BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Approval of the Results of Its 2016 Energy Storage and Distribution Deferral Request for Offers. Application No (Filed December 1, 2017) And Related Matter. Application No REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON PROPOSED DECISION APPROVING ENERGY STORAGE AGREEMENTS AND ASSOCIATED COST RECOVERY MECHANISMS JANET S. COMBS TRISTAN REYES CLOSE Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Dated: October 2, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Approval of the Results of Its 2016 Energy Storage and Distribution Deferral Request for Offers. Application No (Filed December 1, 2017) And Related Matter. Application No REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON PROPOSED DECISION APPROVING ENERGY STORAGE AGREEMENTS AND ASSOCIATED COST RECOVERY MECHANISMS I. INTRODUCTION Pursuant to Rule 14.3(a) of the California Public Utilities Commission s ( Commission ) Rules of Practice and Procedure, Southern California Edison Company ( SCE ) respectfully submits the following reply comments in response to the opening comments of the California Energy Storage Alliance ( CESA ) and the Joint Parties, which includes the Alliance for Retail Energy Markets ( AReM ), the Direct Access Customer Coalition ( DACC ), Marin Clean Energy ( MCE ), Silicon Valley Clean Energy ( SVCE ), Peninsula Clean Energy ( PCE ), and Sonoma Clean Power ( SCP ), on Administrative Law Judge ( ALJ ) Stevens Proposed Decision Approving Energy Storage Agreements and Associated Cost Recovery Mechanisms, dated September 7, 2018 ( PD ). 1

3 II. SCE OBJECTS TO AN AMENDMENT TO THE PD RECOGNIZING THE NEED FOR THE COMMISSION TO ADOPT A UNIFORM COST ALLOCATION POLICY FOR MULTIPLE-USE APPLICATIONS In their opening comments, both CESA and the Joint Parties recommend the development of a uniform cost allocation policy for energy storage multiple-use applications ( MUAs ). 1 The Joint Parties also request that the PD be amended to include a new Finding of Fact explicitly recognizing the need for the Commission to develop a uniform cost allocation policy for multi-use ES projects. 2 SCE objects to the Joint Parties request to amend the PD to include the following proposed Finding of Fact: There is a clear, time-sensitive need for the Commission to consider and adopt a uniform cost allocation methodology for multiple use energy storage systems. 3 First, the issue of whether the Commission should adopt a uniform cost allocation methodology is not in the scope of this proceeding, 4 thus the issue has not been fully developed and considered. Moreover, contrary to the Joint Parties comments, SCE does not agree that the need for such a methodology is clearly established in the record for this proceeding. 5 SCE also disagrees that there is a need for the Commission to adopt a uniform cost allocation methodology for MUAs. 6 MUAs for energy storage resources refer to energy storage providing multiple services to different entities or jurisdictions. 7 The Commission s objectives in developing rules and guidance addressing MUAs are to enable energy storage systems to stack incremental value and revenue streams by delivering multiple services to the wholesale market, 1 CESA s Opening Comments on PD at 6-7; Joint Parties Opening Comments on PD at 5. 2 Joint Parties Opening Comments on PD at 5. 3 Id. 4 Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judges at Joint Parties Opening Comments on PD at 5 (emphasis added). 6 Id. 7 D at 5. 2

4 distribution grid, transmission system, resource adequacy requirements, and customers in whatever procurement venue the storage systems participate. 8 Therefore, MUA-related Commission policies so far have been appropriately focused on enabling energy storage systems to deliver multiple services to various entities in different domains, rather than deciding a priori how a utility procuring such multiple services from a storage system should allocate the underlying costs. While cost allocation for energy storage systems providing multiple services is an important issue, it is one that will, and should be, addressed by the Commission in the relevant proceeding in which approval for the cost recovery of such an energy storage system is being sought, consistent with D This is appropriate given that there are many possible permutations of energy storage services that the utility might be procuring such that uniform cost allocation may not make sense. For example, CESA questions how wholesale market revenues should be credited to distribution reliability costs. 10 This is all dependent on the terms of the contract, and furthermore, dependent on which of the energy storage system s products or services is being procured for the purpose of distribution reliability. If the underlying products are procured and utilized for distribution reliability, and if these products also earn wholesale revenues, such revenues would simply offset the distribution reliability costs. On the other hand, a utility might procure multiple services from the same energy storage system, with only some of the services designed for distribution reliability, while other services providing energy, capacity or ancillary services are unrelated to distribution reliability; revenue from these latter services, if monetized in wholesale markets, might be treated differently based on who receives the benefits of the services. Similarly, if the utility transaction with the energy storage system looks like a 8 Id. at 9. 9 In D , the Commission ordered that the investor-owned utilities must file their respective Dual Use cost recovery methodology for combined generation/distribution storage projects if and when they propose such projects to the Commission for approval. D at 119 (Ordering Paragraph 1(7)). 10 CESA s Opening Comments on PD at 7. 3

5 tolling arrangement, then, much like the cost allocation mechanism ( CAM ), there would be an expectation that the net revenue would be credited against the capacity cost. Simply put, this is not a one-size-fits-all issue. The issue will need to be addressed based upon the circumstances of the contracts just like any cost allocated procurement. Furthermore, the changing nature of the grid will impact the value and the variables in the terms and conditions of a contract further complicating potential uniform cost allocation for MUAs. III. CONCLUSION SCE appreciates the opportunity to provide reply comments. As discussed in its Opening Comments on the PD, SCE supports the ALJ s PD and respectfully requests the Commission adopt the PD without modification as its final decision. Respectfully submitted, JANET S. COMBS TRISTAN REYES CLOSE /s/ Tristan Reyes Close By: Tristan Reyes Close Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Tristan.ReyesClose@sce.com October 2,

6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Approval of the Results of Its 2016 Energy Storage and Distribution Deferral Request for Offers. Application No (Filed December 1, 2017) And Related Matter. Application No 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 REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON PROPOSED DECISION APPROVING ENERGY STORAGE AGREEMENTS AND ASSOCIATED COST RECOVERY MECHANISMS on all parties identified on the attached service list for A , et al. Service was effected by transmitting copies via to ALJ Michelle Cooke and all parties who have provided an e- mail address and by placing copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to the office of the assigned ALJ and/or other addressees. ALJ Brian Stevens California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue, Room 5023 San Francisco, CA Executed on October 2, 2018, at Rosemead, California. /s/ Olivia Gutierrez Olivia Gutierrez SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

7 CPUC - Service Lists - A Page 1 of 4 10/2/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - FOR APPROVA FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: SEPTEMBER 25, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties TRISTAN REYES CLOSE SUE MARA SENIOR ATTORNEY CONSULTANT SOUTHERN CALIFORNIA EDISON COMPANY RTO ADVISORS L.L.C WALNUT GROVE AVENUE PO BOX SPRINGDALE WAY ROSEMEAD, CA REDWOOD CITY, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: ALLIANCE FOR RETAIL ENERGY MARKETS, DIRECT ACCESS CUSTOMER COALITION ROSANNE O'HARA HAYLEY GOODSON STAFF ATTORNEY LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM MARKET ST., STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: ORA GRADY MATHAI-JACKSON MELISSA BRANDT PACIFIC GAS AND ELECTRIC COMPANY SR. DIR - PUBLIC AFFAIRS & GEN. COUNSEL 77 BEALE STREET, B30A EAST BAY COMMUNITY ENERGY SAN FRANCISCO, CA BROADWAY, STE 3000 FOR: PACIFIC GAS AND ELECTRIC COMPANY OAKLAND, CA FOR: EAST BAY COMMUNITY ENERGY ALEX MORRIS GREGORY MORRIS SR. DIR., POLICY & REGULATORY AFFAIRS DIRECTOR CALIFORNIA ENERGY STORAGE ALLIANCE GREEN POWER INSTITUTE 2150 ALLSTON WAY, SUITE SHATTUCK AVENUE, STE 402

