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49 Appendix B
Program list extract from CEDARS, September 16, 2024.
Index Program Program Name Status PA
1 BAY_CS_PortfolioSupport PORTFOLIO ADMIN-CODES & STANDARDS New BayREN 2 BAY_Equity_PortfolioSupport PORTFOLIO ADMIN-EQUITY New BayREN 3 BAY_MS_PortfolioSupport PORTFOLIO ADMIN-MARKET SUPPORT New BayREN 4 BAY_RA_PortfolioSupport PORTFOLIO ADMIN-RESOURCE ACQUISITION New BayREN 5 BAYREN02 Multi Family Active BayREN
6 BAYREN02-A BAMBE Electrification Active BayREN
7 BAYREN02_IDSM MULTIFAMILY IDSM New BayREN
8 BAYREN03 Codes and Standards Program Active BayREN
9 BAYREN04 Water Upgrades Save Active BayREN
10 BAYREN05-A Evaluation Measurement and Verification - BAYREN Active BayREN 11 BAYREN06 Commercial Active BayREN
12 BAYREN07 Green Labeling Active BayREN
13 BAYREN08 Single Family Active BayREN
14 BAYREN08_IDSM SINGLE FAMILY IDSM New BayREN
15 BAYREN09 Climate Careers New BayREN
16 BAYREN10 Refrigerant Replacement New BayREN
17 BAYREN11 Integrated Energy Services New BayREN
18 BAYREN11_IDSM INTEGRATED ENERGY SERVICES IDSM New BayREN 19 BAYREN12 Targeted Decarbonization Services New BayREN 20 BAYREN12_IDSM TARGETED DECARBONIZATION SERVICES IDSM New BayREN 21 BAY_SW_HESC SW Home Energy Score California New BayREN 22 BAY_SW_HESC_PA SW Home Energy Score California - PA Costs New BayREN 23 CPSF_FS CPSF Food Service New CPSF
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50 Index Program Program Name Status PA
24 EBCE01 Commercial Pay-for-Performance Energy Efficiency Program New EBCE 25 IREN-CS-001 C&S Training and Education Program New IREN 26 IREN-CS-002 C&S Technical Support Program New IREN
27 IREN-CS-PortfolioSupport PORTFOLIO ADMIN-CODES & STANDARDS New IREN 28 IREN-EMV-001 IREN EM&V New IREN
29 IREN-Equity-PortfolioSupport PORTFOLIO ADMIN-EQUITY New IREN 30 IREN-IDSM-Equity-001 Equity IDSM New IREN
31 IREN-MS-PortfolioSupport PORTFOLIO ADMIN-MARKET SUPPORT New IREN 32 IREN-PUBL-001 Technical Assistance and Strategic Energy Planning Program New IREN 33 IREN-PUBL-002 Public Buildings NMEC Program New IREN 34 IREN-WET-001 WE&T Training and Education Program New IREN 35 IREN-WET-002 WE&T Workforce Development Program New IREN 36 MCE01 Multifamily Energy Savings Active MCE
37 MCE01c Multifamily Strategic Energy Management Active MCE 38 MCE01d Res Marketplace New MCE
39 MCE02a Commercial Deemed Active MCE
40 MCE02b Commercial Custom Active MCE
41 MCE02c Commercial Strategic Energy Management Active MCE 42 MCE02d Commercial Marketplace Active MCE
43 MCE02e Commercial Equity Transitioning MCE
44 MCE08 Single Family Home Energy Savings Active MCE
45 MCE100 Integrated Demand Side Management (IDSM) New MCE 46 MCE101-Equity-PS Equity Portfolio Support New MCE
47 MCE101-MS-PS Market Support Portfolio Support New MCE 48 MCE101-RA-PS Resource Acquisition Portfolio Support New MCE 49 MCE10a Industrial Deemed Active MCE
50 MCE10b Industrial Custom Active MCE
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51 Index Program Program Name Status PA
51 MCE10c Industrial Strategic Energy Management Active MCE 52 MCE11a Agricultural Deemed Active MCE
53 MCE11b Agricultural Custom Active MCE
54 MCE11c Agricultural Strategic Energy Management Active MCE 55 MCE16 Green Workforce Pathways Active MCE
56 MCE17 Commercial Equity New MCE
57 MCE97 CPUC EM&V Active MCE
58 MCE98 MCE EM&V Active MCE
59 PCE01 PCE FLEXmarket New PCE
60 PGE21002 Residential Energy Efficiency Active PGE
61 PGE21005 Residential New Construction Active PGE
62 PGE21007 California New Homes Multifamily Active PGE 63 PGE21011 Commercial Calculated Incentives Active PGE 64 PGE21012 Commercial Deemed Incentives Active PGE
65 PGE21014 Commercial Energy Advisor Active PGE
66 PGE210143 Hospitality Program Active PGE
67 PGE21015 Commercial HVAC Active PGE
68 PGE21021 Industrial Calculated Incentives Active PGE 69 PGE210210 Industrial Recommissioning Program Active PGE 70 PGE210212 Compressed Air and Vacuum Optimization Program Active PGE 71 PGE21022 Industrial Deemed Incentives Active PGE
72 PGE21024 Industrial Energy Advisor Active PGE
73 PGE21027 Heavy Industry Energy Efficiency Program Active PGE 74 PGE21031 Agricultural Calculated Incentives Active PGE 75 PGE21032 Agricultural Deemed Incentives Active PGE
76 PGE21034 Agricultural Energy Advisor Active PGE
77 PGE21051 Building Codes Advocacy Active PGE
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52 Index Program Program Name Status PA
78 PGE21053 Compliance Improvement Active PGE
79 PGE21054 Reach Codes Active PGE
80 PGE21055 Planning and Coordination Active PGE
81 PGE21056 Code Readiness Active PGE
82 PGE21061 Technology Development Support Active PGE
83 PGE21062 Technology Assessments Active PGE
84 PGE21063 Technology Introduction Support Active PGE
85 PGE21071 WE&T Integrated Energy Education and Training Active PGE 86 PGE21072 WE&T Connections Active PGE
87 PGE21073 WE&T Strategic Planning Active PGE
88 PGE21091 On-Bill Financing (excludes Loan Pool) Active PGE 89 PGE210911 On-Bill Financing Alternative Pathway Active PGE 90 PGE21092 Third-Party Financing Active PGE
91 PGE21093 New Financing Offerings Active PGE
92 PGE2110011 California Community Colleges Active PGE
93 PGE2110012 University of California/California State University Active PGE 94 PGE2110013 State of California Active PGE
95 PGE2110014 Department of Corrections and Rehabilitation Active PGE 96 PGE2110051 Local Government Energy Action Resources (LGEAR) Active PGE 97 PGE211025 Savings by Design (SBD) Active PGE
98 PGE_Ag_001 Agricultural Efficiency Program Active PGE 99 PGE_CEC_SEES SEESP Funds Transfer to CEC Active PGE
100 PGE_Com_001 Grocery Efficiency Program Active PGE
101 PGE_Com_002 Laboratory Performance Efficiency Program Active PGE 102 PGE_Com_003 Commercial Efficiency Program Active PGE 103 PGE_Com_004 High Tech and Bio Tech Efficiency Program Active PGE 104 PGE_Com_005 Healthcare Efficiency Program Active PGE D.23-06-055 Ordering Paragraph 32 Report
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53 Index Program Program Name Status PA
105 PGE_Com_006 Summer Reliability Platform Administrator Placeholder New PGE 106 PGE_Com_007 Commercial Behavioral Program New PGE
107 PGE_Com_008 Multi-DER Placeholder New PGE
108 PGE_Com_EM Commercial Energy Management Placeholder New PGE 109 PGE_Com_SmallBiz Micro and Small Business Program Active PGE 110 PGE_Com_ZE Zonal Electrification Placeholder (Commercial) New PGE 111 PGE_CS_Decarb C&S Decarbonization Support Placeholder New PGE 112 PGE_CS_GRC_Overheads GRC Labor Loaders - Codes and Standards Active PGE 113 PGE_CS_PortfolioSupport Codes & Standards Portfolio Support PA Costs Active PGE 114 PGE_EMV Evaluation Measurement and Verification Active PGE 115 PGE_EMV_001 PGE EM&V Transitioning PGE
116 PGE_EMV_002 CPUC EM&V Transitioning PGE
117 PGE_Equity_GRC_Overheads GRC Labor Loaders - Equity Active PGE 118 PGE_Equity_PortfolioSupport Equity Portfolio Support PA Costs Active PGE 119 PGE_ESA Energy Savings Assistance Active PGE
120 PGE_Ind_001a Industrial Strategic Energy Management - Food Processing Active PGE 121 PGE_Ind_001b Industrial Strategic Energy Management - Manufacturing Active PGE 122 PGE_Ind_002 Petroleum and Chemical Efficiency Program Active PGE 123 PGE_Ind_003 Manufacturing and Food Processing Efficiency Program Active PGE 124 PGE_LoanPool Financing Loan Pool Addition Active PGE 125 PGE_MS_GRC_Overheads GRC Labor Loaders - Market Support Active PGE 126 PGE_MS_PortfolioSupport Market Support Portfolio Support PA Costs Active PGE 127 PGE_OBFAP On-Bill Financing Alternative Pathway Transitioning PGE 128 PGE_OtherPA_Admin IOU REN/CCA Admin Costs New PGE
129 PGE_Portfolio_Oversight ED Portfolio Oversight Active PGE 130 PGE_Pub_001 Central Coast Local Government Partnership Active PGE 131 PGE_Pub_002 Marin Local Government Partnership Active PGE D.23-06-055 Ordering Paragraph 32 Report
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54 Index Program Program Name Status PA
132 PGE_Pub_003 Redwood Local Government Partnership Active PGE 133 PGE_Pub_004 Central California Local Government Partnership Active PGE 134 PGE_Pub_005 San Mateo Local Government Partnership Active PGE 135 PGE_Pub_007 Sierra Local Government Partnership Active PGE 136 PGE_Pub_008 Sonoma Local Government Partnership Active PGE 137 PGE_Pub_009 Government and K-12 Comprehensive Program Active PGE 138 PGE_Pub_010 Wastewater Process Efficiency Program Active PGE 139 PGE_Pub_011 California Analysis Tool for Locational Energy Assessment New PGE 140 PGE_Pub_Resiliency Resiliency Support Placeholder (Public) New PGE 141 PGE_RA_GRC_Overheads GRC Labor Loaders - Resource Acquisition Active PGE 142 PGE_RA_PortfolioSupport Resource Acquisition Portfolio Support PA Costs Active PGE 143 PGE_Res_001a Pay for Performance - Comfortable Home Rebates Active PGE 144 PGE_Res_001b Virtual Energy Audit Program Active PGE 145 PGE_Res_001c Pay for Performance - Home Energy Rewards Active PGE 146 PGE_Res_001d Pay for Performance - Home Energy Optimization Active PGE 147 PGE_Res_002a Universal Audit Tool Program Active PGE 148 PGE_Res_002d Residential Behavioral Program Active PGE 149 PGE_Res_002e Online Marketplace Program New PGE
150 PGE_Res_Equity Residential Equity Placeholder New PGE 151 PGE_Res_LoadMgt Residential Load Management Placeholder New PGE 152 PGE_Res_Mkt_Spt Residential Market Support Placeholder New PGE 153 PGE_Res_Resiliency Resiliency Support Placeholder (Residential) New PGE 154 PGE_Res_ZE Zonal Electrification Placeholder (Residential) New PGE 155 PGE_SW_CSA_Appl State Appliance Standards Advocacy Active PGE 156 PGE_SW_CSA_Appl_PA State Appliance Standards Advocacy - PGE Costs Active PGE 157 PGE_SW_CSA_Bldg State Building Codes Advocacy Active PGE 158 PGE_SW_CSA_Bldg_PA State Building Codes Advocacy - PGE Costs Active PGE D.23-06-055 Ordering Paragraph 32 Report
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55 Index Program Program Name Status PA
159 PGE_SW_CSA_Natl National Codes & Standards Advocacy Active PGE 160 PGE_SW_CSA_Natl_PA National Codes & Standards Advocacy - PGE Costs Active PGE 161 PGE_SW_ETP_Elec Emerging Technologies Program, Electric New PGE 162 PGE_SW_ETP_Elec_PA Emerging Technologies Program, Electric - PGE Costs New PGE 163 PGE_SW_ETP_Gas Emerging Technologies Program, Gas Active PGE 164 PGE_SW_ETP_Gas_PA Emerging Technologies Program, Gas - PGE Costs Active PGE 165 PGE_SW_FS Food Service POS Active PGE
166 PGE_SW_FS_PA Food Service POS - PGE Costs Active PGE 167 PGE_SW_HVAC_QIQM Statewide Residential QI/QM New PGE 168 PGE_SW_HVAC_QIQM_PA Statewide Residential QI/QM - PGE Costs New PGE 169 PGE_SW_HVAC_Up_Com SW HVAC Upstream Commercial New PGE 170 PGE_SW_HVAC_Up_Com_PA SW HVAC Upstream Commercial - PGE Costs New PGE 171 PGE_SW_HVAC_Up_Res SW HVAC Upstream Residential New PGE 172 PGE_SW_HVAC_Up_Res_PA SW HVAC Upstream Residential - PGE Costs New PGE 173 PGE_SW_IP_Colleges Institutional Partnerships, UC/CSU/CCC Active PGE 174 PGE_SW_IP_Colleges_PA Institutional Partnerships, UC/CSU/CCC - PGE Costs Active PGE 175 PGE_SW_IP_Gov Institutional Partnerships: DGS and DoC Active PGE 176 PGE_SW_IP_Gov_PA Institutional Partnerships: DGS and DoC - PGE Costs Active PGE 177 PGE_SW_MCWH Midstream Comm Water Heating Active PGE 178 PGE_SW_MCWH_PA Midstream Comm Water Heating - PGE Costs Active PGE 179 PGE_SWMEO Statewide Marketing Education and Outreach Active PGE 180 PGE_SW_NC_NonRes_Ag_electric SW New Construction NonRes Ag - All Electric Active PGE 181 PGE_SW_NC_NonRes_Ag_electric_PA SW New Construction NonRes Ag - All Electric - PGE Costs Active PGE 182 PGE_SW_NC_NonRes_Ag_mixed SW New Construction NonRes Ag - Mixed Fuel Active PGE 183 PGE_SW_NC_NonRes_Ag_mixed_PA SW New Construction NonRes Ag - Mixed Fuel - PGE Costs Active PGE 184 PGE_SW_NC_NonRes_Com_electric SW New Construction NonRes Com - All Electric Active PGE 185 PGE_SW_NC_NonRes_Com_electric_PA SW New Construction NonRes Com - All Electric - PGE Costs Active PGE D.23-06-055 Ordering Paragraph 32 Report
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56 Index Program Program Name Status PA
186 PGE_SW_NC_NonRes_Com_mixed SW New Construction NonRes Com - Mixed Fuel Active PGE 187 PGE_SW_NC_NonRes_Com_mixed_PA SW New Construction NonRes Com - Mixed Fuel - PGE Costs Active PGE 188 PGE_SW_NC_NonRes_Ind_electric SW New Construction NonRes Ind - All Electric Active PGE 189 PGE_SW_NC_NonRes_Ind_electric_PA SW New Construction NonRes Ind - All Electric - PGE Costs Active PGE 190 PGE_SW_NC_NonRes_Ind_mixed SW New Construction NonRes Ind - Mixed Fuel Active PGE 191 PGE_SW_NC_NonRes_Ind_mixed_PA SW New Construction NonRes Ind - Mixed Fuel - PGE Costs Active PGE 192 PGE_SW_NC_NonRes_Pub_electric SW New Construction NonRes Public - All Electric Active PGE 193 PGE_SW_NC_NonRes_Pub_electric_PA SW New Construction NonRes Public - All Electric - PGE Costs Active PGE 194 PGE_SW_NC_NonRes_Pub_mixed SW New Construction NonRes Public - Mixed Fuel Active PGE 195 PGE_SW_NC_NonRes_Pub_mixed_PA SW New Construction NonRes Public - Mixed Fuel - PGE Costs Active PGE 196 PGE_SW_NC_NonRes_Res_electric SW New Construction NonRes Res - All Electric Active PGE 197 PGE_SW_NC_NonRes_Res_electric_PA SW New Construction NonRes Res - All Electric - PGE Costs Active PGE 198 PGE_SW_NC_NonRes_Res_mixed SW New Construction NonRes Res - Mixed Fuel Active PGE 199 PGE_SW_NC_NonRes_Res_mixed_PA SW New Construction NonRes Res - Mixed Fuel - PGE Costs Active PGE 200 PGE_SW_NC_Res_electric SW New Construction Res - All Electric Active PGE 201 PGE_SW_NC_Res_electric_PA SW New Construction Res - All Electric - PGE Costs Active PGE 202 PGE_SW_PLA Plug Load and Appliance Active PGE
203 PGE_SW_PLA_PA Plug Load and Appliance - PGE Costs Active PGE 204 PGE_SW_UL_PA Lighting (Upstream) - PGE Costs Active PGE 205 PGE_SW_WET_CC WET Career Connections Active PGE
206 PGE_SW_WET_CC_PA WET Career Connections - PGE Costs Active PGE 207 PGE_SW_WET_Work WET Career and Workforce Readiness Active PGE 208 PGE_SW_WET_Work_PA WET Career and Workforce Readiness - PGE Costs Active PGE 209 PGE_SW_WP Water/wastewater Pumping New PGE
210 PGE_SW_WP_PA Water/wastewater Pumping - PGE Costs New PGE 211 PGE_WATER Water Energy Nexus Active PGE
212 RREN01 Residential Resource Acquisition New RREN
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57 Index Program Program Name Status PA
213 RREN02 Commercial Resource Acquisition New RREN
214 RREN03 Public Equity New RREN
215 RREN04 Residential Equity New RREN
216 RREN05 Rural Workforce Education and Training New RREN 217 RREN06 Rural Codes and Standards Program New RREN
218 RREN07 Rural Finance Equity New RREN
219 RREN08_RA_PortfolioSupport Resource Acquisition Portfolio Support PA Costs New RREN 220 RREN09_Equity_PortfolioSupport Equity Portfolio Support PA Costs New RREN 221 RREN10_CS_PortfolioSupport Codes & Standards Portfolio Support PA Costs New RREN 222 RREN11_EMV Evaluation Measurement & Verification Costs New RREN 223 RREN12_IDSM RuralREN IDSM Budget New RREN
224 SCE-13-ESA Energy Savings Assistance Program Active SCE 225 SCE-13-L-002Y Grandfathered Street Lights Active SCE 226 SCE-13-L-003A California Community Colleges Energy Efficiency Partnership Transitioning SCE 227 SCE-13-L-003G UC/CSU Energy Efficiency Partnership Transitioning SCE 228 SCE-13-RENAdmin IOU REN Administrative Costs Active SCE 229 SCE-13-SW-001A Energy Advisor Program Active SCE
230 SCE-13-SW-001B Plug Load and Appliances Program Transitioning SCE 231 SCE-13-SW-001F Residential New Construction Program Transitioning SCE 232 SCE-13-SW-001G Residential Direct Install Program Active SCE 233 SCE-13-SW-002A Commercial Energy Advisor Program Active SCE 234 SCE-13-SW-002F Nonresidential HVAC Program Transitioning SCE 235 SCE-13-SW-003D Strategic Energy Management Program Active SCE 236 SCE-13-SW-007A On-Bill Financing Active SCE
237 SCE-13-SW-007A1 On-Bill Financing Loan Pool Active SCE 238 SCE-13-SW-007C New Finance Offerings Active SCE
239 SCE-13-SW-007C1 New Finance Offerings Credit Enhancements New SCE D.23-06-055 Ordering Paragraph 32 Report
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58 Index Program Program Name Status PA
240 SCE-13-SW-008C Compliance Improvement Active SCE
241 SCE-13-SW-008D Reach Codes Active SCE
242 SCE-13-SW-008E Planning and Coordination Active SCE 243 SCE-13-SW-009A Technology Development Support Transitioning SCE 244 SCE-13-SW-009B Technology Assessments Transitioning SCE 245 SCE-13-SW-009C Technology Introduction Support Transitioning SCE 246 SCE-13-SW-010A WE&T Integrated Energy Education and Training Active SCE 247 SCE-13-SWMEO Statewide Marketing, Education & Outreach Active SCE 248 SCE-13-TP-001 Comprehensive Manufactured Homes Active SCE 249 SCE-13-TP-022 Water Infrastructure Systems Energy Efficiency Program Transitioning SCE 250 SCE-13-TP-025 Facility Assessment Service Program Active SCE 251 SCE-13-TP-026 Residential 3P Solicitation Active SCE 252 SCE-13-TP-027 Commercial 3P Solicitation Active SCE 253 SCE-13-TP-028 Industrial 3P Solicitation Active SCE 254 SCE-13-TP-029 Local Public Sector 3P Solicitation New SCE 255 SCE-13-TP-030 Agricultural 3P Solicitation New SCE
256 SCE-3OV0100 SCE EM&V Active SCE
257 SCE-3OV0200 CPUC EM&V Active SCE
258 SCE_3P_2020RCI_001 Marketplace New SCE
259 SCE_3P_2020RCI_003 Commercial Behavioral Program Active SCE 260 SCE_3P_2020RCI_005 Comprehensive Commercial Program Active SCE 261 SCE_3P_2021AGPUB_001 Agriculture Energy Efficiency Program New SCE 262 SCE_3P_2021AGPUB_002 Public Energy Performance Program New SCE 263 SCE_3P_SEM_001 Commercial Energy Manager Program New SCE 264 SCE_3P_SEM_002 Industrial and Agriculture Energy Manager Program (Ind) New SCE 265 SCE_CS_PortfolioSupport Codes & Standards Portfolio Support Costs New SCE 266 SCE_Equity_PortfolioSupport Equity Portfolio Support Costs New SCE D.23-06-055 Ordering Paragraph 32 Report
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59 Index Program Program Name Status PA
267 SCE_MarketSupport_001 EE New Program Design Pilots New SCE 268 SCE_MarketSupport_002 EE Contractor Demand Building Program New SCE 269 SCE_MS_PortfolioSupport Market Support Portfolio Support Costs New SCE 270 SCE_PB_CS Codes and Standards P&B New SCE
271 SCE_PB_EMV EM&V P&B New SCE
272 SCE_PB_Equity Equity P&B New SCE
273 SCE_PB_MS Market Support P&B New SCE
274 SCE_PB_RA Resource Acquisition P&B New SCE
275 SCE_Portfolio_Oversight ED Portfolio Oversight New SCE 276 SCE_RA_PortfolioSupport Resource Acquisition Portfolio Support Costs New SCE 277 SCE_Res_Equity_001 Residential Energy Advisor (Resource) New SCE 278 SCE_Res_Equity_002 Residential Energy Advisor (Non-Resource) New SCE 279 SCE_Res_Equity_003 Disadvantaged Communities Marketing and Outreach New SCE 280 SCE_SMB_Equity_001 Simplified Savings New SCE
281 SCE_SW_CSA_Appl Codes & Standards Advocacy - State Appliance Standards Advocacy Active SCE 282 SCE_SW_CSA_Appl_PA Codes & Standards Advocacy - State Appliance Standards Advocacy - SCE Costs
Active SCE
283 SCE_SW_CSA_Bldg Codes & Standards Advocacy - State Building Codes Advocacy Active SCE 284 SCE_SW_CSA_Bldg_PA Codes & Standards Advocacy - State Building Codes Advocacy - SCE Costs
Active SCE
285 SCE_SW_CSA_Natl Codes & Standards Advocacy - National Codes & Standards Advocacy Active SCE 286 SCE_SW_CSA_Natl_PA Codes & Standards Advocacy - National Codes & Standards Advocacy - SCE Costs
Active SCE
287 SCE_SW_ETP_Elec Emerging Technologies Program, Electric New SCE 288 SCE_SW_ETP_Elec_PA Emerging Technologies Program, Electric - SCE Costs New SCE 289 SCE_SW_FS Food Service POS Active SCE
290 SCE_SW_FS_PA Food Service POS - SCE Costs Active SCE 291 SCE_SW_HVAC_QIQM SW HVAC QI/QM Program New SCE
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60 Index Program Program Name Status PA
292 SCE_SW_HVAC_QIQM_PA SW HVAC QI/QM Program - SCE Costs Active SCE 293 SCE_SW_HVAC_Up_Com SW HVAC Upstream Commercial New SCE 294 SCE_SW_HVAC_Up_Com_PA SW HVAC Upstream Commercial - SCE Costs New SCE 295 SCE_SW_HVAC_Up_Res SW HVAC Upstream Residential New SCE 296 SCE_SW_HVAC_Up_Res_PA SW HVAC Upstream Residential - SCE Costs New SCE 297 SCE_SW_IP_Colleges Institutional Partnerships, UC/CSU/CCC New SCE 298 SCE_SW_IP_Colleges_PA Institutional Partnerships, UC/CSU/CCC - SCE Costs New SCE 299 SCE_SW_IP_Gov Institutional Partnerships: DGS & DoC Active SCE 300 SCE_SW_IP_Gov_PA Institutional Partnerships: DGS & DoC - SCE Costs Active SCE 301 SCE_SW_MCWH Midstream Comm Water Heating Active SCE 302 SCE_SW_MCWH_PA Midstream Comm Water Heating - SCE Costs Active SCE 303 SCE_SW_NC_NonRes_Ag_electric SW New Construction NonRes Ag - All Electric Active SCE 304 SCE_SW_NC_NonRes_Ag_electric_PA SW New Construction NonRes Ag - All Electric - SCE Costs Active SCE 305 SCE_SW_NC_NonRes_Ag_mixed SW New Construction NonRes Ag - Mixed Fuel Active SCE 306 SCE_SW_NC_NonRes_Ag_mixed_PA SW New Construction NonRes Ag - Mixed Fuel - SCE Costs Active SCE 307 SCE_SW_NC_NonRes_Com_electric SW New Construction NonRes Com - All Electric Active SCE 308 SCE_SW_NC_NonRes_Com_electric_PA SW New Construction NonRes Com - All Electric - SCE Costs Active SCE 309 SCE_SW_NC_NonRes_Com_mixed SW New Construction NonRes Com - Mixed Fuel Active SCE 310 SCE_SW_NC_NonRes_Com_mixed_PA SW New Construction NonRes Com - Mixed Fuel - SCE Costs Active SCE 311 SCE_SW_NC_NonRes_Ind_electric SW New Construction NonRes Ind - All Electric Active SCE 312 SCE_SW_NC_NonRes_Ind_electric_PA SW New Construction NonRes Ind - All Electric - SCE Costs Active SCE 313 SCE_SW_NC_NonRes_Ind_mixed SW New Construction NonRes Ind - Mixed Fuel Active SCE 314 SCE_SW_NC_NonRes_Ind_mixed_PA SW New Construction NonRes Ind - Mixed Fuel - SCE Costs Active SCE 315 SCE_SW_NC_NonRes_Pub_electric SW New Construction NonRes Public - All Electric Active SCE 316 SCE_SW_NC_NonRes_Pub_electric_PA SW New Construction NonRes Public - All Electric - SCE Costs Active SCE 317 SCE_SW_NC_NonRes_Pub_mixed SW New Construction NonRes Public - Mixed Fuel Active SCE 318 SCE_SW_NC_NonRes_Pub_mixed_PA SW New Construction NonRes Public - Mixed Fuel - SCE Costs Active SCE D.23-06-055 Ordering Paragraph 32 Report
