A1103001 et. al DR - SCE Ex-Parte Notice.pdf - Southern California ...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Application of Pacific Gas and Electric (U 39-E)
for Approval of Demand Response Programs,
Pilots and Budgets for 2012-2014.
And Related Matters.
)
)
)
)
)
)
A. 11-03-001
(Filed March 1, 2011)
A. 11-03-002
A. 11-03-003
SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) NOTICE OF EX PARTE
JANET COMBS
R. OLIVIA SAMAD
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone: (626) 302-3477
Facsimile: (626) 302-7740
E-mail:olivia.samad@sce.com
Dated: December 19, 2011
Law#1846151

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Application of Pacific Gas and Electric (U 39-E)
for Approval of Demand Response Programs,
Pilots and Budgets for 2012-2014.
And Related Matters.
)
)
)
)
)
)
A. 11-03-001
(Filed March 1, 2011)
A. 11-03-002
A. 11-03-003
SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) NOTICE OF EX PARTES
Pursuant to Rule 8.4 of the California Public Utilities Commission (Commission) Rules
of Practice and Procedure, Southern California Edison Company (SCE) hereby gives notice of its
December 14, 2011 ex parte communication with President Michael Peevey from 3:00 p.m. to
3:30 p.m. SCE representative Michael Hoover, Director Regulatory Affairs, met with
Commissioner Peevey, as well as his chief of staff, Carol Brown and Deputy Executive Director
of Policy and External Relations, Nancy Ryan. The communication was initiated by SCE and
took place at Commissioner Peevey’s office at the Commission’s headquarters in San Francisco,
California. Mr. Hoover discussed the Proposed Decision of Administrative Law Judge Hymes
Adopting Demand Response Programs and went through the handout, Attachment A, which was
provided to him and his advisors. This meeting was noticed on Friday, December 9, 2011.
To request a copy of this notice, please contact Alejandra Arzola at (626) 302-3062 or
e-mail address: case.admin@sce.com.
- 1 -

Respectfully submitted,
JANET COMBS
R. OLIVIA SAMAD
/s/ R. Olivia Samad
By: R. Olivia Samad
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone: (626) 302-3477
Facsimile: (626) 302-7740
E-mail:olivia.samad@sce.com
December 19, 2011
- 2 -

Attachment A

SCE Issues Regarding PD for
DR Activities and Budgets for 2012-2014
What the PD does
What the consequences are
What needs to change
A-1

Dynamic Pricing
What the PD does:
This PD eliminates all funding for CPP and RTP (total $11.4 million) and directs SCE to request
funding for these programs in its Dynamic Pricing or GRC proceedings.
The PD does not recognize that the Dynamic pricing proceeding is closed nor that it is
problematic whether these modifications to SCE’s GRC can be made.
Nevertheless, the PD denies ME&O for all CPP and finds the costs unreasonable; however, it
does not state why it is unreasonable.
The PD also denies funding of administering and operating CPP and RTP.
The PD does not recognize that most of SCE’s customers 200kW and RTP has been
allowed in all previous DR proceedings.
What the consequences are:
Funds will not be available to provide customer marketing, education and outreach nor will SCE
have the funds to administer and operate the programs.
Customers participating in these programs will not have the level of education necessary to
understand and participate in the programs and would not likely enroll.
Customer enrollment and participation will be adversely affected and expected MW of RA in
2012 may be impacted.
These programs will not reach their full potential that of price responsive DR and in the case of
CPP, the elimination of funding will adversely impact the potential benefits of smart meters now
being deployed to customers below 200 kW.
What needs to change:
Funding for CPP and RTP needs to be approved in this application, $9.3 million for CPP and
$1.1 million for RTP.
A-2

Summer Discount Plan (SDP)
What the PD does:
The PD finds the marketing funding request for SDP to be excessive and reduces SCE’s funding
request of $6.7 million by $4 million.
The PD erroneously calculates the cost to enroll SDP customers (page 79). The PD states that it
cost $3,856 per customer in 2009, and $320 per customer for enrollments through 2014. *
The actual amount requested in 2012-2014 to enroll a new customer is $34.*
*See table for details
What the consequences are:
SCE’s marketing for SDP will be minimal in 2012-2014. Enrollment will likely diminish,
through normal attrition and in reaction to the new program design which begins in 2012.
The DR MWs available for emergencies as well as SCE’s ability to mitigate high wholesale
market prices will be impacted.
What needs to change:
The PD should approve SCE’s funding request for SDP ME&O.
A-3

