BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to consider policy and implementation refinements to the Energy Storage Procurement Framework and Design Program (D , D ) and related Action Plan of the California Energy Storage Roadmap. Rulemaking (Filed March 26, 2015) COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE ORDER INSTITUTING RULEMAKING TO CONSIDER POLICY AND IMPLEMENTATION REFINEMENTS TO THE ENERGY STORAGE PROCUREMENT FRAMEWORK AND DESIGN PROGRAM WILLIAM V. WALSH AMBER DEAN WYATT Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: May 4, 2015

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to consider policy and implementation refinements to the Energy Storage Procurement Framework and Design Program (D , D ) and related Action Plan of the California Energy Storage Roadmap. Rulemaking (Filed March 26, 2015) COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE ORDER INSTITUTING RULEMAKING TO CONSIDER POLICY AND IMPLEMENTATION REFINEMENTS TO THE ENERGY STORAGE PROCUREMENT FRAMEWORK AND DESIGN PROGRAM I. INTRODUCTION Pursuant to the California Public Utilities Commission s ( Commission ) Order Instituting Rulemaking to consider policy and implementation refinements to the Energy Storage Procurement Framework and Design Program ( Storage OIR ), 1 Southern California Edison Company ( SCE ) hereby submits its comments on the Storage OIR s scope and schedule. In summary, SCE makes the following three recommendations: 1 Order Instituting Rulemaking, ( R. ) , Order Instituting Rulemaking to consider policy and implementation refinements to the Energy Storage Procurement Framework and Design Program (D , D ) and related Action Plan of the California Energy Storage Roadmap (April 2, 2015) at 16. 2

3 The Storage OIR should not address issues being addressed in other proceedings such as the Distributed Resources Plan Order Instituting Rulemaking ( DRP OIR ); 2 The Commission should divide the Storage OIR into two phases to first address issues impacting the utilities March 2016 storage procurement plan applications; and The Commission should clarify issue 4(b) regarding explor[ing the] use of nonutility storage assets by third parties to provide permitted service to multiple customers by explaining the problem the Commission is seeking to address and the assumptions underlying the examples provided. II. THE STORAGE OIR SHOULD NOT ADDRESS ISSUES THAT ARE BEING ADDRESSED IN OTHER PROCEEDINGS SUCH AS THE DRP OIR The Commission s preliminary scoping memo for the Storage OIR includes certain issues already being addressed in other proceedings. Most notably, issue 3(a) would direct the Commission and parties in the proceeding to examine and clarify opportunities for storage to defer/displace transmission and distribution upgrades. 3 The issue of storage and other distributed generation displacing transmission and distribution ( T&D ) upgrades is being examined in the DRP OIR. 4 Addressing the same issues in different proceedings is inefficient and may result in inconsistent decisions on the issues. Further, because non-storage distributed energy resources ( DERs ) can also defer or displace T&D upgrades, it is not appropriate to consider storage alone without also considering how other resources may defer T&D upgrades. Accordingly, SCE 2 R , Order Instituting Rulemaking Regarding Policies, Procedures and Rules for Development of Distribution Resources Plans Pursuant to Public Utilities Code 769 (August 20, 2014). 3 Storage OIR at The DRP Guidance requires that the locational net benefits methodology for DERs include locationspecific values including the value from avoided distribution, sub-transmission, and transmission capital and operating expenditures. See R , Attachment to Assigned Commissioner s Ruling on Guidance for Public Utilities Code Section 760 Distribution Resource Planning (February 6, 2015) ( DRP ACR ) at 4. 3

4 suggests that the Commission remove issue 3(a) on T&D deferral from the scope of the Storage OIR and closely monitor the DRP OIR for its impact on energy storage. Additionally, the DRP OIR is already addressing some components of the safety and valuation of all DERs, including energy storage. For example, on safety, the DRP OIR is investigating potential new reliability and safety standards for DERs. 5 Further, on valuation, the DRP OIR requires a new net benefits methodology that includes location-specific value, like transmission and distribution deferral value and societal avoided costs. 6 To the extent that the DRP OIR is already addressing certain components of safety and valuation, those components should not be addressed again in the Storage OIR s proposed issues 1(d) on utility safety standards and certifications 7 and 3(c) on refinements to CEP and valuation methodologies. 8 Instead, as stated above, the Commission should closely monitor the DRP OIR for its impact on energy storage. III. THE COMMISSION SHOULD DIVIDE THE OIR INTO TWO PHASES TO FIRST ADDRESS ISSUES AFFECTING THE UTILITIES MARCH 2016 STORAGE PROCUREMENT PLAN APPLICATIONS The Commission proposed a comprehensive list of twelve issues to address in the new Storage OIR. Resolving all of these issues will be time consuming, possibly taking more than a year, especially given the complexity of some issues such as those impacting multiple jurisdictions. 9 Still, Decision ( D. ) requires the utilities to file their 2016 Storage Procurement Plan applications by March 1, Given that a number of the issues identified in the Storage OIR could affect the utilities 2016 Storage Procurement Plans, it is important that the Commission rule on those issues before the utilities develop their 2016 Storage Procurement Plans. Accordingly, 5 DRP ACR, Attachment at DRP ACR, Attachment at 4. 7 Storage OIR at Id. at Issues 3(b) and 4(a) identified by the Order Instituting Rulemaking address storage across multiple jurisdictions. Storage OIR at

5 SCE suggests that the Commission split the Storage OIR into two phases. Phase 1 would address the issues most relevant to the utilities 2016 Storage Procurement Plans, while Phase 2 would address the remainder of the issues. The Commission should issue a final decision on Phase 1 by November 2015 at the latest so the utilities can have enough time to incorporate any new policy direction into their plans for achieving their 2016 storage targets. Given their relevance to the utilities procurement plans, SCE suggests the following issues be included in Phase 1 of the Storage OIR: 1(a) develop a measurement and evaluation plan for 2016; 1(b) assess best practices and challenges with the procurement process; 1(c) consider revising allocation / flexibility of targets within grid-domains; 2(a) clarify rules on storage technology eligibility and definitions; 2(b) clarify issues related to PCIA to recover above-market stranded and Dual Usage cost recovery methodologies; and 2(c) consider PCIA treatment to the life of the contract beyond ten years. IV. THE COMMISSION SHOULD CLARIFY ISSUE 4(B), INCLUDING THE PROBLEM THE COMMISSION IS SEEKING TO ADDRESS AND THE ASSUMPTIONS UNDERLYING THE EXAMPLES PROVIDED IN THE OIR Issue 4(b) of the Storage OIR says that the Commission will explore use of non-utility storage assets by third parties to provide permitted services to multiple customers. 10 The Commission provides two high-level examples of applications that it would like to facilitate including (1) storage supporting electric vehicle charging stations in a multi-tenant building; and (2) storage connected to community-owned solar for virtual net energy metering. In the upcoming scoping memo on the Storage OIR, the Commission should more clearly define the problem that it 10 Storage OIR at 15. 5

6 is trying to solve. In particular, if the Commission is focused on those two particular storage applications that it provides as examples, then the Commission should provide more information on exactly what functions it wants to facilitate that cannot be facilitated today. Further, although SCE is not necessarily opposed to the inclusion of issue 4(b) in the scope of the Storage OIR (in Phase 2), SCE cautions that the two examples provided in issue 4(b) raise legal and policy concerns, including whether and to what extent these examples involve FERC jurisdictional sales for resale, Commission jurisdictional issues related to public utility service versus direct access service, and rate design and cost shifting issues. V. CONCLUSION SCE appreciates the opportunity to provide these comments on the scope and schedule for the Storage OIR and suggests the Commission to adopt the recommendations contained herein. SCE looks forward to working with the Commission and other stakeholders to resolve outstanding storage policy issues. Respectfully submitted, WILLIAM V. WALSH AMBER DEAN WYATT /s/ Amber Dean Wyatt By: Amber Dean Wyatt Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY May 4, Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626)

7 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to consider policy and implementation refinements to the Energy Storage Procurement Framework and Design Program (D , D ) and related Action Plan of the California Energy Storage Roadmap. Rulemaking (Filed March 26, 2015) 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 COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON THE ORDER INSTITUTING RULEMAKING TO CONSIDER POLICY AND IMPLEMENTATION REFINEMENTS TO THE ENERGY STORAGE PROCUREMENT FRAMEWORK AND DESIGN PROGRAM on all parties identified on the attached service list(s) R Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in properly addressed sealed envelopes and causing such copies to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s): ALJ Melissa K. Semcer CPUC 505 Van Ness Avenue San Francisco, CA Placing copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to all parties for those listed on the attached non- list. Executed this May 4, 2015, at Rosemead, California. /s/ Marcella Davis Marcella Davis Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY Post Office Box Walnut Grove Avenue Rosemead, California 91770

8 CPUC - Service Lists - R Page 1 of 5 5/4/2015 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO CONSID FILER: CPUC LIST NAME: LIST LAST CHANGED: MAY 4, 2015 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties KENNETH SAHM WHITE RACHEL GOLD CLEAN COALITION POLICY DIRECTOR LARGE-SCALE SOLAR ASSOCIATION, CA FOR: CLEAN COALITION, CA FOR: LARGE-SCALE SOLAR ASSOCIATION J. DOUGLAS DIVINE DANIEL W. DOUGLASS CHIEF EXECUTIVE OFFICER ATTORNEY EAGLE CREST ENERGY COMPANY DOUGLASS & LIDDELL 3000 OCEAN PARK BVLD., STE OXNARD ST., STE SANTA MONICA, CA WOODLAND HILLS, CA FOR: EAGLE CREST ENERGY COMPOANY FOR: ALLIANCE FOR RETAIL ENERGY MARKETS, DIRECT ACCESS CUSTOMER COALITION, WESTERN POWER TRADING FORUM GREG BASS PAUL A. SZYMANSKI DIR SR. COUNSEL NOBLE AMERICAS ENERGY SOLUTIONS LLC SAN DIEGO GAS & ELECTRIC COMPANY 401 WEST A STREET, SUITE ASH STREET HQ 12B SAN DIEGO, CA SAN DIEGO, CA FOR: NOBLE AMERICAS ENERGY SOLUTIONS LLC FOR: SAN DIEGO GAS & ELECTRIC COMPANY KELLEY GAGE CHRISTOPHER J. GRIECO SAN DIEGO COUNTY WATER AUTHORITY EXECUTIVE V.P OVERLAND AVENUE GRAVITY POWER, LLC SAN DIEGO, CA B HOLLISTER AVENUE, STE. B FOR: SAN DIEGO COUNTY WATER AUTHORITY GOLETA, CA (SDCWA) FOR: GRAVITY POWER, LLC PIERRE BULL MICHAEL DAY NATURAL RESOURCES DEFENSE COUNCIL GOODIN MACBRIDE SQUERI & DAY LLP 111 SUTTER STREET, 20TH FLOOR 505 SANSOME STREET, STE. 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: NATURAL RESOURCES DEFENSE COUNCIL FOR: ABENGOA SOLAR

9 CPUC - Service Lists - R Page 2 of 5 5/4/2015 SEAN P. BEATTY WILLIAM ROSTOV NRG ENERGY, INC, STAFF ATTORNEY 100 CALIFORNIA STREET, SUITE 650 EARTHJUSTICE SAN FRANCISCO, CA CALIFORNIA ST., STE. 500 FOR: NRG ENERGY, INC. SAN FRANCISCO, CA FOR: SIERRA CLUB MEGAN M. MYERS JASON B. KEYES LAW OFFICES OF SARA STECK MYERS ATTORNEY TH AVENUE KEYES FOX & WIEDMAN LLP SAN FRANCISCO, CA TH STREET, STE FOR: CENTER FOR ENERGY EFFICIENCY AND OAKLAND, CA RENEWABLE TECHNOLOGIES (CEERT) FOR: SOLARCITY CORPORATION GREGG MORRIS DAVID KATES GREEN POWER INSTITUTE DAVID MARK & COMPANY 2039 SHATTUCK AVE., SUTE UNOCAL PLACE, SUITE 200 BERKELEY, CA SANTA ROSA, CA FOR: GREEN POWER INSTITUTE FOR: THE NEVADA HYDRO COMPANY VIRINDER SINGH DIR - REGULATORY & LEGISLATIVE AFFAIRS EDF RENEWABLE ENERGY 1000 SW BROADWAY, SUITE 1880 PORTLAND, OR FOR: EDF RENEWABLE ENERGY Information Only BRIAN KORPICS BRIAN THEAKER POLICY MANAGER DIRECTOR - REGULATORY AFFAIRS CLEAN COALITION NRG ENERGY, INC., CA 00000, CA CASE COORDINATION DANIELLE OSBORNE MILLS PACIFIC GAS AND ELECTRIC COMPANY SENIOR POLICY ADVISOR LARGE-SCALE SOLAR ASSOCIATION, CA 00000, CA DIANE FELLMAN ELI HARLAND DIR - GOVERNMENTAL & REGULATORY AFFAIRS CALIFORNIA ENERGY COMMISSION NRG ENERGY, INC. ENERGY RESEARCH & DEVELOPMENT DIV., CA 00000, CA EVELYN LEE JAMIE L MAULDIN PACIFIC GAS & ELECTRIC COMPANY ADAMS BROADWELL JOSEPH & CARDOZO, CA 00000, CA FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES JEREMY WAEN JOHN W. LESLIE, ESQ REGULATORY ANALYST MCKENNA LONG & ALDRIDGE LLP MARIN CLEAN ENERGY, CA 00000, CA JONATHAN HART MARK HUFFMAN CENTER FOR SJUSATINABLE ENERGY LAW DEPT PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA MCE REGULATORY PETER T. PEARSON MARIN CLEAN ENERGY ENERGY SUPPLY SPECIALIST BEAR VALLEY ELECTRIC SERVICE, CA 00000, CA 00000

10 CPUC - Service Lists - R Page 3 of 5 5/4/2015 PRAMOD KULKARNI REBECCA FEUERLICHT CUSTOMIZED ENERGY SOLUTIONS CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA SACHU CONSTANTINE SEPHRA A. NINOW CENTER FOR SUSTAINABLE ENERGY REGULATORY AFFAIRS MGR. CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA THOMAS ASHLEY UDI HELMAN DIRECTOR OF GOVERNMENT AFFAIRS HELMAN ANALYTICS GREENLOTS, CA 00000, CA WADE A. GREENACRE REGULATORY CASE MGR. MARIN CLEAN ENERGY PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA MRW & ASSOCIATES, LLC MIKE FERRY CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA TONY SIEBERT STEVEN ZURETTI ZBB ENERGY CORPORATION DIR - REGULATORY AFFAIRS N93 W14475 WHITTAKER WAY BROOKFIELD ENERGY MARKETING, INC. MENOMONEE FALLS, WI RUBY PL LOS ANGELES, CA MILISSA MARONA GREGORY S. G. KLATT DIR - GOV'T & UTILITY RELATIONS ATTORNEY CODA ENERGY DOUGLASS & LIDDELL 135 E. MAPLE AVE OXNARD ST., STE MONROVIA, CA WOODLAND HILLS, CA HANNON RASOOL WILLIAM P. FULLER ADMIN. - CALIF. REGULATORY AFFAIRS REGULATORY CASE MANAGER SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT. CP32D 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA SAN DIEGO, CA SUE MARA MARC D. JOSEPH CONSULTANT ADAMS, BROADWELL, JOSEPH & CARDOZO RTO ADVISORS, LLC 601 GATEWAY BLVD., STE SPRINGDALE WAY SOUTH SAN FRANCISCO, CA REDWOOD CITY, CA ARTHUR HAUBENSTOCK BILL KISSINGER MORGAN LEWIS BOCKIUS LLP MORGAN LEWIS & BOCKIUS LLP ONE MARKET, SPEAR STREET TOWER ONE MARKET, SPEAR STREET TOWER SAN FRANCISCO, CA SAN FRANCISCO, CA DEVIN MCDONELL MATTHEW VESPA MORGAN LEWIS BOCKIUS LLP SR. ATTORNEY ONE MARKET, SPEAR STREET TOWER SIERRA CLUB SAN FRANCISCO, CA SECOND ST,, 2ND FL SAN FRANCISCO, CA SARAH KEANE SHERIDAN J. PAUKER, ESQ. ATTORNEY REGULATORY COUNSEL MORGAN LEWIS & BOCKIUS, LLP WILSON SONSINI GOODRICH & ROSATI ONE MARKET, SPEAR STREET TOWER ONE MARKET PLAZA, SPEAR TOWER, STE 3300 SAN FRANCISCO, CA SAN FRANCISCO, CA MONICA SCHWEBS ADENIKE ADEYEYE MORGAN LEWIS BOCKIUS, LLP EARTHJUSTICE ONE MARKET, SPEAR STREET TOWER 50 CALIFORNIA ST., STE. 500 SAN FRANCISCO, CA SAN FRANCISCO, CA RIKKI WEBER YANA GARCIA

11 CPUC - Service Lists - R Page 4 of 5 5/4/2015 LITIGATION ASSISTANT EARTHJUSTICE EARTHJUSTICE 50 CALIFORNIA STREET, SUITE CALIFORNIA STREET, SUITE 500 SAN FRANCISCO, CA SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS CHARLES R. MIDDLEKAUFF 425 DIVISADERO ST., STE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE STREET, B30A, PO BOX 7442 SAN FRANCISCO, CA SARA STECK MYERS ANDY SCHWARTZ ATTORNEY AT LAW SOLARCITY LAW OFFICES OF SARA STECK MYERS 3055 CLEARVIEW WAY TH AVENUE SAN MATEO, CA SAN FRANCISCO, CA GENEVIEVE DUFAU-MCCARTHY EMMIE STENSTEDT SOLARCITY CORPORATION ELSYS INC CLEARVIEW WAY 4966 HUMMINGBIRD ROAD SAN MATEO, CA PLEASANTON, CA BEVIN HONG SAMUEL J. HARVEY UTILITY SALES DIRECTOR KEYES FOX & WIEDMAN LLP ZBB ENERGY CORPORATION TH STREET, SUITE WOODLAND CT. SAN FRANCISCO, CA SAN RAMON, CA TANDY MCMANNES PHILLIP MULLER ABENGOA SOLAR PRESIDENT I KAISER PLAZA, STE SCD ENERGY SOLUTIONS OAKLAND, CA NOVA ALBION WAY SAN RAFAEL, CA DEDRICK ROPER C. SUSIE BERLIN CHARGEPOINT, INC. LAW OFFICES OF SUSIE BERLIN 254 E. HACIENDA 1346 THE ALAMEDA, STE. 7, NO. 141 CAMPBELL, CA SAN JOSE, CA CHASE KAPPEL CHRISTA LIM ELLISON SCHNEIDER & HARRIS, LLP ELLISON SCHNEIDER & HARRIS, LLP 2600 CAPITOL AVE., SUITE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA ANDREW B. BROWN DOUGLAS K. KERNER ELLISON, SCHNEIDER & HARRIS L.L.P. ATTORNEY AT LAW 2600 CAPITOL AVE, SUITE 400 ELLISON, SCHNEIDER & HARRIS, LLP SACRAMENTO, CA CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA JEFFERY D. HARRIS LYNN M. HAUG ELLISON, SCHNEIDER & HARRIS LLP ELLISON, SCHNEIDER & HARRIS LLP 2600 CAPITOL AVENUE, SUITE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRMENTO, CA ANN L. TROWBRIDGE JACK ELLIS ATTORNEY AT LAW 1425 ALPINE WAY / PO BOX 6600 DAY CARTER & MURPHY LLC TAHOE CITY, CA AMERICAN RIVER DRIVE, SUITE 205 SACRAMENTO, CA FOR: GILL RANCH STORAGE, LLC SARAH ADAMS BUSINESS DEVELOPMENT NW NATURAL 220 NW SECOND AVENUE PORTLAND, OR FOR: GILL RANCH STORAGE, LLC State Service MARC MONBOUQUETTE CALIFORNIA PUBLIC UTILITIES COMMISSION ENERGY DIVISION AMY C. BAKER CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION

12 CPUC - Service Lists - R Page 5 of 5 5/4/2015 ROOM 5210, CA VAN NESS AVENUE SAN FRANCISCO, CA ARTHUR J. O'DONNELL GABRIEL PETLIN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION GAS SAFETY AND RELIABILITY BRANCH DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MELISSA K. SEMCER ROSANNE O'HARA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PLANNING & POLICY BRANCH ROOM 5102 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA XIAO SELENA HUANG JOHN MATHIAS CALIF PUBLIC UTILITIES COMMISSION ELECTRIC GENERATION SPECIALIST BROADBAND, POLICY & ANALYSIS BRANCH CALIFORNIA ENERGY COMMISSION AREA 3-D 1516 NINTH STREET, MS VAN NESS AVENUE SACRAMENTO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

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