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61 Index Program Program Name Status PA
319 SCE_SW_NC_NonRes_Res_electric SW New Construction NonRes Res - All Electric Active SCE 320 SCE_SW_NC_NonRes_Res_electric_PA SW New Construction NonRes Res - All Electric - SCE Costs Active SCE 321 SCE_SW_NC_NonRes_Res_mixed SW New Construction NonRes Res - Mixed Fuel Active SCE 322 SCE_SW_NC_NonRes_Res_mixed_PA SW New Construction NonRes Res - Mixed Fuel - SCE Costs Active SCE 323 SCE_SW_NC_Res_electric SW New Construction Res - All Electric Active SCE 324 SCE_SW_NC_Res_electric_PA SW New Construction Res - All Electric - SCE Costs Active SCE 325 SCE_SW_NC_Res_mixed_PA SW New Construction Res - Mixed Fuel - SCE Costs Active SCE 326 SCE_SW_PLA Plug Load and Appliance Active SCE
327 SCE_SW_PLA_PA Plug Load and Appliance - SCE Costs New SCE 328 SCE_SW_UL_PA Lighting (Upstream) - SCE Costs Active SCE 329 SCE_SW_WET_CC WET Career Connections Active SCE
330 SCE_SW_WET_CC_PA WET Career Connections - SCE Costs Active SCE 331 SCE_SW_WET_Work WE&T Career and Workforce Readiness Active SCE 332 SCE_SW_WET_Work_PA WE&T Career and Workforce Readiness - SCE Costs Active SCE 333 SCE_SW_WP Water/wastewater Pumping Active SCE
334 SCE_SW_WP_PA Water/wastewater Pumping - SCE Costs New SCE 335 SCG3701 RES-Residential Energy Advisor Active SCG
336 SCG3702 RES-Residential Energy Efficiency Program Active SCG 337 SCG3705 RES-Multifamily Whole Building Program (Equity) Active SCG 338 SCG3708 COM-Energy Advisor Active SCG
339 SCG3711 COM-Deemed Incentives Active SCG
340 SCG3714 IND-Strategic Energy Management Active SCG
341 SCG3721 ET-Technology Development Support Active SCG 342 SCG3722 ET-Technology Assessment Support Active SCG 343 SCG3723 ET-Technology Introduction Support Active SCG 344 SCG3729 WET&O-Integrated Energy Efficiency Training Active SCG 345 SCG3733 SW-ME&O-ME&O Active SCG
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62 Index Program Program Name Status PA
346 SCG3735 FIN-On-Bill Financing Active SCG
347 SCG3737 FIN-SW-New Financing Offerings Active SCG
348 SCG3757 IND-Small Industrial Facility Upgrades Active SCG 349 SCG3760 WET&O-HERS Rater Training Advancement Active SCG 350 SCG3764 WET&O-Educational Outreach Program Active SCG 351 SCG3771 SOL-IDEEA365 Solicitations Active SCG
352 SCG3772 EM&V-Evaluation Measurement & Verification Active SCG 353 SCG3803 FIN-SW-California Hub for EE Financing Active SCG 354 SCG3823 RES-HVAC QI/QM Transitioning SCG
355 SCG3824 RES-Residential Behavioral Program Active SCG 356 SCG3829 RES-Marketplace Active SCG
357 SCG3830 Retail Channel Support Active SCG
358 SCG3831 RES-EE Kit Delivery Program Active SCG
359 SCG3832 RES-Pasadena Water & Power Home Upgrade Program Active SCG 360 SCG3833 RES-Burbank Water & Power Home Upgrade Program Active SCG 361 SCG3834 COM-LADWP Direct Install Active SCG
362 SCG3837 PUB-SW-Energy Atlas Active SCG
363 SCG3861 RES-Community Language Efficiency Outreach Program Active SCG 364 SCG3882 COM-Small and Medium Commercial EE Program (Resource Acquisition)
Active SCG
365 SCG3883 RES-Residential Advanced Clean Energy Program (Resource Acquisition)
Active SCG
366 SCG3884 RES-Comprehensive Mobile Home Program Active SCG 367 SCG3885 RES-Residential Mobile Home Program Active SCG 368 SCG3886 PUB-Public Direct Install Program Active SCG 369 SCG3887 COM-Commercial-BEST (Resource Acquistion) Active SCG 370 SCG3888 RES-Multifamily Space and Water Heating Controls Active SCG 371 SCG3889 RES-Multifamily Energy Alliance Program (Resource Acquisition) Active SCG D.23-06-055 Ordering Paragraph 32 Report
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63 Index Program Program Name Status PA
372 SCG3890 AG-Agriculture Energy Efficiency Program Active SCG 373 SCG3891 COM-Service RCx Large Commercial Program Active SCG 374 SCG3892 COM-Large Commercial Energy Efficiency Program Active SCG 375 SCG3898 COM-Nonresidential Behavioral Program New SCG 376 SCG3899 PUB-Large Public EE Solicitation New SCG
377 SCG3901 WET&O-Energy Program Outreach New SCG
378 SCG3909 CC-Nonresidential Energy Advisor Program Active SCG 379 SCG3910 CC-Nonresidential Calculated Incentives Active SCG 380 SCG3911 CC-Nonresidential Deemed Incentives Active SCG 381 SCG3912 PUB-Regional Energy Pathways Active SCG
382 SCG3913 PUB-REN Fiscal Management & Coordination Active SCG 383 SCG3935 RES-Residential Advanced Clean Energy Program (Equity) New SCG 384 SCG3936 RES-Multifamily Energy Alliance Program (Equity) New SCG 385 SCG3937 COM-Small and Medium Commercial EE Program (Equity) New SCG 386 SCG3938 RES-Multifamily Whole Building Program (Resource Acquisition) New SCG 387 SCG3939 COM-Strategic Energy Management New SCG
388 SCG3940 COM-Commercial-BEST (Equity) New SCG
389 SCG3941 CC-Sustainability Studio New SCG
390 SCG3942 IND-Industrial Savings, Training, Assistance, and Rebates (Industrial STAR) Program
Active SCG
391 SCG3943 IND-Industrial Energy Partners (IEP) Program New SCG 392 SCG3944 IND-Refinery Gas Energy Efficiency (RGEEP) Program New SCG 393 SCG3945 IND-Innovations to Industrials (i2i) SEM New SCG 394 SCG3948 Summer Reliability Program New SCG
395 SCG3956 K-12 Public Schools Program (K12PSP) New SCG 396 SCG3957 COM-IDEEA365 New SCG
397 SCG3958 Res Energy Efficiency Program Equity New SCG D.23-06-055 Ordering Paragraph 32 Report
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64 Index Program Program Name Status PA
398 SCG3960 Res-IDEEA365 New SCG
399 SCG3961 COM-Pool Heating Energy Efficiency Program New SCG 400 SCG3962 IDSM New SCG
401 SCG_CS_PortfolioSupport Codes & Standards Portfolio Support PA Costs Active SCG 402 SCG_Equity_PortfolioSupport Equity Portfolio Support PA Costs Active SCG 403 SCG-ESAP Energy Savings Assistance Program Active SCG 404 SCG-GRCL GRC Labor Loaders Active SCG
405 SCG_MS_PortfolioSupport Market Support Portfolio Support PA Costs Active SCG 406 SCG_Portfolio_Oversight ED Portfolio Oversight Active SCG 407 SCG_RA_PortfolioSupport Resource Acquisition Portfolio Support PA Costs Active SCG 408 SCG_SW_CSA_Appl C&S-SW-Appliance Standards Advocacy Active SCG 409 SCG_SW_CSA_Appl_PA C&S-SW-Appliance Standards Advocacy-PA Active SCG 410 SCG_SW_CSA_Bldg C&S-SW-Building Codes Advocacy Active SCG 411 SCG_SW_CSA_Bldg_PA C&S-SW-Building Codes Advocacy-PA Active SCG 412 SCG_SW_CSA_Natl C&S-SW-Federal Codes Advocacy Active SCG 413 SCG_SW_CSA_Natl_PA C&S-SW-Federal Codes Advocacy-PA Active SCG 414 SCG_SW_ETP_Gas ET-SW-Emerging Technologies, Gas Active SCG 415 SCG_SW_ETP_Gas_PA ET-SW-Emerging Technologies, Gas-PA Active SCG 416 SCG_SW_FS COM-SW-Point of Sale Food Service Active SCG 417 SCG_SW_FS_PA COM-SW-Point of Sale Food Service-PA Active SCG 418 SCG_SW_HVAC_QIQM RES-SW-HVAC QI/QM Program New SCG
419 SCG_SW_HVAC_QIQM_PA RES-SW-HVAC QI/QM Program-PA New SCG 420 SCG_SW_HVAC_Up_Com COM-SW-HVAC Upstream Commercial New SCG 421 SCG_SW_HVAC_Up_Com_PA COM-SW-HVAC Upstream Commercial-PA New SCG 422 SCG_SW_HVAC_Up_Res RES-SW-HVAC Upstream Residential New SCG 423 SCG_SW_HVAC_Up_Res_PA RES-SW-HVAC Upstream Residential-PA New SCG 424 SCG_SW_IP_Colleges PUB-SW-Institutional Partnership-Colleges New SCG D.23-06-055 Ordering Paragraph 32 Report
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65 Index Program Program Name Status PA
425 SCG_SW_IP_Colleges_PA PUB-SW-Institutional Partnership-Colleges-PA New SCG 426 SCG_SW_IP_Gov PUB-SW-Institutional Partnership-Government Active SCG 427 SCG_SW_IP_Gov_PA PUB-SW-Institutional Partnership-Government-PA Active SCG 428 SCG_SW_MCWH COM-SW-Midstream Commercial Water Heating Active SCG 429 SCG_SW_MCWH_PA COM-SW-Midstream Commercial Water Heating-PA Active SCG 430 SCG_SW_NC_NonRes_Ag_mixed AG-SW-New Construction-Nonresidential-Mixed Fuel Active SCG 431 SCG_SW_NC_NonRes_Ag_mixed_PA AG-SW-New Construction-Nonresidential-Mixed Fuel-PA Active SCG 432 SCG_SW_NC_NonRes_Com_mixed COM-SW-New Construction-Nonresidential-Mixed Fuel Active SCG 433 SCG_SW_NC_NonRes_Com_mixed_PA COM-SW-New Construction-Nonresidential-Mixed Fuel-PA Active SCG 434 SCG_SW_NC_NonRes_Ind_mixed IND-SW-New Construction-Nonresidential-Mixed Fuel Active SCG 435 SCG_SW_NC_NonRes_Ind_mixed_PA IND-SW-New Construction-Nonresidential-Mixed Fuel-PA Active SCG 436 SCG_SW_NC_NonRes_Pub_mixed PUB-SW-New Construction-Nonresidential-Mixed Fuel Active SCG 437 SCG_SW_NC_NonRes_Pub_mixed_PA PUB-SW-New Construction-Nonresidential-Mixed Fuel-PA Active SCG 438 SCG_SW_NC_NonRes_Res_mixed RES-SW-New Construction-Nonresidential-Mixed Fuel Active SCG 439 SCG_SW_NC_NonRes_Res_mixed_PA RES-SW-New Construction-Nonresidential-Mixed Fuel-PA Active SCG 440 SCG_SW_PLA RES-SW-Plug Load and Appliances New SCG
441 SCG_SW_PLA_PA RES-SW-Plug Load and Appliances-PA New SCG 442 SCG_SW_WET_CC WET&O-SW-WE&T Career Connections Active SCG 443 SCG_SW_WET_CC_PA WET&O-SW-WE&T Career Connections-PA Active SCG 444 SCG_SW_WET_Work WET&O-SW-WE&T Career and Workforce Readiness Active SCG 445 SCG_SW_WET_Work_PA WET&O-SW-WE&T Career and Workforce Readiness-PA Active SCG 446 SCG_SW_WP PUB-SW-Water/Wastewater Pumping New SCG
447 SCG_SW_WP_PA PUB-SW-Water/Wastewater Pumping-PA New SCG 448 SCP01 SCP FLEXmarket New SCP
449 SCR-AGR-G1 Agriculture Project Delivery Program New SCR 450 SCR-AGR-G2 Rural-HTR Agricultural DI New SCR
451 SCR-AGR-G3 Agriculture Retrofit New SCR
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66 Index Program Program Name Status PA
452 SCR-CBDC-01 SoCalREN Community Based Design Collaborative New SCR 453 SCR-COM-E2 California Green Business Network New SCR 454 SCR-COM-E3 Food Desert Energy Efficiency Equity Program New SCR 455 SCR-COM-E4 Small & Medium Business Energy Advisory (SMBEA) New SCR 456 SCR-COM-E5 Small Commercial Direct Install Program New SCR 457 SCR_CS_PortfolioSupport Codes & Standards Portfolio Support PA Costs New SCR 458 SCR-CST-F1 Codes and Standards Compliance Enhancement Program New SCR 459 SCR-EMV-01 SoCalREN EM&V Active SCR
460 SCR_EQ_PortfolioSupport Equity Portfolio Support PA Costs New SCR 461 SCR-FIN-C1 Public Agency Revolving Loan Fund Active SCR 462 SCR-FIN-C3 Rural-HTR Agriculture Finance Assistance Program New SCR 463 SCR_MS_PortfolioSupport Market Support Portfolio Support PA Costs New SCR 464 SCR-PUBL-B1 Energy Efficiency Project Delivery Program Active SCR 465 SCR-PUBL-B10 Water Infrastructure Program New SCR
