BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Recover of Costs to Implement Electric Rule 24 Direct Participation Demand Response (U39E). And Related Matters. A (Filed June 2, 2014) A A SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS ON ADMINISTRATIVE LAW JUDGE HYMES PROPOSED DECISION APPROVING RECOVERY OF COSTS TO IMPLEMENT AN INITIAL LEVEL OF DEMAND RESPONSE DIRECT PARTICIPATION JANET S. COMBS ANDREA L. TOZER Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: March 17, 2015 LIMS

2 SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS ON ADMINISTRATIVE LAW JUDGE HYMES PROPOSED DECISION APPROVING RECOVERY OF COSTS TO IMPLEMENT AN INITIAL LEVEL OF DEMAND RESPONSE DIRECT PARTICIPATION TABLE OF CONTENTS Topic Page I. INTRODUCTION AND SUMMARY OF RECOMMENDATIONS...1 II. DISCUSSION...2 A. The Proposed Decision Correctly Concludes that Direct Participation Services Should Follow the Same Cost Causation Principles Adopted in D for Demand Response Programs...2 B. The Proposed Decision Accurately Finds that Rules 24 and 32 Apply to Meter Data Management Services Used in Demand Response Direct Participation...3 C. D. The Proposed Decision Places Appropriate Limitations on Initial Implementation...3 The Commission Should Consider ORA s and TURN s Recommendations for a Different Process to Evaluate Incremental Funding Requests to Support Ancillary and Real-Time Services...4 III. CONCLUSION... ERROR! BOOKMARK NOT DEFINED. i

3 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Recover of Costs to Implement Electric Rule 24 Direct Participation Demand Response (U39E). And Related Matters. A (Filed June 2, 2014) A A SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS ON ADMINISTRATIVE LAW JUDGE HYMES PROPOSED DECISION APPROVING RECOVERY OF COSTS TO IMPLEMENT AN INITIAL LEVEL OF DEMAND RESPONSE DIRECT PARTICIPATION I. INTRODUCTION AND SUMMARY OF RECOMMENDATIONS Pursuant to Rule 14.3(d) of the Rules of Practice and Procedure of the California Public Utilities Commission (Commission or CPUC), Southern California Edison Company (SCE) hereby files its Reply Comments in response to the various parties Opening Comments on Administrative Law Judge (ALJ) Hymes Proposed Decision (PD). 1 SCE appreciates this opportunity to provide reply comments and recommends that the Commission: Reject DACC/AReM s recommendations to modify the PD s cost allocation conclusions and findings; 1 Comments were filed by the California Large Energy Consumer Association (CLECA); the Direct Access Customer Coalition and Alliance for Retail Energy Markets (DACC/AReM); EnergyHub and Alarm.Com (EnergyHub); the Office of Ratepayer Associates (ORA); Pacific Gas and Electric Company (PG&E); San Diego Gas & Electric Company (SDG&E); and the Utility Reform Network (TURN). 1

4 Reject EnergyHub s recommendation to remove enrollment limitations in the early implementation phases; and Consider ORA s and TURN s recommendations for a different process to evaluate the IOUs requirements to support direct participation services for Ancillary Services (AS) and Real-Time (RT) services. II. DISCUSSION A. The Proposed Decision Correctly Concludes that Direct Participation Services Should Follow the Same Cost Causation Principles Adopted in D for Demand Response Programs In its Opening Comments, DACC/AReM argues that demand response (DR) direct participation services are not programs, and thereby the cost causation principles for DR programs adopted in D are not applicable. SCE disagrees. DACC/AReM note that D does not discuss cost causation principles for DR services, however D does adopt a policy that applies to any DR tariff that is available to all customers. 2 Regardless of how the applicability of D is framed, the PD correctly concludes that DR direct participation services are available for use by all customers and therefore the costs associated with those services should be borne by all customers. DACC/AReM also relies on D , which concludes that direct access customers are exempt from direct participation services. 3 However, D did not adopt a prohibition of direct access customers utilizing direct participation services. In fact, D concludes that it is reasonable to require all DR providers to register with the Commission. 4 Thus, all direct access customers are eligible to utilize direct participation services and the 2 D , Ordering Paragraph 8.a. 3 D , Ordering Paragraph 4. 4 D , Conclusion of Law 3, p

5 Commission should reject DACC/AReM s claim that costs of direct participation services should not be allocated to direct access customers. B. The Proposed Decision Accurately Finds that Rules 24 and 32 Apply to Meter Data Management Services Used in Demand Response Direct Participation In its Opening Comments, DACC/AReM emphasize that the IOUs rules for direct participation (Rule 24 for SCE and PG&E; and Rule 32 for SDG&E) include a provision that where the IOU is the Meter Data Management Agent (MDMA), no incremental fees under this rule are required. Metering services shall be provided pursuant to Electric Rule DACC/AReM argue that direct access customers receive no IOU meter services pursuant to the direct participation rules. SCE disagrees. The reference to Rule 22 is to establish that the fees for metering services will follow Rule 22 with the direct participation rules for metering services still applicable for the purpose of DR participating in the California Independent System Operator s (CAISO s) energy market. DACC/AReM s Opening Comments fail to mention the entire section in the IOUs direct participation rules on MDMA services for direct access customers. 6 DACC/AReM does not provide any legitimate justification to remove direct access customers from the allocation of direct participation costs, and yet they are provided the full benefit of utilizing direct participation services if they so choose. As such, the Commission should reject DACC/AReM s suggestion to modify the PD. C. The Proposed Decision Places Appropriate Limitations on Initial Implementation In its Opening Comments, EnergyHub recommends that the PD be modified to remove any limitation on the number of customers that can participate in the early phases of the implementation of direct participation services and that other strategies may be employed to 5 DACC/AReM Opening Comments, p For instance, see SCE Rule 24, Section F.2 MDMA Service Performed by SCE. 3

6 address technical constraints. 7 SCE disagrees. No party to this proceeding filed briefs that oppose a phased approach containing limitations on customer enrollments. However, it is only after the PD is issued that EnergyHub seeks party status to file comments in opposition to the PD. EnergyHub is not prohibited to providing comments, however they stand alone on a major issue of this proceeding which is whether the Commission should proceed with a phased approach to the implementation of direct participation. D. The Commission Should Consider ORA s and TURN s Recommendations for a Different Process to Evaluate Incremental Funding Requests to Support Ancillary and Real-Time Services In its Opening Comments, ORA states that the directive for the IOUs to file budget proposals to support AS and RT services within 30 days of the issuance of the decision and for parties to comment within 14 days is insufficient to provide a robust process. 8 TURN states in its Opening Comments, that it is concerned that a 14-day comments period may not offer adequate opportunity to conduct any factual discovery and address any issues. 9 SCE concurs with ORA s and TURN s concerns. SCE s Opening Comments did not focus on the level of scrutiny the IOUs budget proposals should receive, 10 however it does agree with ORA and TURN that if budget proposals are required to support AS and RT for all customers during the Initial Implementation Step, that the Commission should require parties to provide testimony. Thus, the Commission should consider modifying the process to submit budget proposals to support AS and RT. 7 EnergyHub Opening Comments, p ORA Opening Comments, p TURN Opening Comments, p In its Opening Comments, SCE recommended at least 60 days for it to provide budget proposals, should the Commission conclude that the IOUs are required to modify existing metering and billing systems to support all customers participating in AS and RT during the Initial Implementation Step. (SCE Opening Comments, pp. 4-5). 4

7 III. CONCLUSION SCE appreciates the opportunity to submit these reply comments. Respectfully submitted, JANET S. COMBS ANDREA L. TOZER /s/ Andrea L. Tozer By: Andrea L. Tozer Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) March 17,

8 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Recovery of Costs to Implement Electric Rule 24 Direct Participation Demand Response (U39E). And Related Matters. A (Filed June 2, 2014) A A CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS ON ADMINISTRATIVE LAW JUDGE HYMES PROPOSED DECISION APPROVING RECOVERY OF COSTS TO IMPLEMENT AN INITIAL LEVEL OF DEMAND RESPONSE DIRECT PARTICIPATION on all parties identified on the attached service list(s) A et al. Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s). ALJ Hymes CPUC 505 Van Ness Ave. San Francisco, CA Executed this 17th day of March, 2015, at Rosemead, California. /S/ Melissa Hernandez Melissa Hernandez Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Rosemead, California 91770

9 CPUC - Service Lists - A Page 1 of 4 3/17/2015 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR RECOVERY FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: MARCH 12, 2015 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties JEREMY WAEN FRANK LACEY SR. REGULATORY ANALYST VP - REGULATORY & MKT STRATEGY MARIN CLEAN ENERGY COMVERGE, INC. 415 MCFARLAN ROAD, SUITE 201, CA KENNETT SQUARE, PA FOR: MARIN CLEAN ENERGY FOR: COMVERGE, INC. ANDREA L. TOZER STEVEN C. NELSON ATTORNEY ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE. / PO BOX ASH STREET, HQ12 ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY JOY C. YAMAGATA MONA TIERNEY-LLOYD REGULATORY MGR. SR. DIR., WESTERN REGULATORY AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY ENERNOC, INC CENTURY PARK COURT, CP32D PO BOX 378 SAN DIEGO, CA CAYUCOS, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: ENERNOC, INC. SUE MARA LISA-MARIE SALVACION CONSULTANT CALIF PUBLIC UTILITIES COMMISSION RTO ADVISORS, LLC LEGAL DIVISION 164 SPRINGDALE WAY ROOM 5029 REDWOOD CITY, CA VAN NESS AVENUE FOR: DIRECT ACCESS CUSTOMER COALITION SAN FRANCISCO, CA AND ALLIANCE FOR RETAIL ENERGY MARKETS FOR: ORA

10 CPUC - Service Lists - A Page 2 of 4 3/17/2015 MARCEL HAWIGER MATT DUESTERBERG STAFF ATTORNEY CEO THE UTILITY REFORM NETWORK OHMCONNECT, INC. 785 MARKET ST., STE MISSION STREET, STE. 600 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: OHMCONNECT, INC. NORA SHERIFF J. MICHAEL REIDENBACH ALCANTAR & KAHL LAW DEPARTMENT 33 NEW MONTGOMERY ST., STE PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE ST., B30A / PO BOX 7442 FOR: CALIFORNIA LARGE ENERGY CONSUMERS SAN FRANCISCO, CA ASSOCIATION FOR: PACIFIC GAS AND ELECTRIC COMPANY (PG&E) SARA STECK MYERS ATTORNEY AT LAW TH AVENUE JOHNSON CONTROLS, INC. SAN FRANCISCO, CA CAMPISI WAY, SUITE 260 JENNIFER A. CHAMBERLIN DIR. REG AFFAIRS - INT. DEMAND RESOURCES FOR: JOINT DEMAND RESPONSE PARTIES CAMPBELL, CA (ENERNOC, COMVERGE & JOHNSON CONTROLS) FOR: JOHNSON CONTROLS, INC. Information Only BARBARA R. BARKOVICH CASE COORDINATION BARKOVICH & YAP, INC. PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA DR. ERIC C. WOYCHIK MRW & ASSOCIATES, LLC EXECUTIVE CONSULTANT & PRINCIPAL STRATEGY INTEGRATION LLC, CA 00000, CA JOHN NIMMONS KAREN TERRANOVA JOHN NIMMONS & ASSOCIATES, INC. ALCANTAR & KAHL, CA , CA FOR: SIERRA CLUB PETER DOTSON-WESTPHALEN CAMERON BROOKS MARKET DEVELOPMENT DIRECTOR E9 ENERGY INSIGHT CPOWER 1877 BROADWAY, SUITE EDGEWATER DRIVE, STGE. 293 BOULDER, CO WAKEFIELD, MA DANIEL W. DOUGLASS CASE ADMINISTRATION ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL LAW DEPT OXNARD ST., STE WALNUT GROVE AVE, RM 321 WOODLAND HILLS, CA ROSEMEAD, CA 91770

11 CPUC - Service Lists - A Page 3 of 4 3/17/2015 FOR: ALLIANCE FOR RETAIL ENERGY MARKETS (AREM) AND DIRECT ACCESS CUSTOMER COALITION (DACC) DAVID P. LOWREY KRISTIE C. RAAGAS REGULATORY POLICY & AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 101 ASH STREET, HQ RUSH STREET SAN DIEGO, CA ROSEMEAD, CA DON C. LIDDELL ANNLYN M. FAUSTINO ATTORNEY REGULATORY CASE ANALYST & SUPPORT DOUGLASS & LIDDELL SDG&E/SCGC ND AVENUE 8330 CENTURY PARK COURT, CP31E SAN DIEGO, CA SAN DIEGO, CA CENTRAL FILES WILLIAM FULLER SAN DIEGO GAS & ELECTRIC COMPANY CALIF. REGULATORY AFFAIRS 8330 CENTURY PARK CT, CP31-E SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA CENTURY PARK COURT, 32CH SAN DIEGO, CA JOSEPHINE WU SHIRLEY WOO PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS & ELECTRIC COMPANY 77 BEALE STREET, ROOM BEALE STREET, ROOM 3141 SAN FRANCISCO, CA SAN FRANCISCO, CA STEVE HAERTLE SAMUEL GOLDING PRINCIPAL REGULATORY CASE MGR PRESIDENT PACIFIC GAS AND ELECTRIC COMPANY COMMUNITY CHOICE PARTNERS, INC. PO BOX 7442, MC B9A 58 MIRABEL AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS ERICH HUFFAKER 425 DIVISADERO ST STE 303 OLIVINE, INC. SAN FRANCISCO, CA CROW CANYON PLACE, STE. 100 SAN RAMON, CA DOUGLAS M. GRANDY MIKE CADE DG TECHNOLOGIES ALCANTAR & KAHL 1220 MACAULAY CIRCLE 121 S.W. SALMON STREET, SUITE 1100 CARMICHAEL, CA PORTLAND, OR State Service DAVID PECK BRUCE KANESHIRO CALIFORNIA PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN, CA AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA

12 CPUC - Service Lists - A Page 4 of 4 3/17/2015 KELLY A. HYMES SUDHEER GOKHALE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5111 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA WERNER M. BLUMER XIAN "CINDY" LI CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MICHAEL MINKUS CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION 770 L Street, Suite 1250 Sacramento, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) ) ) )

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U 902-M for Approval Of Demand Response Program Augmentations And Associated Funding For