Regulatory Packet Part 3 — MCE Board of Directors, October 19, 2023

Docket No.: A.23-02-018
Exhibit No.:

Date: September 22, 2023
Witness: Brian Shuey

PREPARED DIRECT TESTIMONY OF BRIAN SHUEY

ON BEHALF OF

THE CALIFORNIA COMMUNITY CHOICE ASSOCIATION
IN PACIFIC GAS AND ELECTRIC COMPANY’S
2022 ERRA COMPLIANCE PROCEEDING
Public Version
i
Table of Contents
I. Introduction and summary of testimony .................................................................................. 1 II. PG&E counted a significant quantity of PCIA-eligible resources toward 2022 System Reliability Incremental Procurement targets. ........................................................................ 3 III. PG&E’s System RA position reports are inconsistent with PG&E’s claim that it had 923 MW of excess RA available during summer months in 2022. .............................................. 5 IV. PG&E did not offer to sell excess System RA to other LSEs prior to counting the capacity toward its System Reliability Incremental Procurement targets. ........................................... 7 V. LSEs have paid substantial fines because they were unable to procure sufficient RA capacity. .............................................................................................................................................. 11 VI. The Commission should scrutinize the assumptions used in PG&E’s position reporting and solicitation process. .............................................................................................................. 14 Attachments
Attachment A: Curriculum Vitae of Brian Shuey
Attachment B: PG&E Responses to CalCCA Data Requests
1 1 I. INTRODUCTION AND SUMMARY OF TESTIMONY
2 The California Community Choice Association (CalCCA) presents this direct 3 testimony in the Application of Pacific Gas and Electric Company (PG&E) for 4 Compliance Review of Utility Owned Generation Operations, Portfolio Allocation 5 Balancing Account (PABA) Entries, Energy Resource Recovery Account (ERRA) 6 Entries, Contract Administration, Economic Dispatch of Electric Resources, Utility 7 Owned Generation Fuel Procurement, and Other Activities for the Record Period 8 January 1 Through December 31, 2022 (Application). This testimony has been prepared 9 on behalf of CalCCA by Brian Shuey, Senior Manager, NewGen Strategies and 10 Solutions, LLC. Mr. Shuey’s qualifications are set forth in Attachment A. 11 CalCCA has a particular interest in the PABA, which is charged to CalCCA 12 members’ customers through the Power Charge Indifference Adjustment (PCIA) rates. 13 This testimony presents CalCCA’s recommendations on issues falling within scope of the 14 following items from the Assigned Commissioner’s Scoping Memo and Ruling in this case:1 15
16 1. Whether PG&E, during the record period, prudently administered and 17 managed, in compliance with all applicable rules, regulations and 18 Commission decisions, including but not limited to Standard of Conduct No. 19 4 (SOC 4), the following:
20 a. Utility-Owned Generation Facilities, except for the Elkhorn Battery 21 Energy Storage System and Pit 1 Powerhouse outages which will be 22 reviewed in the 2023 ERRA Compliance proceeding;
23 b. Qualifying Facilities (QF) Contracts; and
24 c. Non-QF Contracts.
1 Application (A.) 23-02-018, Assigned Commissioner’s Scoping Memo and Ruling at 2-3 (June 2, 2023) (Scoping Ruling).
2 1 If not, what adjustments, if any, should be made to account for imprudently 2 managed or administered resources?
3 2. Whether the entries recorded in the ERRA and the Portfolio Allocation 4 Balancing Account are reasonable, appropriate, accurate, and in compliance 5 with Commission decisions.
6 5. Whether PG&E administered resource adequacy procurement and sales 7 consistent with its Bundled Procurement Plan;
8 Based on my review of PG&E’s Application, supporting workpapers, and 9 responses to discovery I make the following recommendations:
10 • PG&E should be required to provide a detailed reconciliation between the 11 resource adequacy (RA) position reports used as the basis for its solicitations 12 offering to sell RA for delivery in 2022 and its final RA positions resulting in 13 excess capacity in June through October 2022.
14 • The Commission should scrutinize PG&E’s assumptions about resource 15 availability and the adjustments made to its RA position to ensure reductions 16 to capacity made available to the market are justified and to eliminate 17 potential overlap among categories.
18 • PG&E’s Bundled Procurement Plan (BPP) should be updated to ensure excess 19 capacity is made available to the market, either through refined adjustments to 20 available capacity in RA position reports or through market offers outside of 21 the scheduled solicitation process.
22 • The Commission should consider whether disallowance, penalty, or other 23 remedy is warranted for the 2022 record year based on PG&E’s non-24 compliance with Decision (D.) 21-12-015. 3 1 II. PG&E COUNTED A SIGNIFICANT QUANTITY OF PCIA-ELIGIBLE 2 RESOURCES TOWARD 2022 SYSTEM RELIABILITY INCREMENTAL
3 PROCUREMENT TARGETS.
4 In its Prepared Testimony, PG&E reported it transferred a total of 923 MW of 5 excess RA capacity from its existing PCIA-eligible resource portfolio to its Cost 6 Allocation Mechanism (CAM) portfolio to be counted toward its 2022 System Reliability Incremental Procurement requirement established in D.21-03-056.2 7 According to D.21- 8 12-015 if PG&E has not met its minimum contingency procurement target for June and 9 October it may:
10 “…use excess resources in its existing portfolios to meet the 11 minimum contingency procurement target (900 MW for PG&E and 12 SCE, and 200 MW for SDG&E), provided it has made reasonable attempts to sell this excess capacity to other LSEs.”3 13 14 15 Additionally, for the months of July, August, and September, excess resources may:
16 “… be used to meet or supplement these procurement targets up to 17 the upper end of its contingency procurement target (1,350 MW for 18 PG&E and SCE, and 300 MW for SDG&E), provided it has made reasonable attempts to sell this excess capacity to other LSEs.”4 19 20 As noted in D.21-12-015, PG&E is authorized to count excess RA capacity from 21 existing resources to meet its System Reliability Incremental Procurement targets 22 provided it has first made reasonable attempts to sell this excess capacity to other load 23 serving entities (LSEs). Because cost recovery for System Reliability Incremental 24 Procurement is through the CAM, the value of excess RA capacity provided by existing 25 resources must be transferred from the applicable balancing account to the CAM 26 balancing account (for PG&E, the New System Generation Balancing Account 2 PG&E’s Prepared Testimony, Chapter 12, page 12-15, lines 3-19. 3 D.21-02-015, Phase 2 Decision Directing PG&E, SCE, and SDG&E to take actions to prepare for potential extreme weather in the summers of 2022 and 2023, page 183 (emphasis added). 4 Id., page 184 (emphasis added).
4 1 (NSGBA)).
2 PG&E reports that it counted 923 MW of excess RA from existing PCIA-eligible resources, during the months of June through October of 2022.5 3 As required, PG&E 4 credited PABA and charged NSGBA for the value of the RA transferred to CAM. 5 Transfers were valued at the Forecasted 2022 System RA Adder for June through 6 September, prior to the publishing of the Final 2022 System RA Adder. PG&E trued-up 7 the entries through October and made an adjustment to account for the publishing of the 8 Final RA Adders. The total amount transferred to NSGBA was over the five 9 months. See Table 1 for the transfers by month.

Table 1: System RA Transfer from PABA to NSGBA6 10
11 12 CalCCA does not dispute that PG&E is authorized under D.21-12-015 and D.21- 13 03-056 to count excess RA capacity toward incremental procurement obligations. 14 However, even though PG&E appropriately credited the PABA for the PCIA resources it 15 borrowed, my testimony demonstrates that PG&E did not make reasonable attempts to 16 sell the ‘excess’ capacity to other LSEs as required by D.21-12-015. 5 See PG&E’s response to CalCCA data requests 2.19 and 2.58. 6 RA Transferred to CAM from PG&E 2022 IOU Excess Resources Summary Report, https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/resource-adequacy-homepage/resource-adequacy-compliance-materials/oct-2022pge-template-for-excess-resource-reporting-d2112015-public-083122.xlsx.

June July August September October Total
RA Transferred to NSGBA (MW) 103.70 183.14 148.97 156.70 330.00 922.51 System RA Transferred to NSGBA
$/kW
-
5 1 III. PG&E’S SYSTEM RA POSITION REPORTS ARE INCONSISTENT WITH 2 PG&E’S CLAIM THAT IT HAD 923 MW OF EXCESS RA AVAILABLE DURING 3 SUMMER MONTHS IN 2022.
4 PG&E’s BPP Appendix S explains that
5 6
7 8
9 10
11 12
13 14 PG&E creates a projected RA position at the time it holds each solicitation in order to determine the quantity of RA available for sale at that point in time.8 15 As part of 16 the Joint CCA Master Data Request included with PG&E’s filing in this case, PG&E 17 provided CalCCA the RA positions it prepared for each solicitation in which it offered to 18 sell RA with delivery during 2022. Table 2 summarizes PG&E’s System RA position for 19 the months of June through October 2022 as calculated at the time of each solicitation. 7 See PG&E’s Bundled Procurement Plan Appendix S Section B.3.b.1.a 8 See PG&E’s response to Joint CCA Master Data Request 1.08. -
6 1 Table 2: Summer System RA Position (MW)
2 3
4 5
6 7
8 PG&E reported a dramatically different picture to
9 the Commission in its 2022 Excess Resources Report. In that report, PG&E reported that 10 it had 923 MW of excess RA from existing resources during June through October 2022, including 183 MW in July and 330 MW in October.9 11
12 In response to CalCCA’s discovery requests, PG&E explained that it identified 13 the final quantity of excess RA capacity counted towards meeting System Reliability 14 Incremental Procurement targets between T-50 and T-30 days prior to each compliance month.10 15 That timing coincides with PG&E’s preparation of monthly RA supply plans required to be submitted to the CAISO 45 days prior to the compliance month.11 16 This 17 means, for example, that PG&E did not identify that it had 183 MW of excess RA for 9 Excess RA from PG&E 2022 IOU Excess Resources Summary Report, https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/resource-adequacy-homepage/resource-adequacy-compliance-materials/oct-2022pge-template-for-excess-resource-reporting-d2112015-public-083122.xlsx. 10 See PG&E’s response to CalCCA data request 3.26. 11 See CAISO Open Access Transmission Tariff Section 40.4.7.1.b.

RA Position Date Jun-22 Jul-22 Aug-22 Sep-22 Oct-22
8/23/2021 System RA Position
10/6/2021 System RA Position
11/22/2021 System RA Position
1/14/2022 System RA Position
4/11/2022 System RA Position
7/18/2022 System RA Position
7 1 July 2022 until sometime around May 12, 2022, while preparing its monthly RA supply 2 plan. But just 31 days earlier (for its April 11, 2022 solicitation), PG&E prepared a 3 System RA position report
.
12 4 For
5 October 2022, the change from PG&E’s System RA position report to 6 the amount of excess RA counted towards PG&E’s System Reliability Incremental 7 Procurement targets (330 MW excess)
8 9 IV. PG&E DID NOT OFFER TO SELL EXCESS SYSTEM RA TO OTHER LSES 10 PRIOR TO COUNTING THE CAPACITY TOWARD ITS SYSTEM
11 RELIABILITY INCREMENTAL PROCUREMENT TARGETS.
12 When asked to explain all attempts made to sell any portion of the 923 MW of 13 excess capacity, PG&E responded that it “attempts to sell all excess capacity, or its long 14 RA position, as determined by Appendix S [of the BPP], pursuant to the commercial processes in Appendix S.”13 15 Specifically, PG&E issued six solicitations offering to sell 16 System RA for delivery during the 2022 Compliance Year. PG&E held two year-ahead 17 solicitations in August 2021 and October 2021, in which PG&E projected out the 18 available RA for the full twelve months of 2022. PG&E also held four quarterly 19 solicitations in November 2021, January 2022, April 2022, and July 2022, projecting the 20 available RA for the remaining months of 2022 updated on a quarterly basis. 21 As described earlier, PG&E’s BPP prescribes
22 23
12 PG&E held no solicitations after April 11, 2022, offering to sell RA capacity in July 2022. 13 See PG&E’s response to CalCCA data request 2.54.
-
8 1 PG&E’s BPP
2 also states,
3 4
5 14 6
7 Table 3 summarizes the System RA offered for sale in each solicitation with 8 delivery periods from June through October 2022 based on PG&E’s projected System RA positions prepared at the time of each solicitation.15 9 Consistent with PG&E’s BPP 10 Appendix S,
11 12 Table 3: Summer System RA Volumes Offered for Sale by Solicitation (MW) 13 14 As Table 3 demonstrates,
15 16
17 16 18
14 See PG&E’s Bundled Procurement Plan Appendix S Section B.3.d.1. 15 See PG&E’s response to Joint CCA Master Data Request 1.08 Attachment 2 and CalCCA data request 2.57. 16 See PG&E’s response to CalCCA data request 3.31.

RA Position Date System RA Volume Offered for Sale Jun-22 Jul-22 Aug-22 Sep-22 Oct-22 8/23/2021 Phase 1 2022 YA Solicitation
10/6/2021 Phase 2 2022 YA Solicitation
11/22/2021 Q1 Balance-of-Year Solicitation
1/14/2022 Q2 Balance-of-Year Solicitation
4/11/2022 Q3 Balance-of-Year Solicitation
7/18/2022 Q4 Balance-of-Year Solicitation
-
9 1 When asked to provide documentation demonstrating whether it received any 2 offers from other LSEs to purchase any portion of the 923 MW of excess RA, PG&E 3 responded that it “did not receive any bids from other LSEs to purchase any portion of the excess capacity after it was known to be available.” 4 17 However, PG&E issued each of 5 the solicitations summarized in Table 3 above before PG&E had determined the quantity 6 of excess RA from existing resources that it would count toward System Reliability 7 Incremental Procurement targets. In other words, PG&E offered solicitations based on a 8 System RA Position that was calculated before PG&E calculated the excess RA it had 9 available to meet System Reliability Incremental Procurement targets. 10 PG&E issued its final two solicitations for RA with delivery in 2022 on April 11, 11 2022, and July 18, 2022, which projected System RA positions for July through 12 December 2022 and October through December 2022, respectively. According to 13 PG&E’s BPP,
14 15
16 When asked whether it had rejected offers from other LSEs to purchase any 17 portion of the 923 MW of excess capacity, PG&E simply referred back to its statement that it did not receive any bids “after the excess capacity was known to be available.”18 18 19 Reviewing data from PG&E’s RA solicitations tells a more complete story, however. 20 Table 4 below details for each RA solicitation the bids submitted by third parties seeking 21 to purchase System RA, but which were rejected by PG&E 22 17 See PG&E’s response to CalCCA data request 2.55 (emphasis added). 18 See PG&E’s response to CalCCA data request 2.56. 10 1 Table 4 summarizes the number of bids rejected
2 3 . As Table 4 demonstrates,
.
19 4
5 Table 4: Bids Rejected
6 7 PG&E’s responses that it had not received any bids to purchase the RA “after it 8 was known to be available” obfuscates the reality of the solicitation and compliance 9 reporting processes. A follow-up discovery question from CalCCA asked PG&E to 10 explain specifically how it communicated to other LSEs that excess capacity had become 11 available following its solicitation, to which PG&E simply replied that it complied with the requirements in Appendix S of its BPP at all times.20 12 PG&E’s responses to discovery 13 fail to acknowledge that there was no RA solicitation that would have been timely 14 enough to offer PG&E’s excess RA for sale, and that therefore, LSEs could not have 15 made bids to purchase excess RA “once it was known to be available.” Therefore, those 16 LSEs did not have the opportunity to use PG&E’s excess RA capacity to meet their own 17 System RA obligations. PG&E's failure to make reasonable attempts to sell the excess 19 See PG&E’s response to CalCCA data requests 2.21, 2.23, and 2.54 Supplemental. 20 See PG&E’s response to CalCCA data request 3.28.
# of Bids MWs # of Bids MWs # of Bids MWs # of Bids MWs # of Bids MWs Phase 1 2022 YA
Phase 2 2022 YA
Q1 2022 BOY Solicitation
Q2 2022 BOY Solicitation
Q3 2022 BOY Solicitation
Q4 2022 BOY Solicitation
Solicitation Terms / Number of Bids / MWs Rejected
Solicitation
June 2022 July 2022 August 2022 September 2022 October 2022 -
11 1 capacity to other LSEs, as required by D.21-12-015, should have disqualified it from 2 counting the capacity towards its 2022 System Reliability Incremental Procurement 3 targets.
4 V. LSES HAVE PAID SUBSTANTIAL FINES BECAUSE THEY WERE UNABLE TO 5 PROCURE SUFFICIENT RA CAPACITY.
6 Allowing PG&E to count RA from existing resources toward its System 7 Reliability Incremental Procurement target without first making that capacity available to 8 other LSEs cannibalizes an already constrained RA market and increases costs to all 9 customers. One symptom of the constrained RA market is that many LSEs have been 10 unable to meet their System RA requirements despite being willing to pay. The 11 Enforcement Actions Spreadsheet updated by the Consumer Protection and Enforcement 12 Division in July 2023 tracks RA citations issues to various entities from October 2009 13 through July 2023. As shown in Figure 1, there was a sharp increase in the number of citations in 2019, and elevated levels continued through 2022.21 14 21 CPUC’s Utility Enforcement Branch – July 2023 Energy Citations, https://www.cpuc.ca.gov/- /media/cpuc-website/divisions/consumer-protection-and-enforcement-division/documents/ueb/energy-citations/2023/july-2023-ueb-energy-citations.pdf. 12 1 Figure 1: RA Citations by LSE Type
2 3 Since 2009 there have been 130 fines totaling $39.6 million to LSEs for failing to meet RA compliance requirements.22 4 In 2022 alone, there were 18 citations issued 5 totaling $10.9 million, including 11 citations to CCAs that failed to meet the Commission’s RA requirements.23 6 According to the Energy Division’s Annual RA 7 Report from 2021 “Citations and penalties have increased in recent years, likely driven 8 by issues related to supply and demand balances due to resource retirements, load forecast increases, and changes in counting conventions.”24 9 22 Id.
23 Id.
24 2021 Resource Adequacy Report, https://webproda.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/resource-adequacy-homepage/2021 ra report 040523.pdf.

RA Cit at ions by LSIE Type
25 20
.....

C 15 ::,
0 u
C
0 :.:;
B 10 -0
5 I I I • I I
2010 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 ■ CCA ■ IOU ■ Other
13 1 Another symptom of the constrained market is the steadily increasing price of 2 System RA. Figure 2 below reproduces Figure 4 from the 2021 Resource Adequacy Report,25 3 showing the rise in RA prices from 2017 to 2021. 4 Figure 2: Weighted Average Price of System RA, January and August 2017-2021 5 6 As Figure 2 shows, Energy Division’s 2021 Resource Adequacy Report illustrates 7 that the average price of System RA transactions executed for August 2021 was 158% higher than for August 2017.26 8 The RA market price benchmarks calculated by Energy 9 Division in September 2022 report that System RA prices in 2022 averaged $8.11/kW-10 month over the entire year, and the forecast for average System RA prices in 2023 is 11 $7.39/kW-month.
25 2021 Resource Adequacy Report, https://webproda.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/resource-adequacy-homepage/2021 ra report 040523.pdf. 26 Id. at 28-29. 2021 Resource Adequacy Report
Figure 4: Weighted Average Price of System RA ($/kW-month), January and August 2017- 2021
an ug
$9.00
$8.07
$8.00
$7.00 $6.2 1
$6.00
$5.00
$4.00 $3.73 $3.97
$3.00
$2.00
$1.00
$0.00
2017 2018 20 19 2020 2021
Sor,rce: 2017-2021 price data sr,bmitted by LSEs.
14 1 Energy Division’s data also shows that variation in RA prices during 2021 was 2 significantly greater during high-demand summer months relative to other periods; prices for 15 percent of transactions exceeded $14/kW-month during July – September 2021.27 3 4 Figure 3 below presents Energy Division’s monthly price data for 2021 in graph form. 5 Figure 3: 2021 System RA Prices by Month
6 7 Price spikes such as these in the short-term RA market simply create a windfall 8 for existing generation owners at the expense of retail consumers; there is no incremental 9 reliability benefit to the system. If LSEs are not provided with a reasonable opportunity 10 to purchase PG&E’s excess RA in a timely manner, they will continue to struggle to meet 11 RA compliance requirements and incur penalties that increase costs to customers. 12 VI. THE COMMISSION SHOULD SCRUTINIZE THE ASSUMPTIONS USED IN 13 PG&E’S POSITION REPORTING AND SOLICITATION PROCESS.
14 The fact that
15 but then
27 Id. at 27-28.
$18.00
$16.00
$14.00
$12.00
$10.00
$8.00
$6.00
$4.00
$2.00
$0.00
2021 System RA Prices by M onth
11 II 11 11 11 11 I I I 11 II
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
■ IVeghted Av erage Price
(S/k\111- month)
■ &5th Percenti~
(S/k\111- mo nth)
15 1 count excess capacity of 923 MW for System Reliability Incremental Procurement, 2 indicates the current RA solicitation process is flawed. CalCCA asked PG&E several 3 times in discovery to explain how it could forecast a shortfall in RA for a given period 4 but later have excess RA in that same period. PG&E merely responded that its “bundled RA position changed due to a variety of conditions”28 5 and reiterated that it identified the excess capacity between T-50 and T-30 days prior to the compliance month.29 6 7 As described earlier, PG&E determines its System RA position by 8 9
10 30 11 Table 5 below details each of those line items as 12 calculated by PG&E in its RA position reports for the summer 2022 delivery period. 13 Table 5 also shows the change from the previous RA position for each component of the 14 reports.
28 See PG&E’s response to CalCCA data requests 3.27, 4.14 and 4.15. 29 See PG&E’s response to CalCCA data requests 3.33.
30 See PG&E’s Bundled Procurement Plan Appendix S Section B.3.b.1.a. -
16 1 Table 5: RA Position Reports Detail
2 17
1 Table 5 demonstrates that there is little change to PG&E’s RA Position 2 components after the two year-ahead solicitations (based on the 8/23/2021 and 3 10/26/2021 position reports) are complete and resulting RA sales are incorporated. Once 4 the year ahead solicitations are complete the line-item assumptions that go into the 5 ultimate RA position do not change significantly. In fact, the changes are generally 6 smaller than the RA swings in capacity described earlier between 7 PG&E's position reports and ultimate excess RA used towards its System Reliability Incremental Procurement.31 8 CalCCA is continuing to issue discovery to PG&E on this 9 point and may seek to supplement this testimony if it will provide additional clarity. In 10 any event, PG&E should be required to explain specifically what changed relative to its 11 RA position reports such that it ended up with 923 MW of excess summer RA capacity, 12 most of which was never made available to the market. 13 One potential explanation for the swing in PG&E’s available RA capacity is that 14 PG&E determines factors in its RA position reporting that are impacted by resource 15 availability and other adjustments to available capacity. To the extent PG&E has 16 discretion with regard to assumptions of resource availability, outage schedules, or 17 operational constraints, it is likely to make conservative assumptions that ensure 18 resources are used to meet its own compliance rather than make those resources available 19 to the market.
20 Concerns over service reliability and resource adequacy in California, and the 21 increasingly constrained RA market, make it critical that PG&E does not improperly 31 The reason we’re looking at the later position reports only is to get past the major updates from the Commission on RA requirements and CAISO on resource Net Qualifying Capacity. The remaining large changes are in the existing sales line due to previous solicitations. 18 1 withhold available RA capacity from the market. As such, CalCCA recommends the 2 following:
3 • PG&E should be required to provide a detailed reconciliation between the RA 4 position reports used as the basis for its solicitations offering to sell RA for 5 delivery in 2022 and its final RA positions resulting in excess capacity in June 6 through October 2022.
7 • The Commission should scrutinize PG&E’s assumptions about resource 8 availability and the adjustments made to its RA position to ensure reductions 9 to capacity made available to the market are justified and to eliminate 10 potential overlap among categories.
11 • PG&E’s BPP should be updated to ensure excess capacity is made available to 12 the market, either through refined adjustments to available capacity in RA 13 position reports or through market offers outside of the scheduled solicitation 14 process.
15 • The Commission should consider whether disallowance, penalty, or other 16 remedy is warranted for the 2022 record year based on PG&E’s non-17 compliance with D.21-12-015. 18 This concludes my testimony.

Attachment A
Curriculum Vitae of Brian Shuey
Brian T. Shuey

SENIOR MANAGER
[email protected]
Economics | Strategy | Stakeholders | Sustainability
www.newgenstrategies.net
Mr. Brian Shuey joined NewGen as a Senior Manager in May 2022, with over 15 years of experience in consulting and the utility industry. Mr. Shuey has audited specialized financial statements and reviewed adjustment clause rate filings for electric, gas, water, and steam utility companies. Additionally, Mr. Shuey participated in various special projects regarding utility rate-making issues. He also has significant Big 4 internal audit, enterprise risk management, regulatory compliance, IT consulting, and process improvement experience.

EDUCATION
Bachelor of Science in Accounting, The Pennsylvania State University

PROFESSIONAL CERTIFICATIONS
Certified Internal Auditor; Institute of Internal
Auditors

KEY EXPERTISE
Adjustment Clause Rate Filing Review
Cost Recovery
Enterprise Risk Management
Financial Statement Audits
IT Consulting
Management Consulting
Process Improvement
Project Management
Regulatory Compliance
Utility Rate Design

RELEVANT EXPERIENCE
Litigation Support
Mr. Shuey provides litigation support related to utility revenue requirements, rate design, and other ratemaking issues before state and local regulatory bodies. He has evaluated utility stranded costs and exit fees for retail customer choice, including on behalf of approximately a dozen Community Choice Aggregators in California.

A sample of Mr. Shuey’s clients includes the following:
� California Community Choice Association, CA � Clean Power Alliance, CA NewGen
Strategies ~ , ,
Brian Shuey

SENIOR MANAGER
Thoughtful Decision Making for Uncertain Times 2

PRIOR RELEVANT EXPERIENCE
Below is a small sample of Mr. Shuey’s work within the energy utility industry.

PA Public Utility Commission Auditor & Supervisor
§ Experience reviewing and auditing Electric
Default Service, Transmission Service,
Competitive Transition Charges, and
Infrastructure Improvement Charges.
§ Developed and maintained a training program
for new and current employees to complete the
review of adjustment clause rate filings.
§ Assigned and supervised the review of over 300
adjustment clause filings per year for
conformity to Commission directives and State
statutes.
§ Led discussions with utility personnel to revise
or update filings as needed.
§ Supervised the preparation of all audit work
papers and reports for a team of seven
auditors.
§ Reviewed the work of Audit Team Leaders to
ensure the audits were in accordance with
generally accepted auditing standards.

Enterprise Risk Management/Internal Audit
§ Directed and supervised up to 15 staff while
completing multi-year internal control
assessments over multiple large and small state
agencies.
§ Participated in risk assessments and control
testing in multiple organizations over five years,
utilizing COSO 13 and Green Book internal
control frameworks.
§ Facilitated the documentation of over 35 key
processes and over 500 controls for a single
client and assisted in developing and executing
a risk-based monitoring plan for these controls.
§ Participated in executing a risk-based audit
plan, including process/control documentation
and control testing.

Attachment B
PG&E Responses to CalCCA Data Requests

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking to Advance
Demand Flexibility Through Electric Rates. R.22-07-005
CALIFORNIA COMMUNITY CHOICE ASSOCIATION’S COMMENTS
ON ADMINISTRATIVE LAW JUDGE’S RULING ON TRACK B STAFF

PROPOSAL TO EXPAND EXISTING PILOTS
Evelyn Kahl,
General Counsel and Director of Policy
Leanne Bober,
Senior Counsel

CALIFORNIA COMMUNITY CHOICE

ASSOCIATION
One Concord Center
2300 Clayton Road, Suite 1150
Concord, CA 94520
Telephone: (510) 980-9459
E-mail: [email protected]
September 25, 2023
i

TABLE OF CONTENTS
I. INTRODUCTION ...............................................................................................................2 II. CCA PARTICIPATION IN THE EXPANDED PILOTS WILL DEPEND ON CCA BOARD APPROVAL AND EACH CCA’S UNIQUE
CIRCUMSTANCES ............................................................................................................3 III. THE STAFF PROPOSAL SHOULD BE CLARIFIED TO ENABLE CCAS

TO EFFECTIVELY ASSESS THEIR SCOPE OF PARTICIPATION IN THE EXPANDED PILOTS .........................................................................................................4 A. The Staff Proposal’s Funding Considerations Should Be Clarified ........................4 B. The Staff Proposal Should Provide Further Clarity on Expanded Pilot Customer Enrollment, ME&O, Evaluation, and Coordination between IOUs and Participating CCAs ..................................................................................5 IV. THE STAFF PROPOSAL SHOULD INCLUDE PHASED PILOT
PARTICIPATION TO MAXIMIZE CCA PARTICIPATION ...........................................5 V. QUESTIONS FOR PARTY COMMENTS .........................................................................6

1. Should the Commission authorize Expanded Pilot Proposal #1 to extend the VCE AgFIT Pilot, remove the participation cap, and expand eligibility to all agricultural customers in PG&E territory? .......................................................................................................6

3. Should the Commission authorize Expanded Pilot Proposal #3 to extend the duration of the SCE Dynamic Rate Pilot and expand pilot eligibility? ...............................................................................8

4. Please comment on the proposed evaluation requirements that would apply to the three Expanded Pilots in the Staff Proposal. .................9

5. Please comment if any existing Commission requirements or utility program rules may impede customer participation in any of the Expanded Pilots, and if so, explain how such
requirements should be modified for the purpose of pilot participation. ................................................................................................9 Table of Contents continued
ii

6. Are the proposed modifications to the VCE AgFIT Pilot and SCE Dynamic Rates Pilot consistent with the Commission’s Rate Design Principles and Demand Flexibility Design
Principles? If not, please provide specific ways to make the proposed modifications consistent with these principles. ............................9 VI. CONCLUSION ....................................................................................................................9 iii

SUMMARY OF RECOMMENDATIONS
• Community choice aggregator (CCA) participation in the expanded pilots will depend on decisions made by each CCA’s governing board regarding whether the pilot fits within that CCA’s needs and unique circumstances;
• The Staff Proposal on Existing Dynamic Rate Pilot Expansion (Staff Proposal) should be clarified regarding how the proposed funding will be allocated among the investor-owned utilities (IOUs) and participating CCAs, and across cost categories; • The Staff Proposal should be clarified regarding expanded pilot implementation in terms of customer enrollment, marketing, education, and outreach, evaluation, and IOU/CCA coordination; and
• CCAs should be allowed to join the pilots in phases, either in June 2024, June 2025, or June 2026, to maximize CCA participation.

BEFORE THE PUBLIC UTILITIES COMMISSION

PROPOSAL TO EXPAND EXISTING PILOTS
California Community Choice Association1 (CalCCA) submits these comments in response to (1) Administrative Law Judge’s Ruling on Track B Staff Proposal to Expand Existing Pilots2 (Ruling), dated August 15, 2023, requesting party comments on the Track B staff proposal to expand existing pilots to support near-term summer reliability, (2) Procedural Email Granting Extension for Track B Ruling Comments, dated August 24, 2023, granting the extension of deadlines for comments (to September 18, 2023) and reply comments (to October 6, 2023) on the Ruling, and (3) Procedural Email Granting Extension for Track B Ruling Comments, dated September 13, 2023, granting a second extension of the deadlines for filing comments (to September 25, 2023) and reply comments (to October 9, 2023). 1 California Community Choice Association represents the interests of 24 community choice electricity providers in California: Apple Valley Choice Energy, Central Coast Community Energy, Clean Energy Alliance, Clean Power Alliance, CleanPowerSF, Desert Community Energy, East Bay Community Energy, Energy For Palmdale’s Independent Choice, Lancaster Energy, Marin Clean Energy, Orange County Power Authority, Peninsula Clean Energy, Pico Rivera Innovative Municipal Energy, Pioneer Community Energy, Pomona Choice Energy, Rancho Mirage Energy Authority, Redwood Coast Energy Authority, San Diego Community Power, San Jacinto Power, San José Clean Energy, Santa Barbara Clean Energy, Silicon Valley Clean Energy, Sonoma Clean Power, and Valley Clean Energy. 2 Rulemaking (R.) 22-07-005, Administrative Law Judge’s Ruling on Track B Staff Proposal to Expand Existing Pilots (Aug. 15, 2023):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M517/K407/517407755.PDF. 2 I. INTRODUCTION
Energy Division’s Staff Proposal on Existing Dynamic Rate Pilot Expansion (Staff Proposal) provides significant opportunities to further evaluate the impact of dynamic pricing on grid reliability. Existing pilots, including the Valley Clean Energy (VCE)/Pacific Gas & Electric Company (PG&E) Agricultural Pumping Dynamic Rate Pilot (AgFIT), have preliminarily demonstrated load shifts beneficial to grid reliability while providing customer savings in connection with dynamic rates.3
For this reason, CalCCA supported the expansion of the AgFIT pilot in its December 2022 comments on the Scoping Memo.4 Expansion of existing dynamic rate pilots as proposed by the Staff Proposal will allow testing of additional use cases implementing dynamic rates.

Each unique community choice aggregator’s (CCA’s) participation in any of the proposed pilots will depend on a determination by that CCA’s governing board whether such participation fits within the needs and goals of the local community it serves. This CCA rate and program autonomy is reflected in the Staff Proposal’s invitation, but not direction, for CCAs to participate along with PG&E and Southern California Edison Company (SCE). To facilitate each CCA’s assessment of whether and how it will participate, CalCCA provides recommendations and seeks clarifications as set forth below:
• CCA participation will depend on decisions made by each CCA’s governing board regarding whether the pilot fits within that CCA’s needs and unique circumstances;
3 See Ruling, Attachment 2, Preliminary Assessment of Valley Clean Energy’s Agricultural Pumping Dynamic Rate Pilot (May 26, 2023):
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M517/K407/517407316.PDF. 4 See R.22-07-005, CalCCA Comments on Assigned Commissioner’s Phase 1 Scoping Memo and Ruling (Dec. 2, 2022), at 5-7:
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M499/K659/499659049.PDF. 3 • The Staff Proposal should be clarified regarding how the proposed funding will be allocated: (1) among the investor-owned utilities (IOUs) and participating CCAs, and (2) across cost categories;
• The Staff Proposal should be clarified regarding expanded pilot implementation in terms of customer enrollment, marketing, education, and outreach (ME&O), evaluation, and IOU/CCA coordination; and
• CCAs should be allowed to join the pilots in phases, either in June 2024, June 2025, or June 2026, to maximize CCA participation.

II. CCA PARTICIPATION IN THE EXPANDED PILOTS WILL DEPEND ON CCA BOARD APPROVAL AND EACH CCA’S UNIQUE CIRCUMSTANCES
If the Staff Proposal is adopted, the California Public Utilities Commission (Commission) will require PG&E and SCE to expand the pilots, and CCAs will have the option to participate in the expanded pilots.5 CalCCA supports the Staff Proposal’s recognition that each CCA retains its exclusive statutory and regulatory autonomy to determine whether and how to participate. 6 Given
the promising results demonstrated by the VCE/PG&E AgFIT pilot, CCAs are eager to consider participation, but each unique CCA will need to determine if the pilot(s) align with its local community’s needs, goals, and policies. For example, a CCA’s participation in Pilot #1 expanding dynamic pricing to all agricultural customers in PG&E’s service territory may only be prudent for CCAs with sufficient sectors of agricultural customers. Therefore, CCA governing boards will consider all factors impacting their communities prior to deciding whether to participate in the expanded pilots, or to implement a different rate or program more aligned with their needs. 5 See Staff Proposal, at 1 (proposing that the Commission “direct the IOUs to expand certain existing dynamic rate pilots,” while allowing the CCAs to participate). 6 As noted in footnote one, above, CalCCA represents the interests of 24 out of 25 of the CCAs in California. Each CCA was established after the passage of Assembly Bill (AB) 117 in 2022 enabling local governments to establish CCAs to purchase electricity on behalf of residents and business in place of the IOUs. See AB 117, Stats. 2002; ch. 838 (codified at Public Utilities Code § 366.2). AB 117 incorporates an overall statutory and regulatory framework providing CCA governing boards with operational, procurement, and ratesetting autonomy in favor of local communities establishing the policies for their CCA.
4 III. THE STAFF PROPOSAL SHOULD BE CLARIFIED TO ENABLE CCAS TO

EFFECTIVELY ASSESS THEIR SCOPE OF PARTICIPATION IN THE

EXPANDED PILOTS
The Staff Proposal should be clarified to enable CCAs to assess if and how the expanded pilots can be implemented in their service territories. As set forth above, many CCAs are eager to work with the Commission and the IOUs to establish programs under the expanded pilots, especially given the promising results from the AgFIT pilot and the ability to positively impact grid reliability. However, many details of the Staff Proposal must be clarified prior to the CCAs’ committing resources to participate, especially given the short timeline for kickoff of the pilots in June 2024. As discussed below, the following aspects of the Staff Proposal should be clarified: (1) proposed budgets, including allocation of funding both to specific load serving entities (LSEs) and within the categories of costs; (2) customer enrollment and eligibility; (3) ME&O among IOUs and participating CCAs; and (4) inclusion of participating CCA data in pilot evaluations.

A. The Staff Proposal’s Funding Considerations Should Be Clarified CCAs need clarity on the proposed budgets in the Staff Proposal to assess their participation in the expanded pilots. As noted above, CCA governing boards will determine the scope and program design of each CCA’s participation in the pilots, including whether sources of ratepayer funding will be needed to enable unbundled customers in their service areas to participate in the pilot(s). To make these determinations, clarity is necessary regarding funding sources, budgets, and the funding categories (including administration, vendor fees, systems and technology, billing, evaluation, and ME&O).

First, the Staff Proposal should be clarified regarding whether CCAs are eligible to receive funding for any category of budgeted costs under the pilots. If CCAs are eligible to seek cost recovery, does such eligibility extend to administrative costs, third party enrollment costs, and/or vendor fees? In addition, the VCE/PG&E AgFIT pilot includes funding for technology incentives 5 for participants to enable automated load shifting. Will such funding be available to pilot participants, including unbundled customers? If so, what is the amount of funding allocated? In addition, to the extent funding is insufficient to scale the pilot to all customers wishing to participate, how will the funding be allocated across the load-serving entities offering the pilots, the pilots themselves, pilot rate classes, and individual customers? Will a cap be placed on the number of customers able to participate, or can a LSE place caps based upon funding provided by the Commission? Answers to these questions will provide clarity for CCAs to accurately determine their level and scope of participation in the pilots.

B. The Staff Proposal Should Provide Further Clarity on Expanded Pilot Customer Enrollment, ME&O, Evaluation, and Coordination between IOUs and Participating CCAs
The Staff Proposal should be clarified regarding how the IOUs and participating CCAs will coordinate customer enrollment, ME&O, and evaluation of the pilots. For example, with respect to customer enrollment, in many cases CCAs do not have access to data providing information on customer enrollment in certain demand response programs (for example, the Emergency Load Reduction Program). Given the proposed prohibition on dual enrollment for certain programs and the expanded pilots and the inability of CCAs to conduct the dual enrollment check, the IOUs will likely need to perform such dual enrollment checks for CCAs to enroll unbundled customers in its pilot programs. In addition, the Staff Proposal should be clarified regarding how ME&O will be conducted amongst the IOUs and participating CCAs. Finally, the Staff Proposal should address including participating CCA data in the expanded pilot evaluations along with the IOU data.

IV. THE STAFF PROPOSAL SHOULD INCLUDE PHASED PILOT

PARTICIPATION TO MAXIMIZE CCA PARTICIPATION
Energy Division staff should consider providing launch date flexibility to maximize the number of CCAs that can prepare for and launch pilot expansions in their service territories. The 6 Staff Proposal includes June 2024 start dates for all three pilot expansions,7 providing CCAs less than nine months from awareness of the opportunity to participate in the expanded pilots to launch.

The urgency in California for grid reliability and the need for load shifting away from peak grid stress times is evident and this is central to the Staff Proposal. CalCCA understands and appreciates Energy Division’s desire to set one launch date for all LSEs participating in the expanded pilots.

This approach has benefits to the data collection for evaluation, and for providing consistent funding. However, given the contracting, ME&O, and other preparation work required to successfully launch the expanded pilots, nine months may be too short a runway for some CCAs.

To allow more time for CCAs to adequately prepare, Energy Division staff should consider allowing a phased approach to expanded pilot launch. Allowing CCAs to launch in June 2024, June 2025, or June 2026, will maximize CCA participation because any interested CCA that may not be able to launch in June 2024 can plan to launch for a subsequent summer. This phased launch approach will ensure that more customers get opportunities to incentivize load shifting via dynamic rates, regardless of whether their CCA is ready to launch by June 2024. In addition, keeping the launch month for each year (i.e., June) consistent will ensure consistency of data for each summer.

V. QUESTIONS FOR PARTY COMMENTS

1. Should the Commission authorize Expanded Pilot Proposal #1 to extend the VCE AgFIT Pilot, remove the participation cap, and expand eligibility to all agricultural customers in PG&E territory? Yes. Given the promising results of the VCE AgFIT pilot, the Commission should authorize the Expanded Pilot Proposal #1, after providing additional clarity on pilot participation as set forth in CalCCA’s comments above.
a. Please comment on whether the initial results of the VCE AgFIT Pilot indicate that the pilot has been successful at supporting system reliability to date. (See the attached interim 7 See Staff Proposal, at 4 (Expanded Pilot #1), 7 (Expanded Pilot #2), and 8 (Expanded Pilot #3). 7 evaluation report.)
Yes, the pilot appears to be successful with the limited data gathered to date. b. Do you support the staff proposal modifications to eligibility for the pilot?
Yes.
c. Do you support the staff proposal modifications to the duration and/or size of the pilot?
Yes, with the addition of the proposed phased approach as set forth in Section IV., above. d. Do you recommend additional marketing, education, and/or outreach for this pilot? If so, please provide details and a proposed budget.

Yes, with clarifications as set forth in Section III.B., above. e. Do you agree with the staff estimates of the costs of expanding and extending the pilot?
CalCCA requests that the Staff Proposal estimates of costs be clarified as set forth in Section III.A., above.
f. Do you support the proposed timing of implementation of the Expanded Pilot (starting June 2024)?
Yes, with the addition of the proposed phased approach as set forth in Section IV., above.

2. Should the Commission authorize Expanded Pilot Proposal #2 to expand eligibility of the VCE AgFIT Pilot to certain commercial and residential customers in PG&E territory with no participation cap? CalCCA supports expanding eligibility of the VCE AgFIT Pilot but seeks clarification of the expanded pilot as set forth herein.
a. Do you support the proposed modifications to eligibility for the pilot?
Yes.
b. Do you support the proposed modifications to the duration and size of the pilot?
8 Yes, with the addition of the proposed phased approach as set forth in Section IV., above. c. Do you recommend additional marketing, education, and/or outreach for this pilot? If so, please provide details and a proposed budget.

Yes, with clarifications as set forth in Section III.B., above. d. Do you agree with the proposed estimates of the costs of expanding and extending the pilot?
CalCCA requests that the proposed estimates of costs be clarified as set forth in Section III.A., above.
e. Do you support the proposed timing of implementation of the Expanded Pilot (starting June 2024)?
Yes, with the addition of the proposed phased approach as set forth in Section IV., above.

3. Should the Commission authorize Expanded Pilot Proposal #3 to extend the duration of the SCE Dynamic Rate Pilot and expand pilot eligibility?
a. Do you support the proposed modifications to eligibility for the pilot?
Yes.
b. Do you support the proposed modifications to the duration of the pilot?
Yes, with the addition of the proposed phased approach as set forth in Section IV., above. c. What changes, if any, are necessary to enable CCA customers to participate in this pilot?
Please see comments in Sections II.-IV., above.
d. Do you recommend additional marketing, education, or outreach for this pilot? If so, please provide details and a proposed budget.

Yes, with clarifications as set forth in Section III.B., above. e. Do you agree with the proposed estimates of the costs of expanding and extending the pilot?
9 CalCCA requests that the Staff Proposal estimates of costs be clarified as set forth in Section III.A., above.
f. Do you support the proposed timing of implementation of the Expanded Pilot (starting June 2024)?
Yes, with the addition of the proposed phased approach as set forth in Section IV., above.

4. Please comment on the proposed evaluation requirements that would apply to the three Expanded Pilots in the Staff Proposal.

Please see comments in Section III.B., above.

No comment at this time.

Yes.

VI. CONCLUSION
For all the foregoing reasons, CalCCA respectfully requests consideration of the recommendations herein and looks forward to an ongoing dialogue with the Commission and stakeholders.

Respectfully submitted,
Evelyn Kahl,
General Counsel and Director of Policy

CALIFORNIA COMMUNITY CHOICE

ASSOCIATION
September 25, 2023
t
4 ERRA-2022-PGE-Compliance_DR_JointCCAs_001-Q08 Page 1 Confidential

PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account Compliance
Application 23-02-XXX
Data Response
PG&E Data Request No.: JointCCAs 001-Q08
PG&E File Name: ERRA-2022-PGE-Compliance DR JointCCAs 001-Q08 Request Date: January 6, 2021 Requester DR No.: 001
Date Sent: February 28, 2023 Requesting Party: Joint CCAs PG&E Witness: Robert Gomez Requester:

QUESTION 08
Provide Resource Adequacy (RA) information as follows:
(1) sold, unsold and retained resource adequacy by resource and balancing account (RA Tracker)
(2) system, local and flex positions for solicitations governed by Appendix S including the data as presented in the attached RA Position Table for (a) each solicitation in which RA for delivery in the record year was offered for sale (b) at the time each solicitation took place
(3) all Tier 1 advice letter filings addressing Operational Constraints, including confidential attachments.

ANSWER 08

THE ATTACHMENTS TO THIS DATA RESPONSE CONTAIN CONFIDENTIAL INFORMATION PROTECTABLE UNDER DECISION 14-10-033, DECISION 06-06- 066, PUBLIC UTILITIES CODE SECTION 454.5(G) AND/OR PURSUANT TO NON-PROCUREMENT DECLARATION DATED FEBRUARY 28, 2023 (1) Sold, unsold, and retained resource adequacy by resource and balancing account are included in the attachment “ERRA-2022-PGE-Compliance_DR_JointCCAs_001- Q08_Atch01-2022_20221231_Retained_RA_Tracker_December_2022_CONF.xlsx” in the “2022 RA Tracker” tab.
(2) Positions for solicitations governed by Appendix S for (a) each solicitation in which RA for delivery in the record year was offered for sale (b) at the time each solicitation took place are included in ERRA-2022-PGE-Compliance_DR_JointCCAs_001- Q08_Atch02-2022_Positions_CONF.xlsx. Each RA Position Table reflects the system, flex, or local area position at the time of solicitation and the quantity available for sale at that point in time.
(3) All Tier 1 Advice Letter filings addressing Operational Constraints, including confidential attachments are in included in ERRA-2022-PGE-Compliance_DR_JointCCAs_001-Q08_Atch03-Advice_Letter_Filings_CONF.zip.

Attachment is confidential.

ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q019 Page 1

PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account – Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 002-Q019
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q019 Request Date: March 15, 2023 Requester DR No.: 002
Date Sent: April 5, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 019
Referring to PG&E’s prepared testimony, Page 8-4, lines 24-30: Did PG&E meet its minimum target of 900 MW as required in D.21-12-015? If yes, provide workpapers demonstrating compliance. If no, explain why not.

ANSWER 019
Yes. Attached is the public version of PG&E’s progress towards the minimum procurement target of 900 MW (ERRA-2022-PGE-Compliance_DR_CalCCA_002_Q019_Atch01.xlsx). This document can also be found on the CPUC’s RA Compliance website at the following link: https://www.cpuc.ca.gov/- /media/cpuc-website/divisions/energy-division/documents/resource-adequacy-homepage/resource-adequacy-compliance-materials/oct-2022pge-template-for-excess-resource-reporting-d2112015-public-083122.xlsx.

Utility Name: Pacific Gas and Electric
Monthly Minimum MW Target: 900
Date of Report 10/1/22
Subset of the resources below shown on the IOU’s supply plan Jun-22 Jul-22 Aug-22 Sep-22 Oct-22
IOU Supply Plan Summer Reliability MW Amount 670.84 706.00 652.66 756.94 703.90 Total resources available as incremental above 15% RA requirement (i.e., progress toward the IOU's incremental effective PRM target) Project/Resource Name Resource Type Jun-22 Jul-22 Aug-22 Sep-22 Oct-22 Advice Letter and/or
Resolution Notes

1. Supply-Side Emergency Re iability OIR Procurement -
Itemize each new project/resource by name
Ind cate whether the resource is new bu ld firm import short-term energy only call option etc. List # if app icable E.g. exp ain monthly variability discrepanc es between contract values etc.

Sierra Pacific Industries Short-term Energy-Only Call-Option 7.00 7.00 7.00 7.00 10.00 AL-6604 Chevron Taft/Cadet Short-term Energy-Only Call-Option 2.20 2.20 2.20 2.20 2.20 AL-6604 Chevron Cymric Short-term Energy-Only Call-Option 1.50 1.50 1.50 1.50 1.50 AL-6604 Chevron Coalinga Short-term Energy-Only Call-Option 3.20 3.20 3.20 3.20 3.20 AL-6604 Chevron SE Kern River Short-term Energy-Only Call-Option 15.00 15.00 15.00 15.00 15.00 AL-6604 Chevron East Ridge Short-term Energy-Only Call-Option 3.00 3.00 3.00 3.00 3.00 AL-6604 Chevron McKittrick Short-term Energy-Only Call-Option 4.50 4.50 4.50 4.50 4.50 AL-6604 Wheelabrator Shasta Short-term Energy-Only Call-Option 15.90 15.90 15.90 15.90 15.90 AL-6604 Import RA: PowerEx Firm Import 125.00 125.00 125.00 125.00 Import RA: PowerEx Firm Import 75.00 75.00 75.00 75.00 AL-6504 Import RA: PowerEx Firm Import 200.00 200.00 200.00 200.00 Import RA: Morgan Stanley Firm Import 50.00 50.00 41.00 100.00 Import RA: TransAlta Firm Import 50.00 50.00 50.00 50.00 Import RA: Guzman Energy LLC Firm Import 25.00
Import RA: Dynasty Power Inc. Firm Import 25.00
Import RA: BPA Firm Import 100.00
Tesoro Martinez PPA extension 45.00 100.00 100.00 100.00 100.00 AL-6323 Import RA: ConocoPhilips Firm Import 25.00 25.00 75.00
Calpine Short-term RA only 190.00 AL-6604
E k Hills Short-term RA only 70.00 AL-6604
Vistra Short-term RA only 30.00 AL-6604
New build New bu ld 150.00
New build New bu ld 63.00 63.00 63.00
New build New bu ld 47.00 47.00 47.00
UOG Enhancements - Gateway UOG Enhancement 10.00 10.00 10.00 10.00 10.00 AL-6088 page 6 Not included in Cost Recovery for System Re iability OIR UOG Enhancements - Colusa UOG Enhancement 10.00 10.00 10.00 10.00 10.00 AL-6088 page 6 Not included in Cost Recovery for System Re iability OIR

2. Excess Resources from IOU Portfolio Above 15% PRM
Excess Resources from IOU Portfolio Excess Resources 103.70 183.14 148.97 156.70 330.00 Amount to be Shown on RA/Supply Plan SUBTOTAL SUPPLY-side Excess Procurement 961 855 906 1,105 990

3. Demand-Side Emergency Reliability OIR Procurement ndicate subcategor es of resource if applicable ELRP Enrollment 378.00 423.00 466.00 466.00 466.00 N/A
DR program expansion 19.00 15.00 14.00 14.00 12.00 N/A
Other (Smart Thermostat) 12.00 13.00 14.00 13.00 5.00 N/A DRAM 5.00 AL-6619 Amount to be Shown on RA/Supply Plan
SUBTOTAL DEMAND-side Excess Procurement 409 451 494 498 483 1,370 1,306 1,400 1,603 1,473 <-- total MW procured
900 900 900 900 900
-470 -406 -500 -703 -573 <-- negative values mean minimum target exceeded; positive values mean minimum target not met 389 495 444 245 360 <-- maximum additional supply resources permitted Monthly IOU reports available at: https://www.cpuc.ca.gov/General.aspx?id=6311 D.21-12-015 Ordering Paragraph 74:

D.21-12-015 Ordering Paragraph 74:

MW to be c aimed for CAM Cost Recovery

3. Demand-Side Emergency Reliability OIR Procurement: Report a l demand-side resources authorized under D.21-12-015 and being claimed toward the IOU's monthly incremental procurement target.

1. Supply-Side Emergency Re iability OIR Procurement: Report all approved contracts for supply-side resources authorized under D 21-12-015 showing the amount being claimed toward the IOU's monthly incremental procurement target even if the amount for any given month is zero MW.

Apply ng the TAC a ea CAISO load sha es fo each ut l ty s se v ce te to y to the cont ngency p ocu ement set fo th n th s dec s on esults n ta get p ocu ement amounts of 900 MW-1,350 MW each fo PG&E and SCE se v ce te to es and 200 MW-300 MW fo SDG&E se v ce te to y. (D.21-12 015, F nd ngs of Fact 28) PG&E has Excess Resou ces f om ts po tfol o ava lable to supplement the above l sted esou ces n Octobe 2022. These supplemental megawatts a e not captu ed n the above total and w ll not be sub ect to cost ecove y th ough D.21-12-015. The ava lable ene gy f om any Excess Resou ces w l be o fe ed n the CA SO ma ket based on least cost d spatch standa ds. “PG&E b ds esou ces w th b dd ng ghts nto the CAISO ma kets based on the nc emental costs o oppo tun ty costs. By b dd ng ts esou ces nto the CAISO ma kets at the nc emental o oppo tun ty costs, PG&E enables total p ocu ement to meet custome demand n the CA SO ma kets at least cost.

Resou ces w th cont actual o phys cal const a nts that l m t the ab l ty to be b d may be fully o pa t a ly self-scheduled nto the CAISO ma kets.” Page 1- 7, 2020 PG&E ERRA Compl ance Test mony
"Pacific Gas and Electric Company Southern Cal fornia Edison Company and San Diego Gas & Electric Company shall provide the monthly amounts of the excess resources they applied to the Cost Allocation Mechanism as well as the calculus used to determine these amounts to Commission’s Energy Division and Energy Division will post this information on the Commission’s website."
MW to be c aimed for CAM Cost Recovery
MW reported
General: Report actual MW values for previous months and estimates for future months. At the top enter the subset of the resources from Sections 1 and 2 shown on the IOU’s supply plan for each summer month.

IOU EXCESS RESOURCE REPORTING SUMMARY
Instructions:

2. Excess Resources from IOU Portfolio Above 15% PRM: Report any additional "excess resources" above the IOU's 15% PRM requirement being applied to CAM for each month.
"In recognition of the continued tight grid conditions experienced this summer the Cal fornia Independent System Operator’s testimony reflecting a significant shortfa l in Load Serving Entity supply plan resources at net peak and the need for additional contingency resources identified in the California Energy Commission’s Summer 2022 Stack Analysis Southern Cal fornia Edison Company (SCE) Pacific Gas and Electric Company (PG&E) and San Diego Gas & Electric Company (SDG&E) shall use their best efforts to meet a revised targeted procurement range of 2 000 megawatts (MW) to 3 000 MW for summers 2022 and 2023 which includes and is not additive to the targeted procurement of 1 000 MW of contingency resources adopted in Decision (D.) 21-02-028 and D.21-03-056 and results in an “effective PRM” of 20%-22.5%. Based on the proportional load share in each uti ity’s service territory the revised targeted procurement range represents 900 – 1 350 MW of additional procurement for SCE and PG&E and 200 – 00 MW for SDG&E." IOU Progress toward Monthly Target
Minimum Excess Procurement Target per D.21-12-015

DIFFERENCE
Supply Side Headroom (3,000 Max)
ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q021 Page 1

PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account – Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 002-Q021
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q021 Request Date: March 15, 2023 Requester DR No.: 002
Date Sent: April 5, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 021
Referring to PG&E’s prepared testimony, Page 8-7, lines 18-23: For each solicitation referenced in the cited testimony, please provide all workpapers detailing PG&E’s quantitative evaluation of all bids received. Workpapers should include, but not be limited to, the following:
a. Details of all bids received, by solicitation, including buyer, term, volume, bid price, product, area, etc.
b. Each bid received but rejected
c. Justification for rejecting any bid
d. Each bid received resulting in an executed contract.

ANSWER 021

THE ATTACHMENTS TO THIS DATA RESPONSE CONTAIN CONFIDENTIAL INFORMATION PROTECTABLE UNDER DECISION 14-10-033, DECISION 06-06- 066, AND/OR PUBLIC UTILITIES CODE SECTION 454.5(G) – SUBJECT TO NDA a) Please see the following attachments for the bid summary or shortlist files for each solicitation that were submitted to the PRG.
• Q2 2022 Balance of Year Solicitation: ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q021_Atch1-CONF • Q3 2022 Balance of Year Solicitation: ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q021_Atch2-CONF • Q4 2022 Balance of Year Solicitation: ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q021_Atch3-CONF • Q3 2023 Year Ahead Phase 1 Solicitation: ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q021_Atch4-CONF) • Q3 2023 Year Ahead Phase 2 Solicitation: ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q021_Atch5-CONF) • Q2 2023 Balance of Year Solicitation: ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q021_Atch6-CONF These files mentioned above contain the details of all bids received for each RA solicitation with 2022 and 2023 delivery, including counterparty, term, volume, bid price, ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q021 Page 2
product, area. For reference, the table below shows the file that corresponds to each solicitation.

Solicitation
Q2
through
Balance of
Year 2022
Q3
through
Balance of
Year 2022
Q4
through
Balance of
Year 2022
Q3
2023 Year
Ahead
(Phase 1)
Q3
2023 Year
Ahead
(Phase 2)
February
through
Balance of
Year 2023
Date Issued
to the
Market
1/26/2022 3/31/2022 7/21/2022 8/11/2022 9/29/2022 11/9/2022 Attachment
ERRA-2022-
PGE-Compliance_DR
_CalCCA_002-
Q021_Atch1-
CONF
ERRA-2022
PGE-Compliance_DR
_CalCCA_002-
Q021_Atch2-
CONF
ERRA-2022-
PGE-Compliance_
DR_CalCCA_0
02-
Q021_Atch3-
CONF
ERRA-2022-
PGE-Compliance_D
R_CalCCA_002
-Q021_Atch4-
CONF
ERRA-2022-PGE-Compliance_DR_
CalCCA_002-
Q021_Atch5-
CONF
ERRA-2022-
PGE-Compliance
_DR_CalCCA
_002-
Q021_Atch6
-CONF
b) Attachments referenced in 2.21a shows accepted or rejected status of received bids for solicitations held in 2022. Accepted bids are shortlisted with the intention of execution while rejected bids are labelled as "Not Shortlisted". Some bids are partially shortlisted and partially rejected.
c) PG&E rejected bids received in response to RA solicitations in 2022 for a variety of reasons including but not limited to:
d) All attachments referenced in 2.21a show the accepted status of received bids.

Accepted bids are shortlisted with the intention of execution but not all shortlisted bids result in executed contracts for reasons #6,8 and 9 stated in 2.21c. Bids that resulted in executed contracts are in Attachment E and H of the QCR.

Attachment is confidential.

ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q023 Page 1

PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account – Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 002-Q023
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q023 Request Date: March 15, 2023 Requester DR No.: 002
Date Sent: April 5, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 023
Referring to the previous question (CalCCA to PG&E 2.22): For PG&E’s 2022 year ahead RA solicitation(s), please provide all workpapers detailing PG&E’s quantitative evaluation of all bids received. Workpapers should include, but not be limited to, the following:
a. Details of all bids received, by solicitation, including buyer, term, volume, bid price, product, area, etc.
b. Each bid received but rejected
c. Justification for rejecting any bid
d. Each bid received resulting in an executed contract.

ANSWER 023

THE ATTACHMENTS TO THIS DATA RESPONSE CONTAINS CONFIDENTIAL INFORMATION PROTECTABLE UNDER DECISION 14-10-033, DECISION 06-06- 066, AND/OR PUBLIC UTILITIES CODE SECTION 454.5(G) – SUBJECT TO NDA a) Refer to the following Attachments for PG&E’s 2022 year ahead RA solicitation(s) that were submitted to the PRG.
• Phase 1 2022 Year-Ahead: ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q023_Atch1-CONF • Phase 2 2022 Year-Ahead: ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q023_Atch2-CONF These files mentioned above contain the details of all bids received for each RA solicitation with 2022 delivery, including counterparty, term, volume, bid price, product, area. For reference, the table below shows the file that corresponds to each solicitation.

Solicitation Phase 1 2022 Year-Ahead Phase 2 2022 Year-Ahead Date Issued
to the Market 8/31/2021 10/1/2021
Attachment ERRA-2022-PGE-Compliance_DR_CalCCA_002-
Q023_Atch1-CONF)
ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q023_Atch2-
CONF)
ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q023 Page 2
b) Attachments referenced in 2.23a above shows the accepted or rejected status of received bids for PG&E’s 2022 year ahead RA solicitation(s). Accepted bids are shortlisted with the intention of execution while rejected bids are labelled as "Not Shortlisted". Some bids are partially shortlisted and partially rejected. c) PG&E rejected bids received in response to PG&E’s 2022 year ahead RA solicitation(s) for a variety of reasons including but not limited to:
d) All attachments referenced in 2.23a show the accepted status of received bids.

Accepted bids are shortlisted with the intention of execution but not all shortlisted bids result in executed contracts for reasons stated in 2.23c 6, 8 and 9. Bids that resulted in executed contracts are in Attachment E and H of the QCR.

Attachment is confidential.

ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q054 Page 1

PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account – Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 002-Q054
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q054 Request Date: March 15, 2023 Requester DR No.: 002
Date Sent: April 5, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 054
Referring to PG&E’s prepared testimony, page 12-15, lines 13-19: Please explain in detail all attempts to sell to other LSEs any portion of the 923 MW of excess capacity prior to it being transferred from PABA to ERRA.

ANSWER 054
PG&E made attempts to sell all excess capacity, or its long RA position, as determined by Appendix S, pursuant to the commercial processes in Appendix S. Please see Table 8-1 of PG&E’s prepared testimony of a list of solicitations, and Question 21 - attachments 1-6 and Question 23 - attachments 1-2 for the results of each solicitation.

ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q054Supp01 Page 1

PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account – Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 002-Q054
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q054Supp01 Request Date: March 15, 2023 Requester DR No.: 002
Date Sent: April 5, 2023(original) Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 054
Referring to PG&E’s prepared testimony, page 12-15, lines 13-19: Please explain in detail all attempts to sell to other LSEs any portion of the 923 MW of excess capacity prior to it being transferred from PABA to ERRA.

ANSWER 001_SUPP

THE ATTACHMENT TO THIS DATA RESPONSE CONTAINS CONFIDENTIAL INFORMATION PROTECTABLE UNDER DECISION 14-10-033, DECISION 06-06- 066, AND/OR PUBLIC UTILITIES CODE SECTION 454.5(G) – SUBJECT TO NDA PG&E’s February-December 2022 Balance of Year solicitation held in Q4 of 2021 was not included in PG&E’s original response to 2.54. Please see attachment 1 (ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q54_Atch1-CONF) for the results of this solicitation.

Attachment is confidential.

ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q055 Page 1

PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account – Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 002-Q055
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q055 Request Date: March 15, 2023 Requester DR No.: 002
Date Sent: April 5, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 055
Referring to PG&E’s prepared testimony, page 12-15, lines 13-19: Please provide documentation demonstrating whether PG&E received any offers from other LSEs to purchase any portion of the 923 MW of excess PCIA resource capacity.

ANSWER 055
PG&E did not receive bids from other LSEs to purchase any portion of the excess capacity after it was known to be available.

ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q056 Page 1

PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account – Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 002-Q056
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q056 Request Date: March 15, 2023 Requester DR No.: 002
Date Sent: April 5, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 056
Referring to PG&E’s prepared testimony, page 12-15, lines 13-19: Please explain whether any offers to purchase any portion of the 923 MW of excess PCIA resource capacity were rejected by PG&E. If yes, provide all details supporting why PG&E rejected the offer.

ANSWER 056
Please see answer to CalCCA DR 002 Q55.

MCE Board of DirectorsOctober 19, 2023

MCE Board of Directors
October 19, 2023