466 SCR-PUBL-B2 Distributed Energy Resource Disadvantaged Communities Program Active SCR 467 SCR-PUBL-B3 Public Agency NMEC Program Active SCR
468 SCR-PUBL-B4 Streamlined Savings Program Active SCR
469 SCR-PUBL-B5 Rural-HTR Public Agency Direct Install New SCR 470 SCR-PUBL-B6 Energy Resiliency Action Plan New SCR
471 SCR-PUBL-B7 Regional Partner Initiatives New SCR
472 SCR-PUBL-B8 Water & Wastewater Strategic Energy Management New SCR 473 SCR-PUBL-B9 Underserved Schools Strategic Energy Management New SCR 474 SCR_RA_PortfolioSupport Resource Acquisition Portfolio Support PA Costs New SCR 475 SCR-RES-A1 Multifamily Program Active SCR
476 SCR-RES-A4 Residential Kits4Kids Active SCR
477 SCR-RES-A5 Small HTR Multifamily Direct Install New SCR 478 SCR-WET-D1 Workforce Education & Training Program Active SCR D.23-06-055 Ordering Paragraph 32 Report
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67 Index Program Program Name Status PA
479 SCR-WET-D2 ACES Pathway New SCR
480 SCR-WET-D3 Green Path Careers New SCR
481 SCR-WET-D4 WE&T Opportunity HUB New SCR
482 SCR-WET-D5 Agriculture WE&T New SCR
483 SCR-WET-D6 E-Contractor Academy New SCR
484 SDGE3226 SW-COM Direct Install Active SDGE
485 SDGE3251 SW C&S - Compliance Enhancement Active SDGE 486 SDGE3252 SW C&S - Reach Codes Active SDGE
487 SDGE3253 SW C&S - Planning Coordination Active SDGE 488 SDGE3262 SW-FIN-On-Bill Finance Active SDGE
489 SDGE3264 SW-FIN-New Finance Offerings Active SDGE
490 SDGE3280 3P-IDEEA Active SDGE
491 SDGE3281 EM&V-Evaluation Measurement & Verification Active SDGE 492 SDGE3308 Finance Pilot ME&O OBR Active SDGE
493 SDGE3312 Finance IT OBR Active SDGE
494 SDGE3325 SW-FIN-Finance Pilots Credit Enhancement Active SDGE 495 SDGE4001 Single Family Program Active SDGE
496 SDGE4002 Multi Family Program Active SDGE
497 SDGE4004 Commercial Large Customer Services (>20KW) Program Active SDGE 498 SDGE4006 Industrial Sector Program Active SDGE
499 SDGE4009 Agricultural Growers Services Program Active SDGE 500 SDGE4010 Local Government Customers Program Active SDGE 501 SDGE4011 K-12 Customer Services Program Active SDGE 502 SDGE4012 Federal Customer Services Program Active SDGE 503 SDGE4040 IDSM Local Residential Behavioral Program (EE) Active SDGE 504 SDGE4052 IDSM Commercial ME&O - DR Active SDGE
505 SDGE4056 IDSM Commercial - DR Active SDGE
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68 Index Program Program Name Status PA
506 SDGE4057 IDSM Behavioral - DR Active SDGE
507 SDGE4058 IDSM Non Res Audits - DR Active SDGE
508 SDGE4168 Lodging (Hotels/Motels) New SDGE
509 SDGE4169 Groceries, Restaurants and Food Storage New SDGE 510 SDGE4170 Wholesale/Retail/Office, including Entertainment Services New SDGE 511 SDGE4171 Private Institutions/Healthcare New SDGE
512 SDGE4173 Small Business Outreach Active SDGE
513 SDGE4174 Workforce, Education & Training Programs Active SDGE 514 SDGE4175 Local Residential Fuel-Substitution New SDGE 515 SDGE4176 Residential Equity Program New SDGE
516 SDGE4184 Non-Residential Behavioral Program New SDGE 517 SDGE4197 Market Access Program - Residential New SDGE 518 SDGE4198 Market Access Program - Commercial New SDGE 519 SDGE_CS_PortfolioSupport Codes & Standards Portfolio Support PA Costs Active SDGE 520 SDGE_Equity_PortfolioSupport Equity Portfolio Support PA Costs Active SDGE 521 SDGE-ESAP Energy Savings Assistance Program (ESA) Active SDGE 522 SDGE-ESPI ESPI Active SDGE
523 SDGE-GRCL GRC Labor Loaders Active SDGE
524 SDGE_MS_PortfolioSupport Market Support Portfolio Support PA Costs Active SDGE 525 SDGE_Portfolio_Oversight ED Portfolio Oversight Active SDGE 526 SDGE_RA_PortfolioSupport Resource Acquisition Portfolio Support PA Costs Active SDGE 527 SDGE_SW_CSA_Appl SW Codes & Standards Advocacy - State Appliance Standards Active SDGE 528 SDGE_SW_CSA_Appl_PA SW Codes & Standards Advocacy - State Appliance Standards (Utility) Active SDGE 529 SDGE_SW_CSA_Bldg SW Codes & Standards Advocacy - State Building Codes Active SDGE 530 SDGE_SW_CSA_Bldg_PA SW Codes & Standards Advocacy - State Building Codes (Utility) Active SDGE 531 SDGE_SW_CSA_Natl SW Codes & Standards Advocacy - National Codes & Standards Advocacy
Active SDGE
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69 Index Program Program Name Status PA
532 SDGE_SW_CSA_Natl_PA SW Codes & Standards Advocacy - National Codes & Standards Advocacy (Utility)
Active SDGE
533 SDGE_SW_ETP_Elec SW Emerging Technologies - Electric New SDGE 534 SDGE_SW_ETP_Elec_PA SW Emerging Technologies - Electric (Utility) New SDGE 535 SDGE_SW_ETP_Gas SW Emerging Technologies - Gas Active SDGE 536 SDGE_SW_ETP_Gas_PA SW Emerging Technologies - Gas (Utility) Active SDGE 537 SDGE_SW_FS SW Foodservice Point of Sale Program Active SDGE 538 SDGE_SW_FS_PA SW Foodservice Point of Sale Program (Utility) Active SDGE 539 SDGE_SW_HESC_PA SW Home Energy Score California (Utility) New SDGE 540 SDGE_SW_HVAC_QIQM SW HVAC QI/QM Program Active SDGE 541 SDGE_SW_HVAC_QIQM_PA SW HVAC QI/QM Program (Utility) Active SDGE 542 SDGE_SW_HVAC_Up_Com SW HVAC Upstream Commercial Active SDGE 543 SDGE_SW_HVAC_Up_Com_PA SW HVAC Upstream Commercial (Utility) Active SDGE 544 SDGE_SW_HVAC_Up_PA SW HVAC Upstream Program (Utility) Active SDGE 545 SDGE_SW_HVAC_Up_Res SW HVAC Upstream Residential Active SDGE 546 SDGE_SW_HVAC_Up_Res_PA SW HVAC Upstream Residential (Utility) Active SDGE 547 SDGE_SW_IP_Colleges SW Higher Education New SDGE
548 SDGE_SW_IP_Colleges_PA SW Higher Education (Utility) New SDGE 549 SDGE_SW_IP_Gov SW Institutional Partnerships: DGS & DoC Active SDGE 550 SDGE_SW_IP_Gov_PA SW Institutional Partnerships: DGS & DoC (Utility) Active SDGE 551 SDGE_SW_MCWH SW Midstream Commercial Water Heating Active SDGE 552 SDGE_SW_MCWH_PA SW Midstream Commercial Water Heating (Utility) Active SDGE 553 SDGE_SW_NC_NonRes_Ag_electric SW New Construction Non Residential - Agricultural - All Electric Active SDGE 554 SDGE_SW_NC_NonRes_Ag_electric_PA SW New Construction Non Residential - Agricultural - All Electric (Utility)
Active SDGE
555 SDGE_SW_NC_NonRes_Ag_mixed SW New Construction Non Residential - Agricultural - Mixed Fuel Active SDGE 556 SDGE_SW_NC_NonRes_Ag_mixed_PA SW New Construction Non Residential - Agricultural - Mixed Fuel (Utility)
Active SDGE
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October 1, 2024
70 Index Program Program Name Status PA
557 SDGE_SW_NC_NonRes_Com_electric SW New Construction Non Residential - Commercial - All Electric Active SDGE 558 SDGE_SW_NC_NonRes_Com_electric_PA SW New Construction Non Residential - Commercial - All Electric (Utility)
Active SDGE
559 SDGE_SW_NC_NonRes_Com_mixed SW New Construction Non Residential - Commercial - Mixed Fuel Active SDGE 560 SDGE_SW_NC_NonRes_Com_mixed_PA SW New Construction Non Residential - Commercial - Mixed Fuel (Utility)
Active SDGE
561 SDGE_SW_NC_NonRes_Ind_electric SW New Construction Non Residential - Industrial - All Electric Active SDGE 562 SDGE_SW_NC_NonRes_Ind_electric_PA SW New Construction Non Residential - Industrial - All Electric (Utility)
Active SDGE
563 SDGE_SW_NC_NonRes_Ind_mixed SW New Construction Non Residential - Industrial - Mixed Fuel Active SDGE 564 SDGE_SW_NC_NonRes_Ind_mixed_PA SW New Construction Non Residential - Industrial - Mixed Fuel (Utility)
Active SDGE
565 SDGE_SW_NC_NonRes_Pub_electric SW New Construction Non Residential - Public - All Electric Active SDGE 566 SDGE_SW_NC_NonRes_Pub_electric_PA SW New Construction Non Residential - Public - All Electric (Utility) Active SDGE 567 SDGE_SW_NC_NonRes_Pub_mixed SW New Construction Non Residential - Public - Mixed Fuel Active SDGE 568 SDGE_SW_NC_NonRes_Pub_mixed_PA SW New Construction Non Residential - Public - Mixed Fuel (Utility) Active SDGE 569 SDGE_SW_NC_NonRes_Res_electric SW New Construction NonResidential - Residential - All Electric Active SDGE 570 SDGE_SW_NC_NonRes_Res_electric_PA SW New Construction NonResidential - Residential - All Electric (Utility)
Active SDGE
571 SDGE_SW_NC_NonRes_Res_mixed SW New Construction NonResidential - Residential - Mixed Fuel Active SDGE 572 SDGE_SW_NC_NonRes_Res_mixed_PA SW New Construction NonResidential - Residential - Mixed Fuel (Utility)
Active SDGE
573 SDGE_SW_NC_Res_electric SW New Construction Residential - All Electric Active SDGE 574 SDGE_SW_NC_Res_electric_PA SW New Construction Residential - All Electric (Utility) Active SDGE 575 SDGE_SW_PLA SW Plug Load and Appliances New SDGE
576 SDGE_SW_PLA_PA SW Plug Load and Appliances (Utility) New SDGE 577 SDGE_SW_UL_PA SW Lighting Program (Utility) Active SDGE 578 SDGE_SW_WET_CC SW WET Career Connections Active SDGE 579 SDGE_SW_WET_CC_PA SW WET Career Connections (Utility) Active SDGE 580 SDGE_SW_WET_Work SW WE&T Career & Workforce Readiness (CWR) Active SDGE D.23-06-055 Ordering Paragraph 32 Report
October 1, 2024
71 Index Program Program Name Status PA
581 SDGE_SW_WET_Work_PA SW WE&T Career & Workforce Readiness (CWR) (Utility) Active SDGE 582 SDGE_SW_WP SW Downstream Water/Wastewater Pumping Program Active SDGE 583 SDGE_SW_WP_PA SW Downstream Water/Wastewater Pumping Program (Utility) Active SDGE 584 SJCE01 Non-Residential New SJCE
585 SJCE02 Residential New SJCE
586 TCR-Ag-001 Agriculture Technical Assistance New TCR 587 TCR-CC-001 Energy Assurance Services (EAS) New TCR
588 TCR-Com-001 Commercial Marketplace New TCR
589 TCR-CS-001 Codes & Standards Active TCR
590 TCR-CS-PortfolioSupport Portfolio Admin - CS New TCR 591 TCR-EMV-001 TCR EM&V Active TCR
592 TCR-Equity-PortfolioSupport Portfolio Admin - Equity New TCR 593 TCR-IDSM-CS-003 IDSM - Codes & Standards New TCR
594 TCR-IDSM-Equity-001 IDSM - Equity New TCR
595 TCR-IDSM-MarketSupport-002 IDSM - Market Support New TCR 596 TCR-MS-PortfolioSupport Portfolio Admin - Market Support New TCR 597 TCR-Res-002 Multifamily New TCR
598 TCR-Res-003 Single Family NMEC New TCR
599 TCR-WET-001 Workforce Education & Training Active TCR
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Application of Pacific Gas and Electric Company
for Compliance Review of Utility Owned
Generation Operations, Portfolio Allocation
Balancing Account Entries, Energy Resource
Recovery Account Entries, Contract Administration,
Economic Dispatch of Electric Resources, Utility
Owned Generation Fuel Procurement, and Other
Activities for the Record Period January 1 through
December 31, 2022
U 39 E
Application 23-02-018
CALIFORNIA COMMUNITY CHOICE ASSOCIATION’S
OPENING BRIEF
PUBLIC VERSION
Leanne Bober
Director of Regulatory Affairs and
Deputy General Counsel
CALIFORNIA COMMUNITY CHOICE
ASSOCIATION
1121 L Street, Suite 400
Sacramento, CA 95814
Telephone (415) 302-2376
E-mail: [email protected]
Nikhil Vijaykar
Tim Lindl
KEYES & FOX LLP
580 California Street, 12th Floor
San Francisco, CA 94104
Telephone: (408) 621-3256
E-mail: [email protected]
