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  • STATE OF CALIFORNIA Edmund G. Brown Jr., Governor

    PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE

    SAN FRANCISCO, CA 94102-3298

    November 15, 2016

    Advice Letter 3476-E

    Russell G. Worden

    Director, State Regulatory Operations

    Southern California Edison Company

    8631 Rush Street

    Rosemead, CA 91770

    SUBJECT: Publication of SCE's Initial Unit Cost Guide Pursuant to D.16-06-052

    Dear Mr. Worden:

    Advice Letter 3476-E is effective as of September 21, 2016.

    Sincerely,

    Edward Randolph

    Director, Energy Division

  • P.O. Box 800 8631 Rush Street Rosemead, California 91770 (626) 302-4177 Fax (626) 302-4829

    Russell G. Worden Managing Director, State Regulatory Operations

    September 21, 2016

    ADVICE 3476-E (U 338-E)

    PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION

    SUBJECT: Publication of Southern California Edison Companys Initial Unit Cost Guide Pursuant to Decision 16-06-052

    In compliance with the California Public Utilities Commissions (CPUC or Commission) Decision (D.)16-06-052,1 Southern California Edison Company (SCE) hereby submits the initial publication of its Unit Cost Guide relevant to Rule 21. The Unit Cost Guide is included as Attachment A and is attached hereto.

    PURPOSE

    Pursuant to Ordering Paragraphs (OPs) 1 and 10, and Attachments A and D of D.16-06-052, SCE submits the first publication of its Unit Cost Guide relevant to Rule 21.

    BACKGROUND

    On September 22, 2011, the Commission initiated Rulemaking (R.)11-09-011 to review and, if necessary, revise the rules and regulations governing the interconnecting of generation and storage resources to the electric distribution systems of Pacific Gas and Electric Company (PG&E), SCE, and San Diego Gas & Electric Company (SDG&E), collectively the Investor-Owned Utilities (IOUs). The IOUs rules and regulations pertaining to the interconnection of generation are generally set forth in Electric Tariff Rule 21.

    1 D.16-06-052, adopted on June 23, 2016, is entitled Alternate Decision Instituting Cost

    Certainty, Granting Joint Motions to Approve Proposed Revisions to Electric Tariff Rule 21, and Providing Smart Inverter Development a Pathway Forward for Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company.

  • ADVICE 3476-E (U 338-E) - 2 - September 21, 2016

    In compliance with Administrative Law Judge Busheys August 19, 2015 Ruling,2 which sets forth the procedural schedule to work on the issues of: (1) behind-the-meter, non-exporting storage interconnection requests, and (2) interconnection cost certainty, the IOUs, along with interested parties (collectively, the Joint Parties), filed joint motions on November 9, 20153 and November 18, 2015.4 Subsequently, on June 23, 2016, the Commission adopted D.16-06-052 (or the Decision) granting the joint motions filed by the Joint Parties. Specifically, in OP 1 of the Decision, the Commission granted the Joint Parties proposals for a Unit Cost Guide, as further specified in Attachment A.5 Pursuant to OP 10 and the filing and event schedule set forth in Attachment D of the Decision,6 SCE submits the initial publication of its Unit Cost Guide. The Commission authorized that subsequent versions of the Unit Cost Guide do not need to be filed via an advice letter7 but the IOUs need to adhere to the annual stakeholder process described in Attachment A, Section 2.h of the Decision.8

    UNIT COST GUIDE

    The purpose of the Unit Cost Guide is to provide additional cost transparency in support of interconnection provisions included in Rule 21. The Unit Cost Guide is to be published on an annual basis and conform to a set of agreed-upon principles, set forth in Attachment A of the Decision and incorporated into SCEs Rule 21 tariff in Advice 3429-E.9 SCE has collaborated with the other IOUs to ensure a consistent Unit Cost Guide format and participated in a stakeholder call on August 29, 2016 to solicit feedback from stakeholders and the Commissions Energy Division.

    The Unit Cost Guide that SCE publishes today as part of this advice filing complies with the Commissions directions in the Decision.10 The Unit Cost Guide:

    2 Administrative Law Judges Ruling Setting Dates for Filing Final Motions and Granting

    Motions for Party Status. 3 Motion of Southern California Edison Company (U 338-E), San Diego Gas & Electric

    Company (U 90-E), Pacific Gas and Electric Company (U 39-E), California Solar Energy Industries Association, Clean Coalition, CODA Energy, and Interstate Renewable Energy Council, Inc., Proposing Pre-Application Report Enhancements and Development of Unit Cost Guide.

    4 Joint Motion Supporting Revisions to Streamline Rule 21 for Behind-the-Meter, Non-Exporting Storage Devices. Parties that filed with SCE, PG&E, and SDG&E are the Interstate Renewable Energy Council, Inc., Clean Coalition, Robert Bosch, LLC, and Stem, Inc.

    5 D.16-06-052 at p. 47. 6 Ibid., at p. 10. See also Attachment D at pp. 1-2. 7 Ibid., Attachment D at p. 1. 8 Ibid., Attachment A at p. 2. 9 Filed on July 8, 2016 and approved on August 10, 2016:

    https://www.sce.com/NR/sc3/tm2/pdf/3429-E.pdf 10 Decision at p. 7 and Attachment A.

  • ADVICE 3476-E (U 338-E) - 3 - September 21, 2016

    Includes cost information for facilities generally required to interconnect generation to the utilitys Distribution system;

    Reflects a forecasted annual adjustment for five years to provide an estimate for future procurement timing;

    Includes illustrative scenarios reflecting stakeholder input;

    Describes various requirements for interconnection facilities and distribution upgrades; and,

    Provides utility operation and maintenance and recovery cost calculation method calculations, and includes the assumptions used in those calculations.

    Consistent with the Decision, the Unit Cost Guide will not be binding for actual facility costs11 and will not replace any project-specific study costs, but rather, the Cost Guide is intended to be used as a point of reference for projects that are considering the existing study processes.12 Furthermore, per Attachment A of the Decision, the Unit Cost Guide is provided only for additional cost transparency and developer reference availability.

    No cost information is required for this advice filing.

    This advice filing will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule.

    TIER DESIGNATION

    Pursuant to OP 1 and 10 of D.16-06-052, this advice letter is submitted with a Tier 1 designation.

    EFFECTIVE DATE

    This advice filing will become effective on September 21, 2016, which is the same date as filed.

    NOTICE

    Anyone wishing to protest this advice filing may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice filing. Protests should be submitted to:

    11 Ibid. 12 Ibid.

  • ADVICE 3476-E (U 338-E) - 4 - September 21, 2016

    CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov

    Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above).

    In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of:

    Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770

    Telephone (626) 302-4177 Facsimile: (626) 302-4829 E-mail: AdviceTariffManager@sce.com Michael R. Hoover Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: Karyn.Gansecki@sce.com

    There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above.

    In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B and R.11-09-011 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 302-4039. For changes to all other service lists, please contact the Commissions Process Office at (415) 703-2021 or by electronic mail at Process_Office@cpuc.ca.gov.

    Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by filing and keeping the advice filing at SCEs corporate headquarters. To view other SCE advice letters filed with the Commission, log on to SCEs web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters.

  • ADVICE 3476-E (U 338-E) - 5 - September 21, 2016

    For questions, please contact Shiela Linao at (626) 302-4506 or by electronic mail at Shiela.Linao@sce.com

    Southern California Edison Company

    /s/ Russell G. Worden