Summer Discount Plan (SDP) (continued)
Calculation of $ME&O/New Customer for 2012-2014
Line Item Proposed Comments Actual Comments
Decision
1 No. of New 27,000 Source unknown 196,000 SCE Testimony
Customers
2 $ of ME&O $6,714,000 SCE Testimony $6,714,000 SCE Testimony
3 $ME&O/New
Customer
(Line 2/Line
1)
$320 The calculation yields
$249. The value of
$320 in the PD
appears to be a math
error.
$34
Calculation of $ME&O/New Customer for 2009
Lin Item Proposed Comments Actual Comments
e
Decision
1 No. of New
Customers
19,863 From SCE’s 2009
Monthly Report.
Takes EOY
enrollment minus
BOY enrollment.
Does not include new
customers that replace
those that leave
45,405 SCE records
2 $ of ME&O $76,600,00
0
3 $ME&O/New
Customer
(Line 2/Line
1)
program.
Inappropriately
included incentives
paid to all 330,000
enrolled customers for
load reductions. May
be confused that
incentives are an
ME&O cost. Also
included program
operations and admin
costs, in addition to
ME&O
$3,856 $31
$1,398,00
0
SCE Records
A-4

Reliability Programs
What the PD does:
The PD eliminates the ME&O funding for SCE’s reliability programs, the Base Interruptible and
the Agriculture-Interruptible program, in the amount of $147,500.
The PD prohibits any spending for ME&O for these programs, finding that such spending is
unreasonable given that the MWs for these programs are capped under the terms of the
Settlement Agreement adopted in D10-06-034.
The PD does not recognize that the SCE’s funding request, while characterized as ME&O, is
necessary communications with enrolled customers, including such activities as updates, printing
and distribution of fact sheets and letters to customers during the opt-out window.
What the consequences are:
With an absolute prohibition to spend for this category of expense, communications with
customers concerning their participation in programs may be considered a violation of
compliance with the PD directive. SCE cannot operate the programs with this prohibition.
The DR MWs available for emergencies as well as SCE’s ability to mitigate high wholesale
market prices will be impacted.
What needs to change:
The PD should approve SCE’s funding request for ME&O for reliability programs.
A-5

Save Power Day(PTR)
What the PD does:
This PD reduces the funding request for Save Power Day (PTR) ME&O by 50 percent,
approximately $10 million from SCE’s request of $20 million
The PD refers to 2011 ME&O spending for PTR through August 2011, purportedly as reported
in SCE’s Monthly Report for August 2011, finding that the spending for PTR ME&O amounted
to 30 percent of the authorized amount (footnote 194). Based on this finding the PD considered
the reduction of 50 percent of the PTR ME&O budget reasonable.
SCE was not authorized funding for PTR in its 2009-2011 DR funding cycle, has not made any
such expenditures nor reported any such spending on its monthly report.
The PD may be referring to the ME&O spending through August 2011 for a grouping of ME&O
activities that are unrelated to PTR and do not support a specific load reduction program such as
PTR.
The PD does not recognize the composition of SCE’s ME&O request for PTR. Approximately
$14 million is for mass media notification for approximately 24 PTR events, primarily through
radio ads across SCE’s territory. Approximately $5 million is related to communications with
over 4 million customers to encourage them to provide their telephone or fax numbers, email
addresses, etc. so that they can be notified directly.
What the consequences are:
SCE may not be able to effectively communicate with the more than 4 million customers on PTR
to:
Generate awareness and increase enrollment in notification.
Notify customers when a Save Power Day Event is occurring.
Without the ability to educate residential customers on this new program and without adequate
funding to announce events, it is unlikely that load reductions will occur at the level that would
otherwise be enabled by the new smart meters.
What needs to change:
Save Power Day (PTR) funding in the amount requested needs to be approved in this application.
A-6

Cost Effectiveness
What the PD does:
The PD appears to be setting new Commission policies with respect to cost-effectiveness. There
was no discussion nor vetting of these policy changes in the C/E decision, the C/E Protocols nor
in Commission guidance prior to the filing of the IOU Applications.
The PD directs:
That the cost-effectiveness analysis includes all costs related to a DR program from other
proceedings. The PD does not recognize that this is a deviation from prior Commission polices in
DR and Energy Efficiency C/E.
The PD does not adequately examine the effects of the non-program costs (portfolio or indirect
costs), allocated to DR programs, that may cause the C/E of individual programs to be understated.
The PD abandons the TRC as the primary determinant of C/E and establishes a new metric to
determine C/E.
The PD directs some program funding reductions based only on C/E results, with little apparent
regard to the impact of the reduction on the operational effectiveness of the affected program.
The PD directs the Energy Division to hold workshops to address C/E issues raised in the PD.
What the consequences are:
These new applications of the C/E may have significant impacts in other proceedings such as
Energy Efficiency, with unknown consequences, e.g. program modifications or terminations,
reduction in incentives, etc.
The inclusion of costs from other proceedings is poorly defined and may lead to inconsistent
results across utilities for identical programs.
What needs to change:
The PD should not adopt new policies in the PD but rather defer them to resolution in the
workshops, with the outcomes to be the adopted in the protocols or in an amended C/E decision.
The directive to include costs from other proceedings should be deferred
The new metrics to determine C/E should be deferred
Funding reductions based on C/E should be restored, absent a finding of no significant adverse
impact on program operational effectiveness.
A-7

Dual Participation
What the PD does:
The PD adds confusing new rules for dual participation that eliminate nearly all dual
participation. It states that two programs that are RA qualified are ineligible for dual
participation and that CPP contains capacity elements on an “inexplicit” basis. It also directs us
to implement these rules January 2012 but only for new customers, while they will apply to
existing customers January 2013.
What the consequences are:
These new rules will increase costs, create customer confusion and reduce availability of energy
resources into the CAISO market.
It creates a significant negative impact to Auto-DR participation dual participating on BIP/DBP,
especially for the larger customers on multi-year contracts.
BIP customers would opt off.
Funds invested in enabling technologies would not qualify for reimbursement.
Millions of ratepayer dollars would be negatively impacted.
There would not be enough time to update tariffs by January 2012.
What needs to change:
The PD needs to be modified to allow some dual participation, especially BIP/DBP
The PD could leave all dual participation rules as they are to save money and aid customer
understanding.
If there are any changes those changes needs to be applied January 2013.
A-8

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
(U 338-E) NOTICE OF EX PARTE on all parties identified on the attached service list(s).
Service was effected by one or more means indicated below:
Transmitting the copies via e-mail to all parties who have provided an e-mail address.
First class mail will be used if electronic service cannot be effectuated.
Executed this 19 th day of December, 2011, at Rosemead, California.
/s/Alejandra Arzola
Alejandra Arzola
Project Analyst
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770

CPUC - Service Lists - A1103001
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Parties
SUE MARA
STEVEN D. PATRICK
RTO ADVISORS, LLC.
ATTORNEY
EMAIL ONLY
SD GAS AND ELECTRIC CO / SOCAL GAS CO
EMAIL ONLY, CA 00000-0000 555 WEST FIFTH STREET, SUITE 1400
FOR: ALLIANCE FOR RETAIL ENERGY MARKETS LOS ANGELES, CA 90013-1011
FOR: SAN DIEGO GAS AND ELECTRIC COMPANY
DANIEL W. DOUGLASS
R. OLIVIA SAMAD
ATTORNEY
ATTORNEY
DOUGLASS & LIDDELL
SOUTHERN CALIFORNIA EDISON COMPANY
21700 OXNARD ST., STE. 1030 2244 WALNUT GROVE AVE. / PO BOX 800
WOODLAND HILLS, CA 91367 ROSEMEAD, CA 91770
FOR: DIRECT ACCESS CUSTOMER COALITION FOR: SOUTHERN CALIFORNIA EDISON COMPANY
DONALD C. LIDDELL
DONALD C. LIDDELL
ATTORNEY
COUNSEL
DOUGLASS & LIDDELL
DOUGLASS & LIDDELL
2928 2ND AVENUE 2928 2ND AVENUE
SAN DIEGO, CA 92103 SAN DIEGO, CA 92103
FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: ICE ENERGY, INC./CALIFORNIA
ENENRGY STORAGE ALLIANCE/CALMAC
MANUFACTURING CORPORATION
MICHAEL SHAMES
LAURA MANZ
UTILITY CONSUMERS ACTION NETWORK
VIRIDITY ENERGY, INC.
3405 KENYON ST., STE. 401 16870 WEST BERNARDO DR., STE. 400
SAN DIEGO, CA 92110 SAN DIEGO, CA 92127

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FOR: UTILITY CONSUMERS ACTION NETWORK
FOR: VIRIDITY ENERGY, INC.
LISA-MARIE SALVACION
NINA SUETAKE
CALIF PUBLIC UTILITIES COMMISSION
THE UTILITY REFORM NETWORK
LEGAL DIVISION 115 SANSOME STREET, SUITE 900
ROOM 5029 SAN FRANCISCO, CA 94104
505 VAN NESS AVENUE FOR: THE UTILITY REFORM NETWORK
SAN FRANCISCO, CA 94102-3214
FOR: DRA
NORA SHERIFF
WILLIAM H. BOOTH
ALCANTAR & KAHL, LLP
ALCANTAR & KAHL
33 NEW MONTGOMERY STREET, SUITE 1850 33 NEW MONTGOMERY STREET, STE. 1850
SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105
FOR: ENERGY PRODUCERS & USERS COALITION FOR: CALIFORNIA LARGE ENERGY CONSUMERS
ASSOCIATION
MARLO GO STROUD
MARY A. GANDESBERY
GOODIN MACBRIDE SQUERI DAY LAMPREY, LLP PACIFIC GAS AND ELECTRIC COMPANY
505 SANSOME STREET, SUITE 900 PO BOX 7442, MC B30A-3005
SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94120-7442
FOR: NORTH AMERICA POWER PARTNERS, LLC FOR: PACIFIC GAS AND ELECTRIC COMPANY
SARA STECK MYERS
ELIZABETH RASMUSSEN
ATTORNEY AT LAW
PROJECT MGR./REG. AND LEGAL COUNSEL
122 - 28TH AVENUE MARIN ENERGY AUTHORITY
SAN FRANCISCO, CA 94121 781 LINCOLN AVENUE, SUITE 320
FOR: DR AGGREGATORS (ENERNOC/ENERGY SAN RAFAEL, CA 94901
CONNECT, INC./CONVERGE, INC.)
FOR: MARIN ENERGY AUTHORITY
CARLOS LAMAS-BABBINI
RICH QUATTRINI
CEN-CA PROGRAM MGR.
ENERGYCONNECT, INC.
COMVERGE, INC. 901 CAMPISI WAY, SUITE 260
58 MT. TALLAC CT. CAMPBELL, CA 95008
SAN RAFAEL, CA 94903
FOR: ENERGY CONNECT, INC.
FOR: COMVERGE, INC.
BALDASSARO DICAPO
MELANIE GILLETTE
CALIFORNIA ISO
WESTERN REGULATORY AAFAIRS
250 OUTCROPPING WAY ENERNOC, INC.
FOLSOM, CA 95630
115 HAZELMERE DRIVE
FOR: CALIFORNIA INDEPENDENT SYSTEM FOLSOM, CA 95630
OPERATOR CORPORATION
FOR: ENERNOC, INC.
Information Only
ANGELA DAVISON-LEE
JODY LONDON
THE ENERGY COALITION
JODY LONDON CONSULTING
EMAIL ONLY
EMAIL ONLY
EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000
LARA ETTENSON
MRW & ASSOCIATES, LLC

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NATURAL RESOURCES DEFENSE COUNCIL
EMAIL ONLY
EMAIL ONLY EMAIL ONLY, CA 00000
EMAIL ONLY, CA 00000
ANDREW GAY
LARRY ALLEN
ARC ASSET MANAGEMENT, LTD
DEPARTMENT OF THE NAVY
237 PARK AVENUE, 9TH FLOOR 1322 PATTERSON AVE., SE
NEW YORK, NY 10017 WASHINGTON, DC 20374-5018
DAVID NEMTZOW
CASE ADMINISTRATION
ICE ENERGY, INC.
SOUTHERN CALIFORNIA EDISON COMPANY
1254 9TH STREET, NO. 6 2244 WALNUT GROVE AVE., PO BOX 800
SANTA MONICA, CA 90401 ROSEMEAD, CA 91770
DAVID LOWREY
ANNLYN MA. FAUSTINO
SOUTHERN CALIFORNIA EDISON COMPANY SDG&E/SCGC
DEMAND RESPONSE REGULATORY & REPORTING 8330 CENTURY PARK COURT (CP31E)
1515 WALNUT GROVE AVE. SAN DIEGO, CA 92123
ROSEMEAD, CA 91770
CENTRAL FILES
JOY C. YAMAGATA
SAN DIEGO GAS AND ELECTRIC COMPANY REGULATORY MANAGER
8330 CENTURY PARK COURT, CP-32D SAN DIEGO GAS & ELECTRIC/SOCALGAS
SAN DIEGO, CA 92123
8330 CENTURY PARK COURT, CP 32D
SAN DIEGO, CA 92123-1533
NORMAN J. FURUTA
ERIC CUTTER
FEDERAL EXECUTIVE AGENCIES
ENERGY AND ENVIRONMENTAL ECONOMIC
1455 MARKET ST., SUITE 1744 101 MONTGOMERY STREET, SUITE 1600
SAN FRANCISCO, CA 94103-1399 SAN FRANCISCO, CA 94104
FOR: DEPARTMENT OF THE NAVY
CASE COORDINATION
KAREN TERRANOVA
PACIFIC GAS AND ELECTRIC COMPANY
ALCANTAR & KAHL, LLP
77 BEALE ST., PO BOX 770000 MC B9A 33 NEW MONTGOMERY STREET, SUITE 1850
SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105
STEVE HAERTLE
CALIFORNIA ENERGY MARKETS
PACIFIC GAS AND ELECTRIC COMPANY 425 DIVISADERO STREET, SUITE 303
77 BEALE STREET, MC B9A SAN FRANCISCO, CA 94117
SAN FRANCISCO, CA 94105
SHIRLEY A. WOO
JOSEPHINE WU
ATTORNEY AT LAW
PACIFIC GAS AND ELECTRIC COMPANY
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 770000, MC B9A
PO BOX 7442, MC B30A SAN FRANCISCO, CA 94177
SAN FRANCISCO, CA 94120-7442
MARK HUFFMAN
NICK HO
ATTORNEY AT LAW
PACIFIC GAS AND ELECTRIC COMPANY
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 770000, MC N3F
PO BOX 770000, MC B30A SAN FRANCISCO, CA 94177
SAN FRANCISCO, CA 94177

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BARBARA R. BARKOVICH
JEFF NAHIGIAN
BARKOVICH & YAP, INC.
JBS ENERGY, INC.
44810 ROSEWOOD TERRACE 311 D STREET
MENDOCINO, CA 95460 WEST SACRAMENTO, CA 95605
JOHN GOODIN
LEGAL DEPARTMENT
CALIFORNIA ISO
CALIFORNIA ISO
151 BLUE RAVINE RD. 250 OUTCROPPING WAY
FOLSOM, CA 95630 FOLSOM, CA 95630
SCOTT BLAISING
KAREN MILLS
BRAUN BLAISING MCLAUGHLIN P.C.
CALIFORNIA FARM BUREAU FEDERATION
915 L STREET, SUITE 1270 2300 RIVER PLAZA DRIVE
SACRAMENTO, CA 95814 SACRAMENTO, CA 95833
FOR: CALIFORNIA FARM BUREAU FEDERATION
JACK ELLIS
1425 ALPINE WAY / PO BOX 6600
TAHOE CITY, CA 96145
State Service
ALOKE GUPTA
BRUCE KANESHIRO
CALIF PUBLIC UTILITIES COMMISSION
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DORRIS LAM
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CALIF PUBLIC UTILITIES COMMISSION
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