[email protected]
Counsel to
CALIFORNIA COMMUNITY CHOICE
ASSOCIATION
Dated: October 4, 2024
SUBJECT MATTER INDEX
I. BACKGROUND ................................................................................................................... 4 A. PG&E's Effo1is to Sell Excess RA Directly Impact PCIA Rates ....................................... 4 B. PG&E Counted Nearly a Gigawatt of Excess RA Capacity Towards its Incremental Procurement Targets During the Summer of2022 ............................................................. 7 II. BURDEN OF PROOF AND LEGAL STANDARD ............................................................ 9 III. ARGUMENT ....................................................................................................................... 10 A.
........................................................................................................................................... 0 B. The Commission Should Scrntinize the Adjustments PG&E Makes to its RA Position to Ensure Any Reductions to the Capacity PG&E Makes Available to the Market are Justified ............................................................................................................................. 14 C. PG&E Did Not Make Reasonable Attempts To Sell Its Excess RA During The Summer of 2022 After It Was Known to be Available ................................................................... 18 D. The Commission Should Not Find PG&E Prndently Managed its RA Po1ifolio and Should Not Find PG&E's PABA Entries are Reasonable ................................................ 19 E. The Commission Should Revisit PG&E's BPP in the IRP Docket.. ................................ 21 IV. CONCLUSION .................................................................................................................... 23 CalCCA's Opening Brief
CalCCA’s Opening Brief ii
TABLE OF AUTHORITIES
Statutes
Cal. Pub. Util. Code § 451 .............................................................................................................. 9 Commission Decisions
D.02-10-062 .................................................................................................................................. 20 D.02-12-069 .................................................................................................................................. 20 D.02-12-074 .................................................................................................................................. 20 D.05-04-036 .................................................................................................................................. 20 D.09-03-025 .................................................................................................................................. 10 D.12-11-051 .................................................................................................................................. 10 D.16-04-006 .................................................................................................................................. 10 D.18-10-019 .................................................................................................................................... 5 D.19-10-001 ................................................................................................................................ 6, 7 D.20-12-036 .................................................................................................................................. 20 D.21-03-056 ................................................................................................................................ 3, 9 D.21-12-015 ............................................................................................................................ 3, 8, 9 D.22-02-002 .................................................................................................................................... 6 D.22-12-044 .................................................................................................................................... 6 D.23-12-008 .................................................................................................................................. 22 D.90-09-088 .................................................................................................................................. 21 Commission Rules of Practice and Procedure
Rule 13.12 ....................................................................................................................................... 1 CalCCA’s Opening Brief iii
SUMMARY OF RECOMMENDATIONS
• The California Public Utilities Commission (Commission) should scrutinize Pacific Gas & Electric Company’s (PG&E) assumptions about resource availability and the adjustments PG&E made to its System Resource Adequacy (RA) position in future ERRA Compliance proceedings to ensure any reductions to the excess RA capacity PG&E made available to the market are justified.
• The Commission should find PG&E did not make reasonable attempts to sell its excess RA capacity to other load-serving entities (LSE) before counting that capacity towards its own system reliability incremental procurement targets.
• The Commission should not find that PG&E prudently managed its utility-owned generation (UOG) facilities.
• The Commission should not find PG&E’s entries recorded to the Portfolio Allocation Balancing Account (PABA) are reasonable.
• The Commission should revisit PG&E’s Bundled Procurement Plan (BPP) in the Integrated Resource Plan (IRP) proceeding to ensure that PG&E is making its excess RA available to the market in a timely and comprehensive manner, including through scheduled solicitations and market offers outside the scheduled solicitation process.
CalCCA’s Opening Brief 1
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Application of Pacific Gas and Electric Company for
Compliance Review of Utility Owned Generation
Operations, Portfolio Allocation Balancing Account
Entries, Energy Resource Recovery Account Entries,
Contract Administration, Economic Dispatch of
Electric Resources, Utility Owned Generation Fuel
Procurement, and Other Activities for the Record
Period January 1 through December 31, 2022
U 39 E
Application 23-02-018
CALIFORNIA COMMUNITY CHOICE ASSOCIATION’S
OPENING BRIEF
The California Community Choice Association1 (CalCCA) submits this Opening Brief regarding the Application of Pacific Gas and Electric Company (U 39 E) for Compliance Review of Utility Owned Generation Operations, Portfolio Allocation Balancing Account Entries, Energy Resource Recovery Account Entries, Contract Administration, Economic Dispatch of Electric Resources, Utility Owned Generation Fuel Procurement, and Other Activities for the Record Period January 1 Through December 31, 2022 (Application) pursuant to Rule 13.12 of the Rules of Practice and Procedure of the California Public Utilities Commission and the Administrative Law Judge’s (ALJ) September 3, 2024 Ruling Setting the Proceeding Schedule.2 ERRA Compliance proceedings involve a backward-looking review of the investor-owned 1 California Community Choice Association represents the interests of 24 community choice electricity providers in California: Apple Valley Choice Energy, Ava Community Energy, Central Coast Community Energy, Clean Energy Alliance, Clean Power Alliance of Southern California, CleanPowerSF, Desert 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 Administrative Law Judge’s Ruling Setting the Proceeding Schedule (Sept. 3, 2024), available at:
https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M539/K203/539203270.PDF.
CalCCA’s Opening Brief 2
utility’s (IOU) activities and accounting entries. In particular, these proceedings require the Commission to scrutinize the IOU’s activities and entries during the record year and determine whether the IOU met its burden and complied with applicable Commission decisions. The instant proceeding involves an examination of PG&E’s 2022 activities and entries. Those activities include PG&E’s System Resource Adequacy (RA) sales, its attempts to sell RA, and its failure to timely sell excess RA to other LSEs during the summer of 2022—resulting in PG&E counting nearly a gigawatt of excess RA towards its own incremental system reliability procurement targets during the summer of 2022. The Commission has not examined, and will not examine, those specific activities or their associated impacts on PG&E’s accounting entries in any other proceeding.
CalCCA scrutinized PG&E’s efforts to sell excess RA during 2022 because PG&E’s efforts bear directly on the Power Charge Indifference Adjustment (PCIA) rates that both community choice aggregator (CCA) customers and bundled customers pay. RA sales proceeds are credited to all PCIA ratepayers. If PG&E makes inadequate efforts to sell RA, both CCA customers (customers of CalCCA’s members) and bundled customers pay higher PCIA rates than they should pay, because PG&E would credit the PCIA with a lower quantity of sold RA.
Moreover, PG&E’s RA sales activities impact all LSEs (including CCAs), who must procure RA to meet their own RA program obligations. That is why examining PG&E’s efforts to sell RA is a key part of the ERRA review of PG&E’s portfolio management. .
3 Consistent with Appendix S,
3 CalCCA-03C at 12-13.
CalCCA’s Opening Brief 3
Yet, PG&E ultimately identified—and counted towards its incremental system reliability procurement targets—nearly a gigawatt (923 MW) of excess RA capacity during the summer of 2022.7 While Decisions 21-03-056 and 21-12-015 (Summer Reliability decisions) permit PG&E to count excess RA capacity towards system reliability incremental procurement targets by transferring that capacity from the Portfolio Allocation Balancing Account (PABA) to the Cost Allocation Mechanism (CAM), PG&E may only do so after making “reasonable attempts” to sell that capacity to other LSEs.
PG&E’s RA sales activities during the 2022 record period raise two distinct but related concerns. First, PG&E has not adequately explained the glaring disconnect between and the hundreds of megawatts of
RA capacity it identified mere months later. Second, the record demonstrates PG&E did not make reasonable attempts to sell its excess RA capacity to other LSEs using after identifying that capacity and before transferring that capacity to CAM.
In light of those failures, the Commission should not find that PG&E prudently managed its utility-owned generation (UOG) facilities (PG&E’s requested finding 1). Further, because 4 PG&E Prepared Testimony at 8-7.
5 CalCCA-04C, PG&E confidential response to CalCCA Data Request 3.31a. 6 Id., PG&E confidential response to CalCCA Data Request 3.31b, c. 7 PG&E Prepared Testimony at 12-15.
CalCCA’s Opening Brief 4
PG&E’s transfer of capacity from PABA to CAM impacts PG&E’s entries recorded to the PABA, the Commission should not find that PG&E’s entries recorded to the PABA are reasonable, appropriate, accurate and in compliance with Commission decisions (PG&E’s requested finding 3). In addition, the Commission should scrutinize PG&E’s assumptions about resource availability and the adjustments PG&E makes to its RA position in future proceedings to ensure any reductions to the excess RA capacity PG&E makes available to the market are justified. Finally, the Commission should revisit PG&E’s BPP in the Integrated Resource Plan (IRP) proceeding to ensure PG&E is making its excess RA available to the market in a timely and comprehensive manner, including through solicitations and market offers outside the scheduled solicitation process.
I. BACKGROUND
A. PG&E’s Efforts to Sell Excess RA Directly Impact PCIA Rates CCA customers receive generation services from their local CCA and receive transmission, distribution, billing, and other services from PG&E. That means CCA customers in PG&E’s service territory pay the same electric distribution, transmission and non-bypassable rates as PG&E’s bundled customers. However, CCA customers pay CCA-specific generation rates, which vary and are partially influenced by local mandates to increase electric vehicle use, procure and maintain clean electricity portfolios that in many cases exceed state requirements for renewable generation, and achieve other local goals.8
CCA and other unbundled customers are also subject to several non-bypassable charges (NBC), including the PCIA and the CAM. The Commission adopted the PCIA to ensure that when IOU customers depart from bundled service and receive their electricity from a non-IOU provider, 8 CalCCA Protest at 4.
CalCCA’s Opening Brief 5
such as a CCA, “those customers remain responsible for costs previously incurred on their behalf by the IOUs—but only those costs.”9
The structure of the PCIA has evolved over the years. Prior to 2018, the PCIA rate was set only based on forecasts and not trued-up for unbundled customers—only bundled customers’ generation rates were subject to a true-up (via the ERRA). Decision 18-10-019 transformed that ratemaking framework.10 That decision requires that PG&E true-up its forecasted costs (net of forecasted market revenues or imputed revenues) approved in its ERRA Forecast case with the actual recorded costs (net of actual market revenues or imputed revenues) for PCIA-eligible resources during the same year.11 It also requires PG&E to true up the revenues it forecasted it would receive from both bundled and departing load customers over the course of the record year with the actual revenues it received.12 This true-up occurs by comparing the forecasted costs and revenues to the recorded costs and revenues within the PABA on a rolling basis (whereas the true-up of costs to meet bundled customers’ energy and ancillary service requirements occurs in the ERRA).13 The ultimate result of the “rolling true-up”—in both ERRA and PABA—is PG&E recording either an under- or over-collection based on many factors tied to actual market costs, actual market revenues, and actual customer revenues from retail sales.14 That resulting under- or over-collection is then included in the revenue requirement for the following year’s ERRA and PCIA rates (for example, customers in 2023 paid the under- and over-collections that PG&E 9 Decision (D.) 18-10-019 at 3.
10 PGE-01 at 12-1:15-18.
11 D.18-10-019, Ordering Paragraphs 7 and 8.
12 Id.
13 Id. at Ordering Paragraphs 6, 7 and 8.
14 See, e.g. PGE-01 at 12-25, Table 12-7 (comparing 2022 actual recorded PABA portfolio costs compared to approved forecast)
CalCCA’s Opening Brief 6
recorded over the course of 2022).
Following D.18-10-019, therefore, PG&E’s PCIA rates set in the ERRA Forecast proceeding are based not only on the Indifference Amount (the difference in the forecast year between the cost of the IOU’s supply portfolio and the market value of the IOU’s supply portfolio),15 but also the year-end balance in the PABA (the rolling true-up component of PCIA rates).16 The Indifference Amount and the year-end PABA over- or under-collection are added together to form the PABA revenue requirement underlying PCIA rates. The Commission initially determined the level of the 2022 PCIA for PG&E customers in D.22-02-002 based on a forecast of the above-market costs stemming from PG&E’s generation portfolio over the course of 2022 and the 2021 year-end balance in the PABA. Similarly, the Commission initially determined the level of the 2023 PCIA in D.22-12-044 based on a forecast of the above-market costs over the course of 2023 and the 2022 year-end balance in the PABA. PG&E’s entries to the PABA during 2022—which are a focus of this proceeding—therefore directly impact the PCIA rates CCA customers (and bundled customers) pay.17
Among the several important factors that impact PG&E’s rolling true-up in the PABA is PG&E’s sales of excess RA capacity. PG&E sells its excess RA to other LSEs that must also meet RA compliance obligations, just as other IOUs do. The amount of RA capacity PG&E sold to other LSEs during the record period, compared to the amount of RA PG&E forecasted it would sell, drives either an over- or under-collection in the PABA. That is because revenues from PG&E’s sales of excess RA are an important offset to the costs recorded to the PABA during the record 15 D.19-10-001 at 10.
16 Id. at Conclusion of Law 21.
17 CalCCA-01C at 1:11-12.
CalCCA’s Opening Brief 7
year, which are recovered from bundled and unbundled customers. Excess RA that is not sold to third parties is classified as Unsold RA and valued at $0 in the PABA,18 thereby providing no financial benefit to customers. PG&E’s treatment of its excess RA capacity, therefore, directly impacts the PCIA rates CCA customers (and bundled customers) pay. To put a finer point on that dynamic: if PG&E makes inadequate efforts to sell its excess RA, that failure can result in bundled and unbundled customers paying higher PCIA rates than they should be paying. That is why examining PG&E’s efforts to sell RA is a key part of the ERRA review of PG&E’s portfolio management.
B. PG&E Counted Nearly a Gigawatt of Excess RA Capacity Towards its Incremental Procurement Targets During the Summer of 2022 During the summer of 2022, PG&E counted nearly a gigawatt of excess RA capacity— capacity in excess of its bundled customers’ needs—towards its own incremental procurement requirement, after .
19 Because
PG&E recovers the costs of system reliability incremental procurement through the CAM, PG&E must transfer the value of excess RA capacity provided by existing RA resources from the applicable balancing account to the CAM balancing account (for PG&E, the New System Generation Balancing Account or NSGBA).20 PG&E counted 923 MW of excess RA capacity from PCIA-eligible resources towards its incremental procurement targets during the months of June through October of 2022, and accordingly credited PABA and charged NSGBA for the value of that RA.21 PG&E valued that transfer at the Forecasted 2022 System RA Adder for June through 18 D.19-10-001 at Ordering Paragraph 3.e.
19 PGE-01 at 12-15.
20 CalCCA-01C at 3:23-4:1.
21 Id. at 4:2-4.
CalCCA’s Opening Brief 8
September, and subsequently trued-up those entries through October and made an adjustment to account for the publishing of the Final System RA Adder.22 All told, PG&E transferred from PABA to NSGBA over the five months. The table below details that transfer by month:
Table 1: System RA Transfer from PABA to NSGBA23
The central question in this case, therefore, is whether PG&E made reasonable attempts to sell nearly a gigawatt of excess RA capacity to other LSEs during the summer of 2022 before counting that capacity towards its own incremental procurement targets. CalCCA does not dispute the Commission’s Summer Reliability decisions authorize PG&E to use its excess RA capacity towards its incremental procurement obligations. Nor does CalCCA dispute the accuracy of PG&E’s accounting entries to PABA or NSGBA for the RA resources it counted. The Commission’s Summer Reliability decisions, however, allow PG&E to count its existing RA resources towards its system reliability incremental procurement targets only after PG&E makes reasonable attempts to sell its excess RA capacity to other LSEs.24 As this brief discusses below, 22 Id. at 4:5-8.
23 Id. at 4:10-11.
24 R.20-11-003, Order Instituting Rulemaking to Establish Policies, Processes and Rules to Ensure Reliable Electric Service in California in the Event of an Extreme Weather Event in 2021, Phase 2 Decision Directing Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas and Electric Company to take Actions to Prepare for Potential Extreme Weather in the Summers of 2022 and 2023, D.21-12-015 at 183-184 (permitting PG&E to count excess resources in its existing portfolios toward its incremental system reliability procurement targets “provided it has made reasonable attempts to sell this excess capacity to other LSEs”). According to the Summer Reliability decisions, if PG&E has not met its procurement target for June and October, it may “use excess resources in its existing portfolio to meet the minimum contingency targets . . . provided it has made reasonable attempts to sell this excess capacity to other LSEs.” D.21-12-015, Phase 2 Decision Directing Pacific Gas and Electric Company, 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
-
-
CalCCA’s Opening Brief 9
PG&E did not make reasonable attempts to sell its excess RA capacity during the record period.
II. BURDEN OF PROOF AND LEGAL STANDARD
Public Utilities Code Section 451 establishes the foundational standard of review with respect to utility ratesetting:
All charges demanded or received by any public utility, or by any two or more public utilities, for any product or commodity furnished or to be furnished or any service rendered or to be rendered shall be just and reasonable. Every unjust or unreasonable charge demanded or received for such product or commodity or service is unlawful.25 The Commission has also adopted specific standards of review for various aspects of the ERRA Compliance application. PG&E incorporates those standards into the findings it requests in its Application, which include:26
1. That PG&E prudently administered and managed its utility-owned generation (UOG) facilities in compliance with all applicable rules, regulations and Commission decisions, and;
[. . . ]
3. That the entries PG&E recorded in the Energy Resource Recovery Account (ERRA) and Southern California Edison Company and San Diego Gas & Electric Company To Take Actions To Prepare For Potential Extreme Weather In The Summers of 2022 and 2023, Ordering Paragraph 72 (Dec. 6, 2021) (emphasis added); see also D.21-03-056, Decision Directing Pacific Gas and Electric Company, Southern California Edison Company and San Diego Gas & Electric Company To Take Actions to Prepare for Potential Extreme Weather In the Summers of 2021 and 2022, at Ordering Paragraph 79 (Mar. 26, 2021).
Additionally, for the months of July, August, and September, PG&E may use its excess resources “to meet or supplement these procurement targets up to the upper end of its contingency procurement target . . . provided it has made reasonable attempts to sell this excess capacity to other LSEs.” D.21-12-015, Phase 2 Decision Directing Pacific Gas and Electric Company, Southern California Edison Company and San Diego Gas & Electric Company To Take Actions To Prepare For Potential Extreme Weather In The Summers of 2022 and 2023, Ordering Paragraph 73 (Dec. 6, 2021) (emphasis added); see also D.21-03- 056, Decision Directing Pacific Gas and Electric Company, Southern California Edison Company and San Diego Gas & Electric Company To Take Actions to Prepare for Potential Extreme Weather In the Summers of 2021 and 2022, at Ordering Paragraph 80 (Mar. 26, 2021). 25 Cal. Pub. Util. Code § 451.
26 Application at 20.
the Portfolio Allocation Balancing Account (P ABA) are reasonable, appropriate, accurate and in compliance with Commission decisions.
PG&E bears the burden of proof in ERRA Compliance proceedings as the applicant. 27 That burden of proof includes a burden of production, which in ERRA Compliance proceedings is a "preponderance of the evidence. " 28 In this case, PG&E has not met its burden of proof with respect to requested findings 1 and 3. In pa1ticular, PG&E has not adequately explained why its RA position shifted by several hundred megawatts between the time it prepared that position in advance of its scheduled solicitations and the time it applied excess RA towards its incremental procurement targets. Nor has PG&E demonstrated it made reasonable attempts to sell its excess RA to other LSEs prior to counting excess RA towards its incremental procurement targets. As a result, PG&E has not shown by a preponderance of the evidence that it pmdently administered and managed its RA po1tfolio, nor that its entries recorded in the PABA-which reflect PG&E's RA sales-are reasonable.
III. ARGUMENT
A.
yet counted nearly a gigawatt of excess RA towards
its procurement targets.
Per the requirements of Appendix S to PG&E's BPP, PG&E rnns scheduled solicitations to sell RA products from its UOG po1t folio. PG&E issued six solicitations offering to sell System RA for delive1y during 2022.
29 PG&E held two year-ahead solicitations in August 2021 and October 2021, in which PG&E projected out the available RA for the full twelve months of2022. 30 27
28 29
30 D.16-04-006 at 11.
D.12-11-051 at 9; D.09-03-025 at 8.
CalCCA-01 at 7:15-16.
Id. at 7:16-18.
CalCCA's Opening Brief 10
PG&E also held fom quaiierly solicitations in November 2021, Januaiy 2022, April 2022, and July 2022, projecting the available RA for the remaining months of 2022 updated on a quaiierly basis.31
PG&E's BPP Appendix S explains that
-
PG&E creates a projected RA position (a calculation of its available system RA capacity) at the time it holds each solicitation in order to detennine the quantity of RA available for sale at that point in time.35 Table 2 below summai·izes PG&E's System RA position for the months of June through October 2022 as calculated at the time of each applicable solicitation. 31 Id. at 7:18-20.
Section B. l.b.(l).(a) of Appendix S to PG&E's BPP, describing- ).
33 34
35 CalCCA-OlC at 5:9-11.
Id. at 5:11-13.
Id. at 5: 14-15 (citing PG&E's response to Joint CCA Master Data Request 1.08).
CalCCA's Opening Brief 11
Table 2: Summer System RA Position (MW)36
RA Position Date
8/23/2021 System RA Posit ion
10/6/2021 System RA Posit ion
11/22/2021 System RA Posit ion
1/ 14/2022 System RA Posit ion
4/11/2022 System RA Posit ion
7/18/2022 System RA Posit ion
Consistent with PG&E's BPP Appendix S,
39 Table 3, below, summarizes the System
RA PG&E offered for sale in each solicitation with delive1y periods from June through October 2022 based on PG&E's projected System RA positions prepared at the time of each solicitation. 40 36 Id. at 6:1-2.
37 Id. at 6:3-5.
38 Id. at 6:5-6.
39 Id. at 8:9-11.
40 Id. at 8:7-9 (citing PG&E's response to Joint CCA Master Data Request 1.08 Attachment 2 and CalCCA data request 2.57).
CalCCA's Opening Brief 12
CalCCA’s Opening Brief 13
Table 3: Summer System RA Volumes Offered for Sale by Solicitation (MW)41 PG&E’s offers to sell excess RA between July and October of 2022 stand in stark contrast with the near gigawatt of excess RA it counted towards its incremental procurement targets during the same time period. When asked to provide documentation demonstrating whether it received any offers from other LSEs to purchase any portion of the 923 MW of excess RA, PG&E 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.”42
Reviewing data from PG&E’s RA solicitations tells a more complete story, however. Table 4 below details for each RA solicitation the bids submitted by third parties seeking to purchase System RA, but which PG&E rejected
Table 4 summarizes the number
of bids rejected
As Table 4 demonstrates,
.
43 41 Id. at 8:12-13.
42 See id., Attachment B (PG&E’s response to CalCCA data request 2.55 (emphasis added)). 43 See id., Attachment B (PG&E’s response to CalCCA data requests 2.21, 2.23, and 2.54 Supplemental).
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
-
CalCCA’s Opening Brief 14
Table 4: Bids Rejected
Collectively, Tables 3 and 4 demonstrate
Yet, as Table 1 above illustrates, only a short time later, PG&E counted 923 MW of excess RA capacity from PCIA-eligible resources towards its incremental procurement targets.44 This raises two concerns. First, PG&E has not explained why its RA position changed so dramatically in a matter of months. Second, given that PGE&’s RA solicitations came before PG&E identified excess RA during the summer of 2022, PG&E has not demonstrated that it made reasonable, timely attempts to sell its excess RA capacity to other LSEs after that excess RA was known to be available.
B. The Commission Should Scrutinize the Adjustments PG&E Makes to its RA Position to Ensure Any Reductions to the Capacity PG&E Makes Available to the Market are Justified
As described earlier, PG&E determines its System RA position ahead of each solicitation by
44 Id. at 4:2-4.
# 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 CalCCA’s Opening Brief 15
45 Table 5 below details each of those line items as calculated by PG&E in its RA position reports for the summer 2022 delivery period. Table 5 also shows the change from the previous RA position for each component of the reports. 45 See CalCCA-03-C, PG&E’s Bundled Procurement Plan Appendix S Section B.3.b.1.a.
CalCCA’s Opening Brief 16
Table 5: RA Position Reports Detail46
As Table 5 demonstrates, several line items that constitute PG&E's RA Position changed significantly each time PG&E calculated that position. One potential explanation for PG&E identifying significant excess RA (after projecting ahead of its solicitations) is that certain line items in PG&E's RA position are impacted by resource availability and other adjustments to available capacity. To the extent PG&E has discretion with regard to its assumptions of resource availability, outage schedules, or operational constraints, it is likely to make conservative assumptions to ensure resources are used to meet PG&E's own compliance obligations rather than making those resources available to the market.47 In response to CalCCA discove1y on this issue, PG&E first dismissed CalCCA's concern by asse1iing that its bundled RA position "changed due to a variety of conditions."48 In response to follow up discove1y , PG&E offered
. That is a
problem because, again, PG&E has an incentive to make conservative assumptions that ensure resources are available to meet PG&E's own compliance obligations (rather than making those resources available to other LSEs). To mitigate this risk, the Commission should scmtinize the adjustments PG&E makes to its RA position in future ERRA Compliance proceedings to ensure any reductions to the capacity PG&E makes available to the market through scheduled solicitations 46 47
48 49
CalCCA-OlC at 16.
Id. at 17:15-19.
CalCCA-04C, PG&E response to CalCCA data request 3.27.
Id., PG&E response to CalCCA data request 6.03.
CalCCA's Opening Brief 17
CalCCA’s Opening Brief 18
are justified. Moreover, the Commission should expressly permit parties to examine the assumptions underlying PG&E’s RA positions in future ERRA Compliance proceedings.
C. PG&E Did Not Make Reasonable Attempts To Sell Its Excess RA During The Summer of 2022 After It Was Known to be Available.
In addition to scrutinizing the swings in PG&E’s RA position, the Commission should examine PG&E’s attempts to sell excess RA once PG&E identified that excess. PG&E states it identified the final quantity of excess RA capacity shown towards meeting Summer Reliability procurement targets between T-50 and T-30 days prior to each compliance month.50 That means PG&E did not identify the final quantity of excess RA capacity counted towards meeting incremental procurement targets for July, August, and September 2022 until after its Q3 Balance of Year Solicitation (for which PG&E prepared an RA Position on April 11, 2022). Similarly, that timeline means PG&E did not identify the final quantity of excess RA capacity counted towards PG&E’s incremental procurement target for October 2022 until after the Q4 Balance of Year Solicitation (for which PG&E prepared an RA position on July 18, 2022). 51 In fact, in 2022,
.
52 Yet,
50 Id., PG&E response to CalCCA data request 3.26, 3.33. 51 Id., PG&E response to CalCCA data request 7.01; CalCCA-03C at 13. 52 Id., PG&E response to CalCCA data request 7.02, 7.03. -
In fact, _
[nstead, PG&E counted
hundreds of megawatts towards its own system reliability incremental procurement targets- - Far from making "reasonable attempts" to sell the excess RA it identified, therefore, PG&E
-
D. The Commission Should Not Find PG&E Prudently Managed its RA Portfolio and Should Not Find PG&E's PABA Entries are Reasonable Scoping Issue 1 in this proceeding asks "[w]hether PG&E, during the record period, prndently administered and managed the following, in compliance with all applicable rnles, regulations, and Commission decisions, including but not limited to Standard of Conduct (SOC) 4: a) Utility-Owned Generation Facilities, except for the Elkhorn Batte1y Energy Storage System and Pit 1 Powerhouse outages which will be reviewed in the 2023 ERRA Compliance proceeding; b) Qualifying Facilities (QF) Contracts; and c) Non-QF Contracts. If not what adjustments, if any, should be made to account for imprndently managed or administered resources?"55 At a high level, Scoping Issue 1 requires the Commission to evaluate whether PG&E prndently administered and managed its generation portfolio (UOG and contracted resources) in ss Assigned Commissioner's Scoping Memo and Ruling at 2.
CalCCA's Opening Brief 19
CalCCA’s Opening Brief 20
2022. As a part of that broad evaluation, the Commission must assess whether PG&E administered and managed its RA resources prudently. That prudence assessment, in turn, includes assessing whether PG&E made reasonable efforts to ensure it received value for all its RA resources, a key consideration in determining whether PG&E has prudently managed is generation portfolio.
The Commission applies several standards to assess the prudence of PG&E’s management and administration of its generation portfolio, including SOC 4, the Commission’s Good Utility Practice standard and the “reasonable manager” standard.56 SOC 4 requires utilities to prudently administer all contracts and generation resources and dispatch the energy in a least-cost manner.57 The Commission has stated that prudent contract administration consistent with SOC 4 requires the utility “dispose of economic long power”—in other words, sell excess resources—among other activities.58 In a similar vein, the “Good Utility Practice” standard requires utilities act consistent with:
“[A]ny of the practices, methods and acts engaged in or approved by a significant portion of the electric utility industry during the relevant time period, or any of the practices, methods and acts which, in the exercise of reasonable judgment in light of the facts known at the time the decision was made, could have been expected to accomplish the desired result at a reasonable cost consistent with good business practices, reliability, safety and expedition.”59 Lastly, the broad “reasonable manager” standard requires utilities act in a manner that “comport[s] with what a reasonable manager of sufficient education, training, experience and skills using the tools and knowledge at his disposal would do when faced with a need to make a decision and 56 See e.g. D.20-12-036 at 9 (in SDG&E’s 2018 ERRA Compliance proceeding, finding SDG&E complied with the Good Utility Practice and reasonable manager standards). 57 D.02-10-062 at Conclusion of Law 11.
58 D.02-12-074 at 54; see also D.05-04-036 at 24.
59 D.02-12-069, Attachment A at 5.
CalCCA’s Opening Brief 21
act.”60 Each of these standards permit the Commission to review whether the utility maximized the value of its RA resources for the benefit of its customers during the record period.
In the instant proceeding, PG&E has not demonstrated that it maximized the value of its RA resources for the benefit of its customers. PG&E
and then, after identifying hundreds of
megawatts of excess RA just a few months later, before
transferring that capacity to CAM. The Commission should therefore not find that PG&E managed its UOG portfolio prudently. Moreover, given that PG&E’s RA sales directly impact its PABA entries (i.e., sold RA is credited to the PABA), the Commission should not find that PG&E’s PABA entries for the 2022 record period are reasonable.
E. The Commission Should Revisit PG&E’s BPP in the IRP Docket The record demonstrates PG&E’s RA position can fluctuate rapidly and significantly. It also demonstrates PG&E’s scheduled solicitations may not be a sufficiently flexible or robust means—standing alone—for ensuring that PG&E makes excess RA capacity available to the market in both a timely and comprehensive manner. While the Commission must review PG&E’s 2022 RA activities in this proceeding and should scrutinize PG&E’s RA positions and activities in future ERRA Compliance proceedings, the Commission should revisit PG&E’s BPP in the IRP proceeding to ensure that Appendix S delivers that outcome.
The Commission can, in this proceeding, order that PG&E’s BPP be revisited in the IRP docket.61 The IRP docket, as the successor to the Long-Term Procurement Plan dockets that gave rise to the most recent, full BPPs, is the appropriate place to evaluate BPP revisions. Specifically, 60 D.90-09-088 at 499.
61 California PUC Docket No. R.20-05-003.
CalCCA’s Opening Brief 22
the initial Order Instituting Rulemaking (OIR) issued in the current IRP docket stated explicitly that the IRP docket was the correct venue for BPP revisions.62 This notion was reaffirmed by the Preliminary Scoping Memo included in the OIR.63 Further, the Amended Scoping Memo, which currently controls the IRP docket, states that the IRP docket is anchored by, among other things, “[c]onsideration of the need for procurement by LSEs of electricity resources,” and that the current scope includes issues related to “[e]stablishing a process and cadence for performing reliability analysis and setting reliability planning and procurement requirements for LSEs . . . involv[ing] coordination with resource adequacy requirements[.]”64 This Commission has reinforced this conclusion in other proceedings, suggesting that BPP procurement rules have not yet been addressed in the IRP docket.65
Finally, the IRP docket provides a forum in which parties may workshop best practices for BPP provisions governing excess RA solicitations and market offers. While the Commission’s model non-disclosure agreement prevents discussion of the specifics of the confidential components of other IOUs’ BPPs in individual ERRA Compliance proceedings, the IRP docket is a consolidated proceeding in which parties may execute non-disclosure agreements that allow for the evaluation of each IOUs’ BPP in the same place. Accordingly, parties and the Commission can determine if other IOUs’ existing practices might complement PG&E’s practices and help ensure 62 R.20-05-003, Order Instituting Rulemaking at 2 (May 14, 2020). 63 Id. at 10.
64 R.20-05-003, Assigned Commissioner’s Amended Scoping Memo and Ruling Extending Statutory Deadline at 2, 9 (Apr. 18, 2024).
65 D.23-12-008 at 23 (stating “BPPs were reviewed and adopted every two years via a Commission decision in the Long-Term Procurement Plan (LTPP) proceeding. Although the IOUs' current BPPs were last approved, with modifications, by D.15-10-031 on October 22, 2015, in R.13-12-010, the IOUs have not filed a full update of their BPPs since then. Instead, the IOUs have updated various sections of their BPPs via advice letters as needed over the years. The IRP proceeding is the successor proceeding to the LTPP proceeding, however, a complete review of the IOU BPPs and changes to BPP procurement rules has yet to be addressed.” (emphasis added)).
CalCCA’s Opening Brief 23
PG&E makes excess RA available to other LSEs in an appropriate manner.
IV. CONCLUSION
For the reasons described in this brief, CalCCA respectfully urges the Commission to take the actions discussed herein and to grant any other relief the Commission deems just and reasonable.
Respectfully submitted,
Nikhil Vijaykar
KEYES & FOX LLP
580 California Street, 12th Floor
San Francisco, CA 94104
Telephone: (408) 621-3256
E-mail: [email protected]
Counsel to
CALIFORNIA COMMUNITY CHOICE
ASSOCIATION
Dated: October 4, 2024
FILED
10/11/24
04:59 PM
A2302018
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Application of Pacific Gas and Electric Company
for Compliance Review of Utility Owned
Generation Operations, Portfolio Allocation
Balancing Account Entries, Energy Resow-ce
Recovery Account Entries, Contract Administration,
Economic Dispatch of Electric Resources, Utility
Owned Generation Fuel Procurement, and Other
Activities for the Record Period January l through
December 31, 2022
U39E
Application 23-02-018
CALIFORNIA COMMUNITY CHOICE ASSOCIATION'S
REPLY BRIEF
PUBLIC VERSION
Leanne Bober
Director of Regulatory Affairs and Deputy
General Counsel
CALIFORNIA COMMUNITY CHOICE
ASSOCIATION
1121 L Street, Suite 400
Sacramento, CA 95814
Telephone (415) 302-2376
E-mail: [email protected]
Dated: October 11 , 2024
Nikhil Vijaykar
Tim Lindi
KEYES & FOX LLP
580 Californ ia Street, 12th Floor
San Francisco, CA 94104
Telephone: (408) 621 -3256
E-mail: [email protected]
[email protected]
Counsel to
CALIFORNIA COMMUNITY CHOICE
ASSOCIATION
SUBJECT MATTER INDEX
I. ARGUMENT ........................................................................................................................... 3 A. PG&E Has Not Demonstrated That It Prudently Administered Its Generation Portfolio During the Record Period ............................................................................................................ 3 B. The Commission Should Revisit PG&E's BPP in the IRP Proceeding .............................. 5 II. CONCLUSION ....................................................................................................................... 6 CalCCA's Reply Brief
TABLE OF AUTHORITIES
Commission Decisions
D.02-10-062 ..................................................................................................................................... 4 D.02-12-069 ..................................................................................................................................... 4 D.02-12-074 ..................................................................................................................................... 4 D.20-12-036 ..................................................................................................................................... 4 D.90-09-088 ..................................................................................................................................... 4 Rules of Practice and Procedure
Rule 13.12 ........................................................................................................................................ l CalCCA's Reply Brief II
SUMMARY OF RECOMMENDATIONS
• The California Public Utilities Commission (Commission) should adopt the recommendations CalCCA makes in its opening brief.
CalCCA's Reply Brief 111
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Application of Pacific Gas and Electric Company for
Compliance Review of Utility Owned Generation
Operations, Portfolio Allocation Balancing Account
Entries, Energy Resource Recovery Account Entries,
Contract Administration, Economic Dispatch of
Electric Resources, Utility Owned Generation Fuel
Procurement, and Other Activities for the Record
Period January l through December 31, 2022
U39E
Application 23-02-018
CALIFORNIA COMMUNITY CHOICE ASSOCIATION'S
REPLY BRIEF
The California Community Choice Association' (CalCCA) submits this Reply Brief regarding the Application of Pacific Gas and Electric Company (U 39 E) for Compliance Review of Utility Owned Generation Operations, Portfolio Allocation Balancing Account Entries, Energy Resource Recovery Account Entries, Contract Administration, Economic Dispatch of Electric Resources, Utility Owned Generation Fuel Procurement, and Other Activities for the Record Period January 1 Through December 31, 2022 (Application) pursuant to Rule 13.12 of the Rules of Practice and Procedure of the California Public Utilities Commission and the Administrative Law Judge's (ALJ) September 3, 2024 Ruling Setting the Proceeding Schedule. 2 Pacific Gas & Electric Company's (PG&E) opening brief ski1ts the central question in this California Community Choice Association represents the interests of 24 community choice electricity providers in California: Apple Valley Choice Energy, Ava Community Energy, Central Coast Community Energy, Clean Energy Alliance, Clean Power Alliance of Southern California, CleanPowerSF, Desert 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 Jose Clean Energy, Santa Barbara Clean Energy, Silicon Valley Clean Energy, Sonoma Clean Power, and Valley Clean Energy. 2 Administrative Law Judge's Ruling Setting the Proceeding Schedule (Sept. 3, 2024), available at:
https://docs.cpuc.ca.gov/Published.Docs/Efile/G000/M539/K203/539203270.PDF.
CalCCA's Reply Brief
case: Whether PG&E made reasonable attempts to sell its excess Resource Adequacy (RA) to other load-serving entities (LSE) during the summer of 2022 before counting that capacity towards its own incremental procurement targets. PG&E's failure to address that question is concerning because, as its testimony (but not its opening brief) acknowledges, PG&E counted nearly a gigawatt of excess RA towards its own incremental procurement targets rather than selling that capacity to other LSEs during the record period.
3 Moreover, PG&E did so after
4 CalCCA expects PG&E will, in its reply brief, argue its 2022 RA sales solicitations comply with its Bundled Procurement Plan (BPP)- a point CalCCA does not challenge. But that defense should not end the Commission's inquiry .
.
5 As CalCCA's testimony and exhibits demonstrate,
PG&E did not make reasonable attempts to sell its excess RA capacity to other LSEs - after identifying that capacity
and before counting that capacity towards its incremental procurement targets.
While PG&E's opening brief does not meaningfully engage with the central question in this case, CalCCA's opening brief thoroughly addresses PG&E's 2022 RA sales activities. This brief does not repeat those arguments, but makes the following two points.
First, CalCCA responds to PG&E's discussion of Scoping Issue 1. PG&E asse1ts it prudently administered its utility-owned generation (UOG) facilities and dismisses CalCCA's evidence on PG&E's RA sales as "the subject of Scoping Issue 5." 6 PG&E takes an unduly narrow view of Scoping Issue 1. The legal standards applicable to Scoping Issue 1 permit the Commission 3 4
5 6
PG&E-01 at 12-15.
CalCCA-04C, PG&E confidential response to CalCCA Data Request 3.31a.
CalCCA Opening Brief at 18.
PG&E Opening Brief at 7.
CalCCA's Reply Brief 2
to review whether the utility maximized the value of its generation portfolio- including its RA resources- for the benefit of its customers during the record period. The record demonstrates PG&E did not maximize the value of its RA resources for the benefit of its customers, and therefore, the Commission should not find that PG&E prudently managed its UOG facilities during the record period.
Second, PG&E's opening brief demonstrates why the Commission must revisit PG&E's BPP in the Integrated Resource Plan (IRP) proceeding. Again, PG&E asserts it complied with Appendix S of its BPP7 but does not explain why it nevertheless ended up with nearly a gigawatt of excess RA at a time when the RA market was constrained. The IRP proceeding is the right forum for the Commission to consider best practices in RA sales, compare practices across utilities, and ensure PG&E makes its excess RA available to LSEs in an appropriate manner going forward.
I. ARGUMENT
A. PG&E Has Not Demonstrated That It Prudently Administered Its Generation Portfolio During the Record Period
PG&E asse1ts it prudently administered its UOG facilities and generation contracts, and CalCCA's testimony "does not present any evidence to the contrary."8 Not so. CalCCA's testimony and exhibits demonstrate PG&E did not make reasonable attempts to sell excess RA to other LSEs after identifying that excess and before counting it towards PG&E's system reliability incremental procurement targets during the summer of 2022. 9 The fundamental flaw affecting PG&E's argument with respect to Scoping Issue 1 is that PG&E recites, but glosses over, the relevant legal standards. The Commission applies several standards to assess the prudence of PG&E's management and administration of its generation 7 8
9 Id. at 9-10.
id.at 7.
See CalCCA Opening Brief at 10-19.
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po1tfolio, including Standard of Conduct (SOC) 4, the Commission's Good Utility Practice standard and the "reasonable manager" standard.
10 SOC 4 requires utilities to prudently administer
all conh·acts and generation resources and dispatch the energy in a least-cost manner. 11 The Commission has stated that prudent contract administration consistent with SOC 4 requires the utility "dispose of economic long power"- in other words, sell excess resources- among other activities.
12 In a similar vein, the "Good Utility Practice" standard requires utilities act consistent with:
"[ A ]ny of the practices, methods and acts engaged in or approved by a significant portion of the electric utility industry during the relevant time period, or any of the practices, methods and acts which, in the exercise of reasonable judgment in light of the facts known at the time the decision was made, could have been expected to accomplish the desired result at a reasonable cost consistent with good business practices, reliability, safety and expedition."13 Lastly, the broad "reasonable manager" standard requires utilities act in a manner that "comport[s] with what a reasonable manager of sufficient education, training, experience and skills using the tools and knowledge at his disposal would do when faced with a need to make a decision and act."14 Each of these standards permit the Commission to review whether the utility maximized the value of its generation portfolio- which includes its RA resources- for the benefit of its customers during the record period.
Thus, CalCCA's testimony and exhibits concerning PG&E's RA sales activities are squarely within and concern Scoping Issue 1. PG&E has not met its burden of proof with respect to Scoping Issue 1 because the record demonstrates PG&E See, e.g. A.19-05-007, D.20-12-036 at 9 (in SDG&E's 2018 ERRA Compliance proceeding, finding SDG&E complied with the Good Utility Practice and reasonable manager standards). 11 D.02-10-062, Conclusion of Law 11 (Oct. 24, 2002). 12 D.02-12-074 at 54 (Dec. 19, 2002); see also D.05-04-036 at 24. 13 D.02-12-069, Attachment A at 5 (Dec. 19, 2002). 14 D.90-09-088 at 499.
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,
15 and then, after identifying
hundreds of megawatts of excess RA just a few months later, before counting that capacity towards its incremental procurement targets. 16 The Commission
should not, therefore, find that PG&E prudently administered its generation portfolio during the record period.
B. The Commission Should Revisit PG&E's BPP in the IRP Proceeding.
With respect to PG&E's scheduled solicitations for the sale of RA with delivery during the summer of 2022, CalCCA does not challenge PG&E's compliance with Appendix S of its BPP.
The problem, however, is that notwithstanding those solicitations, PG&E ended up with nearly a gigawatt of excess RA capacity during the summer of 2022, and did not make reasonable attempts to sell that capacity after identifying it. PG&E's opening brief does not acknowledge or engage with this disconnect, and instead focuses on its compliance with Appendix S of its BPP.
PG&E's "bare minimum" approach is exactly the reason the Commission should revisit PG&E's BPP in the IRP proceeding. As CalCCA explained in its opening brief, the IRP docket provides a forum in which patties may workshop best practices for BPP provisions governing excess RA solicitations and market offers. While the Commission's model non-disclosure agreement prevents discussion of the specifics of the confidential components of other IO Us' BPPs in individual ERRA Compliance proceedings, the IRP docket is a consolidated proceeding in which parties may execute non-disclosure agreements that allow for the evaluation of each IOUs' BPP in the same place. Accordingly, pa1ties and the Commission can determine if other IOUs' existing practices might complement PG&E's practices. This would help ensure PG&E makes 15 CalCCA-0lC at 8:12-13. 16 CalCCA-04C, PG&E response to CalCCA data request 7.05c, 7.05d, 7.06c, 7.06d, 7.07c, 7.07d,
7.08c, 7.08d.
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excess RA available to other LSEs in a proactive and timely manner, rather than simply "ticking the box" on RA sales.
II. CONCLUSION
For the reasons described in its testimony and briefs, CalCCA respectfully urges the Commission to adopt the recommendations listed in CalCCA's opening brief and to grant any other relief the Commission deems just and reasonable.
Dated: October 11, 2024
CalCCA's Reply Brief
Respectfully submitted,
/:::;P-Nikhil Vijaykar
KEYES & FOX LLP
580 California Street, 12th Floor
San Francisco, CA 94104
Telephone: (408) 621-3256
E-mail: [email protected]
Counsel to
CALIFORNIA COMMUNITY CHOICE
ASSOCIATION
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