January 16, 2009
Mr. Curtis Seymour
California Public Utilities Commission
505 Van Ness Ave.
San Francisco, CA 94102
RE: Informal Joint Comments of Southern California Edison Company (SCE) and San
Diego Gas & Electric Company (SDG&E) on Matters Discussed at the Tariff
Implementation Workshop Regarding AB 2466 – Local Government Renewable
Energy Self Generation Program
The California Public Utilities Commission (CPUC) Energy Division held a workshop on January 8, 2009 to allow Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company to provide a public presentation of their draft tariffs to implement AB 2466 (2008) – Local Government Renewable Energy
Self Generation Program. The purpose of the workshop was to allow interested parties and stakeholders the opportunity to ask questions and engage in a discussion to facilitate implementation in advance of the formal tariff filings. In these Post-workshop Comments, SCE and SDG&E summarize the presentation at the workshop with a description of the proposed crediting and eligibility process. We appreciate the opportunity both to participate in the workshop and to comment on issues raised therein.
Summary of Presentation
AB 2466 allows local governments, such as cities and school districts, to receive monetary credits for excess renewable generation that is exported to the utility grid. These credits can then be applied to offset the generation costs of the customer’s other
retail service accounts.
Participating customers are provided credits associated with a retail account to which an eligible renewable generation facility is interconnected. This account is called the Generating Account. The amount of the credit provided is determined by multiplying the energy (kWh) that flows into the utility grid (i.e., generation net of contemporaneous load requirements of the generating account and any station power) multiplied by the per-kWh generation component that is applicable for the Generating Account. Because the customer accounts participating are required to be on a Time-Of-Use (TOU) rate, the value of the credit produced will depend on the TOU generation rate at the time the generator is exporting energy to the utility grid. The credit, which is in dollars, is then applied for the same billing period to reduce the generation charge of the customer’s
various accounts, known as Benefiting Accounts. For example, a TOU customer with an eligible photo-voltaic generating facility that exports energy during the On-Peak (i.e. the highest rate period) will receive the utility’s On-Peak rate for its exported generation.
That is, the credit is based on the On-Peak generation rate multiplied by the energy (kWh) exported to the grid in the On-Peak period. The resulting credit is then applied as described above to the Benefiting Accounts’ generation charge, regardless of the timing
of load supplied by the utility to the Benefiting Account.
Description of Proposed Crediting and Eligibility Process
Credits are first applied to the Generating Account, which is also a Benefiting Account. Although the generator will be supplying Generating Account load that is contemporaneous with generation, the Generating Account may have net generation charges for consumption during which the generator is not operating. Remaining credits are then applied to the other Benefiting Accounts during each billing cycle. While it is anticipated that the credits will be fully used during each billing cycle by the Benefiting Accounts, any remaining credits will be carried over to the next billing cycle. Pursuant to AB 2466, this process continues for a 12-month period with any remaining credit at the end of the 12-month period forfeited and a new 12-month period initiated.
The customer’s Generating Account may not simultaneously participate in both the program created by AB 2466 and Net Energy Metering (NEM). NEM allows for excess generation to be carried forward to offset the generating account’s usage during a 12-
month period. AB 2466 defines “Bill Credit” as being calculated based on electricity
“exported to the grid”. AB 2466, as codified in Public Utilities Code Section 2830(a)(2), states:
Electricity is exported to the grid if it is generated by an eligible renewable
generating facility, is not utilized on-site by the local government, and the
electricity flows through the meter site and on to the electrical corporation’s
distribution or transmission infrastructure.
While Generating Account load which is contemporaneous with generation is offset before any energy can be exported to the grid, once that energy is exported it is valued at the Generating Account rate under AB 2466 and is not eligible for NEM treatment. The customer has the opportunity every 12 months to change the Benefiting Accounts designated to receive the credits, by notifying the utility 60 days in advance of the change. The customer may designate any number of accounts as Benefiting Accounts provided that such accounts take retail service on a TOU rate. If the customer has more than one Generating Account, the customer must designate Benefiting Accounts exclusive to each Generating Account. A Benefiting Account cannot receive credit from more than one Generating Account.
Lastly, the customer must provide the utility 60 days’ notice prior to the eligible
renewable generating facility becoming operational. Additional metering, billing, and interconnection costs to accommodate the participation in the AB 2466 program are to be paid by participating customers.
We respectfully submit our comments to the issues raised at the workshop and urge the
Commission to consider them in resolving any outstanding questions or issues in this