Whether PG&E’s Greenhouse Gas Compliance Instrument procurement complies with the 2014 bundled procurement plans; Whether the costs incurred and the entries recorded in the Green Tariff Shared Renewables Balancing Account in 2016 are in compliance with applicable tariffs and Commission directives; and Whether the request to recover the $5.689 million, not including interest and franchise fees and uncollectables through December 31, 2016, should be approved. Positions of the Parties Applicant: PG&E In its application, PG&E requests the Commission determine that, during the record year, PG&E: 1) complied with its Commission-approved Bundled Procurement Plan for fuel procurement, administration of power purchase contracts, greenhouse gas compliance instrument procurement, and least cost dispatch of electric generation resources; 2) managed its utility-owned generation facilities reasonably; 3) made reasonable expenditures in its Diablo Canyon Seismic Studies Balancing Account and the Green Tariff Shared Renewables Memorandum Account; and 4) ensured entries in the Green Tariff Shared Renewables Balancing Account were consistent with applicable tariffs and Commission directives. PG&E requests recovery of revenue requirements totaling $5.689 million, not including the associated interest and franchise fees and uncollectibles. PG&E makes the following contentions in its application: PG&E’s least cost dispatch showing is consistent with requirements in D.15-05-006, D.15-12-015, and the settlement approved in D.16-12-045, from the 2014 ERRA Compliance proceeding.
Independent review by outside party of PG&E’s hydro dispatch model (review to be on a one-time basis, not annual) D.16-12-045, Settlement Section 2.6 PG&E and ORA to work informally to address hydro-self-scheduling documentation and information concerning dispatchable renewable resources to be included in future ERRA Compliance applications D.16-12-045, Settlement Section 2.7 – 2.8 Definition of “operational constraints” as a reason not to dispatch when demand response program economic triggers are met D.16-12-045, Settlement Section 3.2 General set of guidelines for situations in which “customer fatigue” may occur in connection with demand response programs D.16-12-045, Settlement Section 3.2 Definition of “opportunity cost” as a reason not to dispatch demand response programs when economic triggers are met D.16-12-045, Settlement Sections 3.6 Develop quantitative opportunity cost measure as a metric D.16-12-045, Settlement Sections 3.8 – 3.9 Standard of Conduct 4 maximum disallowance amount and associated workpapers D.16-12-045, Settlement Section 5.3 Review and recovery of incentive payments for certain distributed energy resources D.16-12-036, OP 22 3.2. ORA ORA reviewed the application and recommends the Commission adopt disallowances related to two utility-owned generation facility outages: 1) $113,472 replacement power costs for the June 2016 outage at Cresta Powerhouse Unit 2; and 2) $211,325 replacement power costs for the February 2016 outage at Kerckhoff 1 Powerhouse Unit 3. Additionally, ORA recommends a third disallowance of $20,699 for failure to prudently administer a
Related to the utility-owned fossil generation and related outages, ORA made four recommendations, listed below, which ORA states were agreed to by PG&E. ORA requests the Commission to memorialize PG&E’s agreement. PG&E does not dispute agreement to these recommendations but , offers refinements and clarifications. PG&E agrees to prepare an incident report following the forced outage of any unit at any one of its generating facilities over 25 megawatts. PG&E had originally agreed to include supplemental testimony regarding an outage at the Humboldt Bay Generation Station (Humboldt). Instead, PG&E corrected the master data response and, thus, ORA is satisfied with the correction and no longer requests a supplemental filing. ORA recommends the Commission require PG&E to update the Commission on the company’s implementation of the Environex Report recommendations. Instead, PG&E proposes that it provide a report to ORA in response to a data request in next year’s proceeding. ORA recommends PG&E perform a cost-effectiveness analysis of whether Humboldt should be shut down by Instrumentation and Control devices instead of manually. PG&E explains that the use of these devices would increase outages thereby increasing costs. ORA accepted PG&E’s explanation and requested the Commission find PG&E in compliance with industry standard when an Instrumentation and Control device indicates high emissions. We address recommendation numbers three and four, as there appears to be some need for clarity. For recommendation number three above, there appears to be a difference of opinion with respect to how the Commission should be updated on PG&E’s implementation of the Environex Report: ORA recommends PG&E provide a