BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Approval of the Results of Its 2016 Energy Storage and Distribution Deferral Request for Offers. Application No (Filed December 1, 2017) And Related Matter. Application No REPLY BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) JANET S. COMBS TRISTAN REYES CLOSE Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: June 4, 2018

2 REPLY BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) Table of Authorities Page I. INTRODUCTION...1 II. III. THE POWIN CONTRACT IS REASONABLE AND SHOULD BE APPROVED...2 THE COMMISSION SHOULD REJECT TURN S PROPOSAL TO TRACK AND COMPILE DATA ON THE PERFORMANCE OF THE POWIN RESOURCE...2 IV. CONCLUSION...3 -i-

3 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Approval of the Results of Its 2016 Energy Storage and Distribution Deferral Request for Offers. Application No (Filed December 1, 2017) And Related Matter. Application No REPLY BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) Pursuant to Rule of the Rules of Practice and Procedure of the California Public Utilities Commission ( Commission or CPUC ) and the schedule set forth in the Scoping Memo and Ruling of Assigned Commissioner and Administrative Law Judges, dated February 28, 2018 ( Scoping Memo ), Southern California Edison Company ( SCE ) respectfully submits this reply to the closing brief filed by The Utility Reform Network ( TURN ) on May 14, 2018 ( Reply Brief ). I. INTRODUCTION SCE s Application for Approval of the Results of its 2016 Energy Storage and Distribution Deferral Request for Offers ( ES & DD RFO ) ( Application ) seeks approval of one 10 megawatt ( MW ) contract with Powin SBI, LLC ( Powin ). The Powin contract is reasonable and was executed consistent with SCE s Application for Approval of its 2016 Energy Storage Procurement Plan, which was approved by the Commission in Decision ( D. ) Therefore, SCE respectfully requests that the Commission approve the 2016 ES & DD RFO, SCE s conduct with respect to the 2016 ES & DD RFO, and the 10 MW Powin contract selected through the 2016 ES & DD RFO as reasonable. 1

4 II. THE POWIN CONTRACT IS REASONABLE AND SHOULD BE APPROVED TURN s brief states that it believes the Commission should consider the qualitative benefits attributed to the Powin project by SCE in determining whether to approve the contract. 1 As discussed in its Rebuttal Testimony, SCE concurs with the need for careful evaluation and agrees that to approve the Powin contract and SCE s conduct with respect to the RFO, the Commission must evaluate SCE s assessment of the costs and benefits of the Powin contract. 2 Moreover, in its Closing Brief, SCE referenced the discussion in D that provides that any actual finding of cost-effectiveness should only be done in a utility application for approval of storage contracts or rate-based additions, where there is a specific project and actual project inputs. 4 Notwithstanding SCE s concurrence with TURN on the Commission s role in evaluating the Powin contract, SCE asserts that once the Commission reviews the totality of the contract, including the quantitative and qualitative elements, as directed in D , it will find ample support for approving the Powin contract as a cost competitive energy storage resource. Accordingly, the Commission should approve the 10 MW Powin contract. III. THE COMMISSION SHOULD REJECT TURN S PROPOSAL TO TRACK AND COMPILE DATA ON THE PERFORMANCE OF THE POWIN RESOURCE TURN continues to suggest that if the Commission approves the Powin contract it should require SCE to track information on the charging and discharging patterns of, as well as the services provided by, the Powin facility 5 and compile the data in an annual report to be 1 TURN s Closing Brief at 3. 2 Exhibit SCE-03, Rebuttal Testimony of SCE on the Results of Its 2016 Energy Storage and Distribution Deferral Request for Offers, at 2. 3 SCE s Closing Brief at 8, fn D at TURN s Closing Brief at 5. 2

5 served in the energy storage rulemaking. 6 Yet TURN does not address the issue raised in SCE s Rebuttal Testimony and Closing Brief that SCE will not have access to the information TURN would like SCE to track and compile. 7 As SCE has previously explained, the Powin contract is a resource adequacy-only contract and SCE would not be bidding the resource into the market or metering it, therefore, SCE does not have access to the information being requested, nor is Powin contractually required to provide this information to SCE. 8 SCE is not in a position to track and compile data that it does not have access to, therefore, the Commission should reject TURN s suggestion as unreasonable. IV. CONCLUSION Through its Application, testimony, and briefing, SCE has demonstrated that the 2016 ES & DD RFO and the 10 MW Powin contract selected through the RFO are reasonable. Therefore, the Commission should approve SCE s Application in its entirety and grant the findings requested by SCE. Respectfully submitted, JANET S. COMBS TRISTAN REYES CLOSE /s/ Tristan Reyes Close By: Tristan Reyes Close Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) June 4, Tristan.ReyesClose@sce.com 6 Id. 7 Exhibit SCE-03, Rebuttal Testimony of SCE on the Results of Its 2016 Energy Storage and Distribution Deferral Request for Offers, at 7; SCE s Closing Brief at Id. 3

6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Approval of the Results of Its 2016 Energy Storage and Distribution Deferral Request for Offers. Application No (Filed December 1, 2017) And Related Matter. Application No 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 REPLY BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) on all parties identified on the attached service list for A , et al. Service was effected by transmitting copies via to ALJ Michelle Cooke and all parties who have provided an address and by placing copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to the office of the assigned ALJ and/or other addressees. ALJ Brian Stevens California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue, Room 5103 San Francisco, CA Executed on June 4, 2018, at Rosemead, California. /s/ Olivia Gutierrez Olivia Gutierrez SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

7 CPUC - Service Lists - A Page 1 of 3 6/4/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - FOR APPROVA FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: APRIL 12, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties TRISTAN REYES CLOSE ANAND DURVASULA SENIOR ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY LEGAL DIVISION 2244 WALNUT GROVE AVENUE PO BOX 800 ROOM 4107 ROSEMEAD, CA VAN NESS AVENUE FOR: SOUTHERN CALIFORNIA EDISON COMPANY SAN FRANCISCO, CA FOR: ORA HAYLEY GOODSON ALEX MORRIS STAFF ATTORNEY SR. DIR., POLICY & REGULATORY AFFAIRS THE UTILITY REFORM NETWORK CALIFORNIA ENERGY STORAGE ALLIANCE 785 MARKET ST., STE ALLSTON WAY, SUITE 210 SAN FRANCISCO, CA BERKELEY, CA FOR: TURN FOR: CALIFORNIA ENERGY STORAGE ALLIANCE (CESA) GREGORY MORRIS DIRECTOR GREEN POWER INSTITUTE 2039 SHATTUCK AVENUE, STE 402 BERKELEY, CA FOR: GREEN POWER INSTITUTE Information Only CASE COORDINATION PACIFIC GAS AND ELECTRIC COMPANY DONALD LIDDELL DOUGLASS & LIDDELL

8 CPUC - Service Lists - A Page 2 of 3 6/4/2018 ONLY ONLY ONLY, CA ONLY, CA REGULATORY CLERK MRW & ASSOCIATES, LLC BRAUN BLAISING SMITH WYNNE, PC ONLY ONLY ONLY, CA ONLY, CA CASE ADMINISTRATION SUE MARA SOUTHERN CALIFORNIA EDISON COMPANY CONSULTANT 8631 RUSH STREET RTO ADVISORS L.L.C. ROSEMEAD, CA SPRINGDALE WAY REDWOOD CITY, CA ERIC BORDEN DAVID PEFFER ENERGY POLICY ANALYST ATTORNEY AT LAW THE UTILITY REFORM NETWORK BRAUN BLAISING SMITH WYNNE, P.C. 785 MARKET STREET, STE L STREET, SUITE 1480 SAN FRANCISCO, CA SACRAMENTO, CA KEVIN WOODRUFF SCOTT BLAISING CONSULTANT ATTORNEY WOODRUFF EXPERT SERVICES, INC. BRAUN BLAISING SMITH WYNNE, PC TH STREET, SUITE L STREET, STE SACRAMENTO, CA SACRAMENTO, CA FOR: TURN ANDREW B. BROWN TAM HUNT, J.D. ATTORNEY AT LAW CONSULTING ATTORNEY ELLISON SCHNEIDER HARRIS & DONLAN LLP COMMUNITY RENEWABLE SOLUTIONS, LLC 2600 CAPITAL AVENUE, SUITE MOKU ST SACRAMENTO, CA PAHOA, HI FOR: GREEN POWER INSTITUTE State Service MICHELLE COOKE ADMINISTRATIVE LAW JUDGE CALIFORNIA PUBLIC UTILITIES COMMISSION ONLY ONLY, CA AMIN NOJAN ELECTRICITY PLANNING & POLICY BRANCH AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA FOR: ORA BRIAN STEVENS CHRISTOPHER MYERS DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PLANNING & POLICY BRANCH ROOM 5103 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA KARIN M. HIETA LEE-WHEI TAN

9 CPUC - Service Lists - A Page 3 of 3 6/4/2018 ELECTRICITY PLANNING & POLICY BRANCH ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5010 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA RACHEL MCMAHON SHANNON O'ROURKE INFRASTRUCTURE PLANNING AND PERMITTING B COMMISSIONER PETERMAN AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS