copies via to ALJ Michelle Cooke and all parties who have provided an address. Executed on July 11, 2016, at Rosemead, California. /s/ Regina Coburn Regina Coburn Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

7 CPUC - Service Lists - A Page 1 of 4 7/11/2016 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR AUTHORITY FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: JUNE 30, 2016 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties DONALD KELLY AMBER DEAN WYATT EXE DIR UTILITY CONSUMERS ACTION NETWORK SOUTHERN CALIFORNIA EDISON COMPANY ONLY 2244 WALNUT GROVE AVE., PO BOX 800 ONLY, CA ROSEMEAD, CA FOR: UCAN FOR: SOUTHERN CALIFORNIA EDISON COMPANY DONALD C. LIDDELL PAUL A. SZYMANSKI SR. COUNSEL DOUGLASS & LIDDELL SAN DIEGO GAS & ELECTRIC COMPANY ND AVENUE 8330 CENTURTY PARK CT., CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: SAN DIEGO GAS & ELECTRIC COMPANY TED KO DAVID MACMILLAN DIRECTOR OF POLICY PRESIDENT STEM, INC. MEGAWATT STORAGE FARMS, INC 100 ROLLINS ROAD 3931 JEFFERSON AVE MILLBRAE, CA WOODSIDE, CA FOR: STEM, INC. FOR: MEGAWATT STORAGE FARMS, INC. SUE MARA LISA-MARIE CLARK CONSULTANT RTO ADVISORS, LLC LEGAL DIVISION 164 SPRINGDALE WAY ROOM 4300 REDWOOD CITY, CA VAN NESS AVENUE

8 CPUC - Service Lists - A Page 2 of 4 7/11/2016 FOR: ALLIANCE FOR RETAIL ENERGY MARKETS SAN FRANCISCO, CA AND DIRECT ACCESS CUSTOMER COALITION FOR: ORA HAYLEY GOODSON NINA SUETAKE STAFF STAFF THE UTILITY REFORM NETWORK THE UTILITIY REFORM NETWORK 785 MARKET ST., STE MARKET STREET, SUITE 1400 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: TURN EVELYN C. LEE GREGORY MORRIS DIRECTOR PACIFIC GAS AND ELECTRIC COMPANY GREEN POWER INSTITUTE PO BOX SHATTUCK AVENUE, STE 402 SAN FRANCISCO, CA BERKELEY, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: THE GREEN POWER INSTITUTE C. C. SONG STEVEN S. SHUPE REGULATORY ANALYST GENERAL COUNSEL MARIN CLEAN ENERGY SONOMA CLEAN POWER AUTHORITY 1125 TAMALPAIS AVE. 50 SANTA ROSA AVE., 5THFL. SAN RAFAEL, CA SANTA ROSA, CA FOR: MARIN CLEAN ENERGY FOR: SONOMA CLEAN POWER AUTHORITY Information Only MIKE CADE ALCANTAR & KAHL ONLY ONLY, CA TRINA HORNER CONSULTANT LEAN ENERGY US ONLY ONLY, CA PACIFIC GAS AND ELECTRIC COMPANY MRW & ASSOCIATES, LLC ONLY ONLY ONLY, CA ONLY, CA KELLY CRANDALL DANIEL DOUGLASS KEYES, FOX & WIEDMAN, LLP 1580 LINCOLN STEET, SUITE 880 DOUGLASS & LIDDELL DENVER, CO PARK GRANADA, SUITE 209 CALABASAS, CA DANIEL KELLY HANNON RASOOL EXECUTIVE DIRECTOR ADMIN. - CALIF. REGULATORY AFFAIRS UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY 3405 KENYON STREET, SUITE CENTURY PARK CT. CP32D SAN DIEGO, CA SAN DIEGO, CA 92123

9 CPUC - Service Lists - A Page 3 of 4 7/11/2016 WILLIAM P. FULLER REGULATORY CASE ANALYST REGULATORY CASE ADMINISTRATOR SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP13E 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA SAN DIEGO, CA SAN DIEGO GAS & ELECTRIC COMPANY ANTHONY HARRISON CENTRAL FILES MGR. - REGULATORY AFFAIRS 8330 CENTURY PARK COURT STEM, INC. SAN DIEGO, CA ROLLINS RD. MILLBRAE, CA CHARLES R. MIDDLEKAUFF WADE A. GREENACRE PACIFIC GAS AND ELECTRIC COMPANY REGULATORY CASE COORDINATOR LAW DEPT. PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, B30A / PO BOX BEALE ST., MC B9A SAN FRANCISCO, CA SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS CASE ADMINISTRATION 425 DIVISADERO ST. SUITE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE STREET, MC B9A SAN FRANCISCO, CA TAM HUNT MCE REGULATORY GREEN POWER INSTITUTE MARIN CLEAN ENERGY 2297 SHATTUCK AVENUE 1125 TAMALPAIS AVENUE BERKELEY, CA SAN RAFAEL, CA PHILLIP MULLER CAROLYN KEHREIN PRESIDENT ENERGY MANAGEMENT SERVICES SCD ENERGY SOLUTIONS ENERGY USERS FORUM 436 NOVA ALBION WAY 2602 CELEBRATION WAY SAN RAFAEL, CA WOODLAND, CA KEVIN WOODRUFF SCOTT BLAISING WOODRUFF EXPERT SERVICES COUNSEL TH STREET, SUITE 514 BRAUN BLAISING MCLAUGHLIN & SMITH P.C. SACRAMENTO, CA L STREET, SUITE 1480 SACRAMENTO, CA TY TOSDAL JEFFERY D. HARRIS OF COUNSEL BRAUN BALISING MCLAUGHLIN & SMITH, P.C. ELLISON SCHNEIDER & HARRIS LLP 915 L. STREET, SUITE CAPITOL AVENUE, STE. 400 SACRAMENTO, CA SACRAMENTO, CA ANDREW B. BROWN AT LAW ELLISON SCHNEIDER & HARRIS LLP ANN L. TROWBRIDGE DAY CARTER & MURPHY LLP

10 CPUC - Service Lists - A Page 4 of 4 7/11/ CAPITOL AVENUE, SUITE AMERICAN RIVER DR., STE. 205 SACRAMENTO, CA SACRAMENTO, CA State Service MICHELLE COOKE AMY C. BAKER ADMINISTRATIVE LAW JUDGE CALIFORNIA PUBLIC UTILITIES COMMISSION RISK ASSESSMENT AND ENFORCEMENT ONLY ROOM ONLY, CA VAN NESS AVENUE SAN FRANCISCO, CA JOSE ALIAGA-CARO KARIN M. HIETA INFRASTRUCTURE PLANNING AND PERMITTING B ELECTRICITY PLANNING & POLICY BRANCH AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MANISHA LAKHANPAL REGINA DEANGELIS COMMUNICATIONS AND WATER POLICY BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA ROSANNE O'HARA ELECTRICITY PLANNING & POLICY BRANCH AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS