ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q057 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-Q057
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q057 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 057
Referring to PG&E’s prepared testimony, page 12-15, lines 13-19: Please provide all RA Position Breakdown documents demonstrating that the excess capacity was made available in an RA solicitation pursuant to Appendix S of PG&E’s approved Bundled Procurement Plan prior to being counted toward PG&E’s system reliability procurement target.
ANSWER 057
Please see please see PG&E’s response to the Joint CCA’s Master Data Request question 8, Attachment 2: “ERRA-2022-PGE-Compliance_DR_JointCCAs_001- Q08_Atch02-2022_Positions_CONF.xlsx”.
ERRA-2022-PGE-Compliance_DR_CalCCA_002-Q058 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-Q058
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 002-Q058 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 058
Referring to PG&E’s prepared testimony, page 12-15, footnote 25:
a. What factors caused Diablo Canyon to have excess capacity? b. How was it determined that Diablo Canyon was the resource with the excess capacity?
c. Why wasn’t it another resource with the excess capacity at this time? d. Does PG&E have discretion to select the resource with the excess capacity? If so, please describe how PG&E makes that determination.
ANSWER 058
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. During the summer months of June through October 2022, not fully utilized to meet PG&E’s bundled compliance commitments, RA sales, or planned outage substitution obligations.
b. PG&E selected resources to meet its bundled compliance obligations, RA sales obligations, and planned outage substitution obligations. After meeting those obligations,
.
c. excess capacity available during the
summer months.
d. D.21-12-015 authorized IOUs to meet incremental procurement targets with excess RA capacity, and was silent regarding how excess resources should be selected. See response to Joint CCA DR 002 Q58 part a.
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.PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account - Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 003-0026
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 003-0026 Request Date: April 25, 2023 Requester DR No.: 003
Date Sent: May 23, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Viiavkar
QUESTION 026
Referring to CalCCA DR Response 2.55: When did it become known to PG&E that the excess PCIA resource capacity was available?
ANSWER026
PG&E objects to this question on the grounds that it is beyond the scope of the ERRA Compliance proceeding, is irrelevant, and is not reasonably calculated to lead to admissible evidence. This data request is irrelevant to the subject matter of this proceeding because the ERRA Compliance proceeding concerns PG&E's demonstration of com liance with its Bundled Procurement Plan BPP The final quantity of excess RA capacity shown towards meeting Summer Reliability procurement targets was identified between T-50 and T-30 days prior to the compliance month.
ERRA-2022-PGE-Compliance_DR_CalCCA_003-Q026 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 003-0027
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 003-0027 Request Date: April 25, 2023 Requester DR No.: 003
Date Sent: May 23, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Viiavkar
QUESTION 027
Referring to CalCCA DR Response 2.55: If the referenced excess PCIA resource capacity was not previously known to be available, what circumstances changed that caused the capacity to become excess and available for use to meet summer reliability needs?
ANSWER 027
PG&E objects to this question on the grounds that it is beyond the scope of the ERRA Compliance proceeding, is irrelevant, and is not reasonably calculated to lead to admissible evidence. This data request is irrelevant to the subject matter of this proceeding because the ERRA Compliance proceeding concerns PG&E's demonstration of com liance with its Bundled Procurement Plan BPP .
PG&E's bundled RA position changed due to a variety of conditions.
ERRA-2022-PGE-Compliance_DR_CalCCA_003-Q027 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 003-0028
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 003-0 028 Request Date: April 25, 2023 Requester DR No.: 003
Date Sent: May 23, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Viiavkar
QUESTION 028
Referring to CalCCA DR Response 2.55: Please explain specifically how PG&E communicated to other LSEs that the excess capacity had become available.
ANSWER028
PG&E objects to this question on the grounds that it is beyond the scope of the ERRA Compliance proceeding, is irrelevant, and is not reasonably calculated to lead to admissible evidence. This data request is irrelevant to the subject matter of this proceeding because the ERRA Compliance proceeding concerns PG&E's demonstration of com liance with its Bundled Procurement Plan BPP responds as fol lows:
For information regarding the required commercial processes under Appendix S of PG&E's BPP, please refer to Section 8.1.d of Appendix S. PG&E complied with the requirements in Appendix S of its BPP at all times.
ERRA-2022-PGE-Compliance_DR_CalCCA_003-Q028 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 003-0031
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 003-Q031CONF Request Date: April 25, 2023 Requester DR No.: 003
Date Sent: May 23, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Viiavkar
QUESTION 031
Referring to the previous question and MOR 1.8, Attachment 2:
a.
b.
C.
ANSWER 031
THIS DA TA RESPONSE CONTAINS 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 DA TED MAY 23, 2023 - SUBJECT TO NDA.
PG&E objects to this data request to the extent that it seeks information intended to support an argument that excess capacity was required to be offered in an RA solicitation pursuant to Appendix S of PG&E's BPP on the grounds that it assumes facts not in evidence, is beyond the scope of the ERRA Compliance proceeding, is irrelevant, and is not reasonably calculated to lead to admissible evidence. This data request refers to the previous question, which refers to CalCCA DR Res onse 2.57 which is remised on the false assum tion
ant
ncern no
compliance with its BPP. Subject to and without waiving this objection, PG&E responds as follows:
ERRA-2022-PGE-Compliance_DR_ CalCCA_003-Q031 CONF Page 1 ERRA-2022-PGE-Compliance_DR_CalCCA_003-Q031CONF Page 2
PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account - Compliance
Application 23-02-018
Data Response
PG&E Data Request No.: CalCCA 003-0033
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 003-Q033CONF Request Date: April 25, 2023 Requester DR No.: 003
Date Sent: May 23, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Viiavkar
QUESTION 033
Referring to CalCCA MOR 1.8, Attachment 2: Please explain how PG&E ends up with excess to transfer from PABA to CAM for Summer Reliabilit even thou h the osition iiiii~e ANSWER033
PG&E objects to this question on the grounds that it is beyond the scope of the ERRA Compliance proceeding, is irrelevant, and is not reasonably calculated to lead to admissible evidence. This data request is irrelevant to the subject matter of this proceeding because the ERRA Compliance proceeding concerns PG&E's demonstration of com liance with its Bundled Procurement Plan BPP .
The final quantity of excess RA capacity shown towards meeting Summer Reliability procurement targets was identified between T-50 and T-30 days prior to the compliance month.
ERRA-2022-PGE-Compliance_DR_CalCCA_003-Q033CONF Page 1
PACIFIC GAS AND ELECTRIC COMPANY
2022 Energy Resource Recovery Account - Compliance
Application 23-02-018
Data Response
PG&E Data Reauest No.: CalCCA 004-Q014
PG&E File Name: ERRA-2022-PGE-Comoliance DR CalCCA 004-Q014CONF Reauest Date: June 29, 2023 Reauester DR No.: 004
Date Sent: July 14, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 014
Referring to PG&E's response to CalCCA 03.33: Please explain in detail how PG&E can show
ANSWER 014
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 ERRA-2022-PGE-Compliance_DR_ CalCCA_004-Q014CONF Page 1 ERRA-2022-PGE-Compliance_DR_CalCCA_004-Q015 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 004-Q015
PG&E File Name: ERRA-2022-PGE-Compliance DR CalCCA 004-Q015 Request Date: June 29, 2023 Requester DR No.: 004
Date Sent: July 14, 2023 Requesting Party: California Community Choice Association
PG&E Witness: Robert Gomez Requester: Nikhil Vijaykar
QUESTION 015
Referring to PG&E’s response to CalCCA 03.33: Please explain how PG&E may forecast a shortfall in RA for a given period but later have actual excess RA in that period.
ANSWER 015
PG&E objects to this question on the grounds that it is beyond the scope of the ERRA Compliance proceeding, is irrelevant, and is not reasonably calculated to lead to admissible evidence. This data request is irrelevant to the subject matter of this proceeding because the ERRA Compliance proceeding concerns PG&E’s demonstration of compliance with its Bundled Procurement Plan (BPP). The possible RA position changes that can occur after the monthly sales amount is determined pursuant to the BPP are not relevant to whether PG&E complied with the BPP. Subject to and without waiving this objection, PG&E responds as follows:
PG&E’s bundled RA position changed due to a variety of conditions.