8 CPUC - Service Lists - A Page 2 of 4 10/2/2018 BERKELEY, CA BERKELEY, CA FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: GREEN POWER INSTITUTE (CESA) DAVID PEFFER ATTORNEY AT LAW BRAUN BLAISING SMITH WYNNE, P.C. 915 L STREET, SUITE 1480 SACRAMENTO, CA FOR: CCA PARTIES: MARIN CLEAN ENERGY (MCE), PENINSULA CLEAN ENERGY (PCE), SILICON VALLEY CLEAN ENERGY (SVCE), AND THE SONOMA CLEAN POWER AUTHORITY (SCP) Information Only C.C. SONG CASE COORDINATION REGULATORY ANALYST PACIFIC GAS AND ELECTRIC COMPANY MARIN CLEAN ENERGY, CA 00000, CA DONALD LIDDELL EBCE REGULATORY DOUGLASS & LIDDELL EAST BAY COMMUNITY ENERGY, CA 00000, CA HILARY STAVER JOSEPH WIEDMAN SILICON VALLEY CLEAN ENERGY PENNINSULA CLEAN ENERGY, CA 00000, CA MATTHEW PLUMMER NEAL REARDON STATE AGENCY REGULATIONS REGULATORY AFFAIRS MANAGER PACIFIC GAS AND ELECTRIC COMPANY SONOMA CLEAN POWER, CA 00000, CA PASCHELLE WHITE REGULATORY CLERK REGULATORY CASE COORDINATOR BRAUN BLAISING SMITH WYNNE, PC PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA MRW & ASSOCIATES, LLC, CA AMBER DEAN WYATT SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. ROSEMEAD, CA CASE ADMINISTRATION KAJ PETERSON SOUTHERN CALIFORNIA EDISON COMPANY 8631 RUSH STREET ELECTRICITY PLANNING & POLICY BRANCH ROSEMEAD, CA AREA

9 CPUC - Service Lists - A Page 3 of 4 10/2/ VAN NESS AVENUE SAN FRANCISCO, CA SONJA ZIAJA ERIC BORDEN ENERGY POLICY ANALYST ELECTRICITY PLANNING & POLICY BRANCH THE UTILITY REFORM NETWORK AREA 785 MARKET STREET, STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JESSICA TELLEZ ALICE L. HARRON ENERGY SUPPLY PROCEEDINGS CEO PACIFIC GAS AND ELECTRIC COMPANY HARRON, LLC PO BOX EVERETT AVE. SAN FRANCISCO, CA OAKLAND, CA KEVIN WOODRUFF SCOTT BLAISING CONSULTANT ATTORNEY WOODRUFF EXPERT SERVICES, INC. BRAUN BLAISING SMITH WYNNE, PC TH STREET, SUITE L STREET, STE SACRAMENTO, CA SACRAMENTO, CA FOR: TURN ANDREW B. BROWN TAM HUNT, J.D. ATTORNEY AT LAW CONSULTING ATTORNEY ELLISON SCHNEIDER HARRIS & DONLAN LLP COMMUNITY RENEWABLE SOLUTIONS, LLC 2600 CAPITAL AVENUE, SUITE MOKU ST SACRAMENTO, CA PAHOA, HI FOR: GREEN POWER INSTITUTE State Service MICHELLE COOKE ADMINISTRATIVE LAW JUDGE CALIFORNIA PUBLIC UTILITIES COMMISSION, CA AMIN NOJAN CARRIER OVERSIGHT AND PROGRAMS BRANCH AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA BRIAN STEVENS CHRISTOPHER MYERS DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PLANNING & POLICY BRANCH ROOM 5023 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA KARIN M. HIETA LEE-WHEI TAN ELECTRICITY PLANNING & POLICY BRANCH ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5010 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA

10 CPUC - Service Lists - A Page 4 of 4 10/2/2018 RACHEL MCMAHON SHANNON O'ROURKE INFRASTRUCTURE PLANNING AND PERMITTING B DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS