amended southern california edison company’s … · 21 renewables facility that is subscribed by...

Application No.: A.12-01-008/A.12-04-020/14-01-007 (Consolidated)

Exhibit No.: SCE-5 Witnesses: Kathleen Sloan

Brandi Anderson Amir Angha Robert Thomas Jessica Lim Douglas Snow

(U 338-E)

AMENDED SOUTHERN CALIFORNIA EDISON

COMPANY’S COMMUNITY RENEWABLES

PROGRAM

Before the

Public Utilities Commission of the State of California

Rosemead, California

April 11, 2014

AMENDED SOUTHERN CALIFORNIA EDISON COMPANY’S COMMUNITY RENEWABLES PROGRAM

Table Of Contents

Section Page Witness

i

I. INTRODUCTION .............................................................................................1 K. Sloan

II. COMMUNITY RENEWABLES PROGRAM STRUCTURE .........................4

A. Relationship Between Participating Customer and Community Renewables Provider .........................................................4

B. Relationship Between Community Renewables Provider and SCE .................................................................................................4

C. Relationship Between Participating Customer and SCE .......................7

III. COMMUNITY RENEWABLES PROGRAM SCOPE AND REQUIREMENTS .............................................................................................8 B. Anderson

A. Community Renewables Program Scope...............................................8

B. Community Renewables Participating Customer Requirements .........................................................................................9

C. Community Renewables Facility Requirements ..................................11 A. Angha

IV. COMMUNITY RENEWABLES RATE DESIGN .........................................13 R. Thomas

A. Generation Credit Components ............................................................13

1. Class Average Retail Generation Rate .....................................13

2. Adjustments .............................................................................14

a) Indifference Adjustment ..............................................14

b) Resource Adequacy Charge .........................................14 A. Angha

c) Renewable Integration and Market Participation Charge.....................................................15

B. Program Administration Charge ..........................................................15 B. Anderson

C. Balance of Payments in the Community Renewables Program ................................................................................................16 K. Sloan

V. COMMUNITY RENEWABLES EDUCATION AND OUTREACH ....................................................................................................18 J. Lim


Table Of Contents (Continued)


ii

VI. COMMUNITY RENEWABLES COST RECOVERY ...................................19 D. Snow

VII. BENEFITS OF SCE’S COMMUNITY RENEWABLES PROGRAM DESIGN ......................................................................................21 K. Sloan

VIII. COMPARISON OF COMMUNITY RENEWABLES AND GREEN RATE PROGRAMS ..........................................................................24

Appendix A Witness Qualifications

Appendix B Redline of Amended Community Renewables Program in Comparison to Community Renewables Program


List of Tables

Table Page

iii

Table IV-1 Balance of Payments in the Community Renewables Program ..............................................16

Table VIII-2 Comparison of SCE’s Green Rate and Community Renewables

Programs ....................................................................................................................................................25

Southern California Edison Company (“SCE”) is serving this Amended Southern

California Edison Company’s Community Renewables Program, Exhibit SCE-5 (“Amended

Community Renewables Testimony”), in order to consolidate all changes to Southern California

Edison Company’s Community Renewables Program, Exhibit SCE-3, served on March 21, 2014

(“Community Renewables Testimony”) into one document.

SCE is changing the witness designations from witness Robert Thomas to witnesses Amir

Angha and Brandi Anderson in certain portions of Chapter IV, Sections A and B. SCE made

changes to the table of contents to reflect these changes. Additionally, SCE corrected a

typographical error.

A redline identifying the changes in SCE’s Amended Community Renewables Testimony

compared to SCE’s Community Renewables Testimony is included as Appendix B.

1

I. 1

INTRODUCTION 2

On January 10, 2014, Southern California Edison Company (“SCE”) filed an application 3

(“Application”) requesting California Public Utilities Commission (“Commission” or “CPUC”) 4

approval of an optional green rate (the “Green Rate”).1 SCE’s proposed Green Rate complies 5

with Senate Bill (“SB”) 43’s requirement that electrical corporations with 100,000 or more 6

customer accounts in California request Commission approval to administer a green tariff shared 7

renewables program.2 In particular, the Green Rate will expand customers’ access to renewable 8

generation by allowing SCE’s Bundled Service customers to voluntarily subscribe to receive 9

either 50 or 100 percent of their electricity from a portfolio of eligible renewable resources. 10

SB 43 also states that “[a] participating utility shall provide support for enhanced 11

community renewables programs to facilitate development of eligible renewable energy resource 12

projects located close to the source of demand.”3 To implement this statutory provision, SCE 13

proposes to offer an enhanced community renewables program called the Community 14

Renewables program. The Community Renewables program will further increase customers’ 15

renewable energy options by allowing SCE’s Bundled Service customers to subscribe to a share 16

of a specific renewable generating facility to be built in SCE’s service territory, and to receive a 17

bill credit from SCE based on their subscription to that facility’s production. 18

1 SCE concurrently served its Prepared Testimony of Southern California Edison Company in Support

of Application for Approval of Optional Green Rate, Exhibit SCE-1 (“Prepared Testimony”), which was subsequently amended in the Amendments to Prepared Testimony of Southern California Edison Company in Support of Application for Approval of Optional Green Rate, Exhibit SCE-2, served March 11, 2014. Any citations to SCE’s Prepared Testimony refer to the testimony as amended.

2 See Cal. Pub. Util. Code §§ 2832(a), 2833(a).

3 Id. § 2833(o)

2

Under the Community Renewables program, SCE’s Bundled Service customers may 1

enter into agreements with renewable developers, communities, or other entities developing local 2

distributed renewable projects (“community renewables providers”) to subscribe to a portion of 3

the output of a renewable project (“community renewables facility”). These agreements could 4

take a variety of forms. For example, a customer could buy a share in a solar facility by 5

purchasing a number of solar panels. The agreement could also provide for a per kilowatt-hour 6

(“kWh”) charge or a monthly payment by the customer. The community renewables provider 7

would fund the development of the community renewables facility from the payments received 8

through customer subscriptions or with other funding sources obtained by the provider. Thus, 9

customers would directly support the development of new renewable projects within SCE’s 10

service territory. SCE would not be a party to the agreement between the customer and the 11

community renewables provider. Nor would SCE dictate the terms and conditions of that 12

transaction, or play any role in marketing community renewables facilities, agreement structures, 13

or community renewables providers to customers. 14

Community renewables providers developing renewable generating facilities that meet 15

the requirements of the Community Renewables program will be able to enter into a Community 16

Renewables agreement with SCE. This agreement will not be a renewable power purchase 17

agreement, but will instead provide that SCE will act as scheduling agent and revenue 18

coordinator for the community renewables facility. The community renewables provider will be 19

responsible for providing information about customer subscriptions of its facility to SCE. 20

Community Renewables participating customers will remain SCE’s Bundled Service 21

customers. SCE will retain the obligation to procure energy on their behalf and serve their load. 22

Moreover, SCE will continue to bill participating customers under their otherwise applicable 23

3

tariff for their electricity usage. With respect to the participating customer’s share of the 1

community renewables facility’s production, however, the customer will receive a bill credit 2

based on the customer’s Class Average Retail Generation Rate. SCE will adjust this credit based 3

on several charges detailed herein in order to ensure non-participating customer indifference.4 4

Participating customers will also be charged an administrative fee. 5

As discussed below, SCE proposes to open the Community Renewables program to new 6

renewable facilities sized between 500 kilowatts (“kW”) and 3 megawatts (“MW”) (AC) that 7

will be located in SCE’s service territory and connected to SCE’s system, in addition to meeting 8

certain other eligibility requirements.5 As a pilot, SCE will offer up to 40 MW under the 9

Community Renewables program (“Community Renewables Cap”), released incrementally over 10

the course of the program, with the potential to expand that amount based on the initial response 11

to the program. SCE will close the Community Renewables program to new customer 12

enrollment on January 1, 2019, or when the Community Renewables Cap is met. 13

4 See Chapter IV of this testimony.

5 See Chapter III, Section C of this testimony.

4

II. 1

COMMUNITY RENEWABLES PROGRAM STRUCTURE 2

SCE’s proposed Community Renewables program involves relationships between three 3

different parties: the participating customer, the community renewables provider, and SCE. This 4

Chapter explains the relationships between each of these parties. 5

A. Relationship Between Participating Customer and Community Renewables 6

Provider 7

Under SCE’s Community Renewables program structure, a project developer, a 8

community, a local organization, or another entity planning to develop a new renewable 9

generating facility in SCE’s service territory has the option to market subscriptions in such 10

facility to customers. These community renewables providers may enter into an agreement with 11

a customer – or a group of customers – whereby the customers provide the renewable project’s 12

development funding through payment for subscriptions in the project. The subscribing 13

customer’s payment to the community renewables provider to fund the renewable project could 14

take several forms, including an upfront payment to fund “shares” of the facility, a per kWh 15

payment, or a monthly charge. Although SCE will establish eligibility requirements for 16

renewable facilities and customers participating in the Community Renewables program, SCE 17

will not be a party to the transactions between community renewables providers and customers, 18

and SCE will not control the terms of those agreements. 19

B. Relationship Between Community Renewables Provider and SCE 20

Subject to the terms and conditions of the Community Renewables program, SCE will 21

enter into Community Renewables agreements with community renewables providers 22

5

developing renewable generating facilities that meet the requirements of the program.6 A 1

Community Renewables agreement will not be a typical renewable power purchase agreement 2

obligating SCE to purchase the renewable energy produced by the facility. Rather, the 3

Community Renewables agreement will, among other things, provide for the following: 4

The community renewables facility will be obligated to maintain prudent 5

electrical operations and meet the requirements for facilities participating in the 6

Community Renewables program. 7

The community renewables provider will provide SCE with a list of customers to 8

receive bill credits based on the community renewables facility’s generation, 9

including the amount of each customer’s subscription (i.e., a portion of the 10

facility’s capacity). The community renewables provider will be responsible for 11

informing SCE of any changes to customer subscriptions, including subscription 12

terminations and transfers of subscriptions among customers. 13

SCE will provide scheduling agent and revenue coordinator services for the 14

community renewables facility, and will collect all revenue earned from sale of 15

the facility’s energy into the California Independent System Operator (“CAISO”) 16

energy market. Additionally, SCE will calculate the value associated with any 17

Resource Adequacy provided by the community renewables facility, using the 18

same methodology described for the Resource Adequacy Adjustment in 19

connection with SCE’s Green Rate.7 For all energy produced by the community 20

renewables facility that is subscribed by participating customers, SCE will retain 21


7 See Prepared Testimony at 20-21, 25-26.

6

the energy revenues earned from the sale of the associated energy and the 1

capacity revenues as calculated. For unsubscribed energy, SCE will pass the 2

energy revenues through to the community renewables provider. SCE will also 3

pass through a value associated with any unsubscribed Resource Adequacy, but 4

will structure this payment to ensure that the payment does not incent gaming of 5

the program by facilities seeking a lucrative Resource Adequacy payment. In 6

both cases, SCE will count any Resource Adequacy credit received toward its 7

total Resource Adequacy requirements. 8

The agreement will include monthly settling of the difference between: (1) the 9

revenues from the sale of the community renewables facility’s subscribed energy 10

and calculated capacity value as discussed above, and (2) the generation-related 11

credit provided to participating customers. If the energy revenues plus capacity 12

value exceed the credit, SCE will provide the difference to the community 13

renewables provider. If the credit exceeds the energy revenues and capacity 14

value, the community renewables provider will provide the difference to SCE. 15

The community renewables provider will provide SCE with all renewable energy 16

credits (“RECs”) associated with the community renewables facility’s generation 17

that has been subscribed by participating customers. SCE will retire all such 18

RECs on behalf of participating customers in a designated Western Renewable 19

Energy Generation Information System (“WREGIS”) Retirement Sub-Account 20

separate from those used to meet SCE’s Renewables Portfolio Standard (“RPS”) 21

compliance. The community renewables provider will retain any RECs 22

associated with the community renewables facility’s unsubscribed generation. 23

7

SCE will not count any Community Renewables program generation toward its 1

RPS requirements. 2

C. Relationship Between Participating Customer and SCE 3

Community Renewables participating customers will remain Bundled Service customers 4

of SCE. SCE will retain the obligation to procure energy to reliably serve their load. Likewise, 5

SCE will continue to schedule participating customers’ load into the CAISO energy market and 6

procure energy and capacity on their behalf. Furthermore, SCE will bill participating customers 7

under their otherwise applicable tariffs for all electricity usage. SCE will provide a bill credit 8

that is based on the customer’s Class Average Retail Generation Rate and commensurate to the 9

size of the participating customer’s Community Renewables program subscription. As discussed 10

in Chapter IV, SCE will adjust this credit by various charges (e.g., indifference adjustment) to 11

ensure non-participating customer indifference. Participating customers will also be charged a 12

fee for program administration. 13

As explained above, SCE will not count any renewable generation associated with a 14

participating customer’s subscription toward its RPS requirements, instead retiring the RECs on 15

the customer’s behalf in a designated WREGIS Retirement Sub-Account separate from those 16

used to meet SCE’s RPS targets. The kWh of Community Renewables participating customers’ 17

subscriptions, however, will be deducted from SCE’s bundled retail sales for the purpose of 18

calculating RPS procurement quantity requirements.8 19

8 See Cal. Pub. Util. Code § 2833(t).

8

III. 1

COMMUNITY RENEWABLES PROGRAM SCOPE AND REQUIREMENTS 2

A. Community Renewables Program Scope 3

In order to gain experience with the Community Renewables program and measure the 4

level of customer interest in the program, SCE proposes to begin the Community Renewables 5

program as a 40 MW pilot (i.e., the Community Renewables Cap). SCE plans to offer 10 MW in 6

the first year of the Community Renewables program, expected to be 2015, and then offer an 7

additional 10 MW in each year remaining until the program sunset date of January 1, 2019.9 8

Depending on the initial response to the Community Renewables program, SCE may file an 9

advice letter requesting to increase the capacity offered in the program. In any case, the total 10

subscriptions under the Green Rate and Community Renewables programs will be capped at 269 11

MW, which is SCE’s share of the statewide limitation of 600 MW.10 SCE will also reserve no 12

less than one-sixth of the combined Green Rate and Community Renewables program capacity 13

for participation by residential customers and one-sixth of the combined program capacity for 14

renewable generating facilities that are no larger than 1 MW that are located in areas previously 15

identified by the California Environmental Protection Agency as the most impacted and 16

disadvantaged communities. 11 17

Similar to the Green Rate, SCE proposes to begin offering the Community Renewables 18

program no later than 12 months after Commission approval of SCE’s Application. SCE plans 19

to launch the Community Renewables program in 2015, and will close the program to new 20

9 See Cal. Pub. Util. Code § 2834.

10 See Prepared Testimony at 8, 33-34.

11 See Cal. Pub. Util. Code §§ 2833(d)(1)-(2).

9

customer enrollment on January 1, 2019, or when the Community Renewables Cap is reached. 1

Participating customers already subscribed to the Community Renewables program when 2

enrollment is closed to new customers may remain in the program past this date, and may 3

transfer their subscriptions to other participating customers already subscribed to the program. 4

However, they may not enter into a new agreement with a community renewables facility past 5

this date. 6

SCE cannot make any adoption assumptions for the Community Renewables program at 7

this time. Because of the limited number of active community renewables programs available 8

nationally – particularly in cases where they serve as an additional green option to other green 9

rates offered by the same load-serving entity – SCE does not have sufficient data to gauge 10

estimated customer enrollment. For instance, the National Renewable Energy Laboratory’s 11

(“NREL”) “Status and Trends in the US Voluntary Green Power Market” cites only 14 MW of 12

total community renewables capacity in the United States as of June 2013, which translates to 13

estimated energy sales of less than one percent of national green rate utility sales seen in 2012.12 14

Furthermore, SCE will not dictate the pricing terms between the community renewables provider 15

and the participating customer, which makes it difficult to assess the level of customer interest. 16

B. Community Renewables Participating Customer Requirements 17

All of SCE’s Bundled Service customers are eligible to participate in the Community 18

Renewables program. However, SCE reserves the right to exclude Bundled Service customers 19

12 See J. Heeter and T. Nicholas, NREL, Status and Trends in the U.S. Voluntary Green Power Market

(2012 Data) at 35 (October 2013) (available at: http://www.nrel.gov/docs/fy14osti/60210.pdf), assuming a 40 percent capacity factor applied to full generation running 8,760 hours per year. National data from the U.S. Energy Information Administration’s (“EIA”) Form EIA-861, released December 2013 (available at: http://www.eia.gov/electricity/data/eia861/index.html), reflects approximately 7.6 million megawatt-hours of 2012 sales.

10

served on rates that may significantly raise implementation costs (as determined during the 1

implementation phase), provided there is not a demonstrated interest in participating in the 2

Community Renewables program by those customer groups that is high enough to justify the 3

additional costs. 4

Under their agreement with a community renewables provider, participating customers 5

may subscribe to a portion of a community renewables facility’s capacity (i.e., a kW share of the 6

facility). Participating customers will be required to size their subscription to not exceed their 7

average annual electrical usage requirements.13 A participating customer may only have one 8

Community Renewables subscription at any given time. SCE will also track subscriptions per 9

customer in both the Green Rate and Community Renewables programs to ensure that 10

subscriptions comply with Public Utilities Code Sections 2833(h) and 2833(i). 11

A participating customer will not begin receiving bill credits under the Community 12

Renewables program until the community renewables facility in which the customer has a 13

subscription meets the requirements of the program14 and begins delivering energy. SCE does 14

not intend to require any minimum duration for participation in the Community Renewables 15

program. Nonetheless, SCE expects that many customers will pay for their subscriptions upfront 16

or enter into long-term agreements with community renewables providers, and will therefore 17

participate in the program for a number of years. If a participating customer moves to a new 18

location within SCE’s service territory, the customer may maintain its subscription (so long as it 19

is still sized appropriately to the customer’s load). A participating customer could also transfer 20

its subscription in a community renewables facility to another party (e.g., if the customer moves 21

13 See Cal. Pub. Util. Code § 2833(g). To translate between subscriptions, in kW, and monthly usage, in

kWh, SCE will use a typical community renewables facility’s capacity factor.


11

out of SCE’s service territory or loses interest in the program), assuming that is permitted in the 1

agreement between the customer and the community renewables provider. Transfers will be 2

limited by any restrictions on new customer enrollment in the Community Renewables program. 3

Furthermore, subject to the requirements of both programs, customers may participate in both the 4

Green Rate and the Community Renewables program or transfer between the two programs. 5

C. Community Renewables Facility Requirements 6

SCE will open the Community Renewables program to new renewable generating 7

facilities sized between 500 kW and 3 MW (AC) that will be located in SCE’s service territory 8

and connected to SCE’s system.15 As explained above, SCE will reserve one-sixth of the total 9

Green Rate and Community Renewables capacity for generating facilities that are sized no larger 10

than 1 MW that are located in the most impacted and disadvantaged communities.16 11

SCE will also impose other minimum requirements on community renewables facilities 12

to help ensure accurate scheduling and planning, as well as to increase the potential viability of 13

participating facilities. Such requirements may include, but are not limited to: 14

Installation of telemetry equipment. 15

Installation of CAISO and SCE revenue meters. 16

Either (1) System Impact Study, (2) a Phase I Interconnection Study, (3) 17

documentation demonstrating that the project has passed Fast Track screens, or 18

(4) the equivalent or better. 19

Proof of site control and application for permits. 20

15 Such renewable facilities must qualify as eligible renewable energy resources under Public Utilities

Code Section 399.12(e) and comply with the State Air Resources Board’s Voluntary Renewable Electricity Program. See Cal. Pub. Util. Code §§ 2833(b), 2833(u).

16 See id. § 2833(d)(1).

12

Proof of developer experience and technology commercialization. 1

Proof of significant participating customer interest. 2

As soon as the Community Renewables program is operational, community renewables 3

providers developing eligible community renewables facilities may apply to participate in the 4

program. SCE will accept facilities on a first-come, first-served basis subject to the limitations 5

on the program. SCE will require community renewables facilities to achieve commercial 6

operation within 24 months after being accepted to the program to ensure that community 7

renewables providers do not “reserve” capacity under the program for facilities that never 8

achieve commercial operation. 9

13

IV. 1

COMMUNITY RENEWABLES RATE DESIGN 2

A. Generation Credit Components 3

Under the Community Renewables program, participating customers will continue to pay 4

all normal bill charges for their electricity usage based on their otherwise applicable tariff. 5

However, participating customers will also receive a bill credit for their subscription to a specific 6

community renewables facility. The customer’s kW subscription in the facility will be converted 7

to a kWh number based on the facility’s generation. The generation credit will be equal to the 8

customer’s Class Average Retail Generation Rate minus three adjustments. The generation 9

credit and adjustments are also used in SCE’s proposed Green Rate.17 10

1. Class Average Retail Generation Rate 11

A unique Class Average Retail Generation Rate will be established for each rate 12

class and will represent the class’s average rate for generation energy and capacity. Each 13

Community Renewables participating customer will be credited the rate for the class to which 14

the customer belongs for each kWh-equivalent of the customer’s subscription.18 SCE will update 15

the Class Average Retail Generation Rates in each Energy Resource Recovery Account 16

(“ERRA”) forecast proceeding to capture the generation revenue requirement and sales forecast 17

changes reflected in retail rates. 18

17 SCE will not apply all charges and adjustments proposed in the Green Rate to the Community

Renewables program. In particular, the Time-of-Delivery and Resource Adequacy Adjustments are not necessary because they will be captured by the value of the customer’s subscribed energy and capacity as it is sold in the CAISO market and valued for Resource Adequacy purposes.

18 For many customers, this credit will not be equal to their generation rate because many rates are variable with time of use, amount of usage, and other factors.

14

2. Adjustments 1

a) Indifference Adjustment 2

The generation credit provided to Community Renewables participating 3

customers will be reduced by an Indifference Adjustment. The Indifference Adjustment will 4

consist of the Power Charge Indifference Adjustment (“PCIA”) and the Competitive Transition 5

Charge (“CTC”). SCE determines the PCIA and CTC in each ERRA forecast proceeding 6

pursuant to Decision (“D.”) 11-12-018 and Resolution E-4475. Each participating customer will 7

be assigned an Indifference Adjustment schedule vintage based on the year they first take service 8

under the Community Renewables program subscription. 9

b) Resource Adequacy Charge 10

A participating customer’s generation credit will be decreased by the costs 11

incurred by SCE to ensure sufficient Resource Adequacy capacity to meet Resource Adequacy 12

compliance requirements for the customer’s Community Renewables program subscription. The 13

Commission’s Resource Adequacy compliance program requires a 15 percent reserve margin on 14

load, which means that SCE will need to procure Resource Adequacy for 115 percent of each 15

kW subscribed to the Community Renewables program. Accordingly, the Resource Adequacy 16

Charge will be determined by multiplying 115 percent by the Resource Adequacy price adopted 17

per the Cost Responsibility Surcharge.19 The Resource Adequacy Charge will be updated as 18

necessary in each ERRA forecast proceeding. 19

19 This Resource Adequacy price is currently $50.17 per kW-year, or roughly 0.5727 cents per kWh.

See Resolution E-4475 at Ordering Paragraph 2.

15

c) Renewable Integration and Market Participation Charge 1

The Renewable Integration and Market Participation Charge will also 2

decrease a participating customer’s generation credit. The Renewable Integration Charge will 3

include any Commission-approved charge or adder associated with the increased costs imposed 4

on the grid due to the increasing integration of renewable resources.20 The Market Participation 5

Charge will include scheduling charges based on the CAISO tariffs and forecasted SCE 6

scheduling costs for Community Renewables program generation. Additionally, the Market 7

Participation Charge will include the charges assessed by WREGIS to create and voluntarily 8

retire RECs associated with Community Renewables program generation. Like the other 9

generation credit components, the Renewable Integration and Market Participation Charge will 10

be updated as necessary in each ERRA forecast proceeding. 11

B. Program Administration Charge 12

Independent of the generation credit for Community Renewables participating customers, 13

SCE will assess a Program Administration Charge on participating customers. SCE will collect 14

all costs of outreach and administration of the Community Renewables program through the 15

Program Administration Charge. The Program Administration Charge will help to ensure 16

compliance with the statutory requirement that non-participating customers are held indifferent 17

to the Community Renewables program.21 SCE will assess, and, if necessary, update the 18

Program Administration Charge annually in the ERRA forecast proceeding in keeping with the 19

cost recovery schedule and process outlined for the Green Rate program. 20

20 The Commission has not yet approved a non-zero charge or adder.

21 While SCE currently proposes to recover these costs solely through a volumetric charge, SCE reserves the right to introduce a fixed charge should that serve program cost recovery purposes.

16

C. Balance of Payments in the Community Renewables Program 1

Table IV-1 below shows the flow of payments under the Community Renewables 2

program, assuming that the community renewables facility is fully subscribed. These payments 3

are designed to ensure that non-participating customers are indifferent to the Community 4

Renewables program, and that participating customers receive the benefit of their Community 5

Renewables program subscription. Table IV-1 only shows energy-related payments. Because a 6

participating customer continues to pay all charges under their otherwise applicable tariff, the 7

customer will continue to pay its share of transmission, distribution, public purpose, and other 8

charges. 9

Table IV-1 Balance of Payments in the Community Renewables Program

Customer SCE Provider Market

Bundled Energy Service -E E

Generation Credit G -G

Class Average Gen Cost

Indifference Adjustment

Resource Adequacy Charge Renewables Integration & Market Participation Charge

Market Revenues

Renewable Energy and Capacity Value R -R Facility balance of payment [G-R] -[G-R]

Renewable Development Cost -C C

Administrative Charges -A A

E: SCE serves all of the customer’s energy needs, and charges the customer for 10

this through their normal billing process. 11

G: SCE provides the customer a credit based on the Class Average Retail 12

Generation Rate for every kWh associated with the customer’s Community 13

17

Renewables program subscription. This credit is adjusted by three primary 1

charges, as described above. 2

R: SCE delivers the community renewables facility’s energy to the CAISO 3

market. SCE then receives revenues from the CAISO market associated with 4

selling this energy, and calculates revenue associated with the Resource 5

Adequacy value provided. This revenue helps offset the generation credit (“G”) 6

that has been provided to customers. 7

[G-R]: The generation credit (“G”), including the three primary adjustments, that 8

SCE provides to customers may differ from the revenue received from the sale of 9

the energy and the calculated capacity value (“R”).22 This difference will be 10

settled by a balance of payments agreement between SCE and the community 11

renewables provider. 12

C: The customer will pay the community renewables provider payment for the 13

customer’s subscription. 14

A: SCE will recover administrative costs from participating customers to ensure 15

that non-participating customers are indifferent to the Community Renewables 16

program.17

22 If the community renewables facility is located in a high-load area and delivers during high-value

time-of-delivery periods, for example, the energy from the facility would likely earn more revenue in the CAISO market. This revenue may exceed the generation credit provided to customers (i.e., G-S is negative), in which case SCE would provide this excess to the community renewables provider. If, however, the revenue is less than the generation credit provided to customers (G-S is positive), SCE would receive the balance from the community renewables provider.

18

V. 1

COMMUNITY RENEWABLES EDUCATION AND OUTREACH 2

When appropriate, SCE plans to leverage the same education, and outreach channels 3

proposed for the Green Rate (e.g., SCE’s website) for its Community Renewables program to 4

better educate customers about their options. Messaging related to SCE’s Community 5

Renewables program will largely focus on educating interested customers about the program, its 6

differences from other rates and options, and the specific requirements and constraints involved 7

with participation. SCE will not directly market specific community renewables facilities, 8

agreement structures, or community renewables providers to customers. As with the Green Rate, 9

all of SCE’s Community Renewables education and outreach activities will adhere to the Code 10

of Conduct governing the treatment of community choice aggregators by investor-owned 11

utilities.23 12

23 See Prepared Testimony at 48.

19

VI. 1

COMMUNITY RENEWABLES COST RECOVERY 2

SCE’s Application and Prepared Testimony set forth SCE’s proposal to establish a new 3

Green Rate Balancing Account (“GRBA”) to record the difference between the actual revenues 4

collected from Green Rate participants in the form of the Green Rate Charge and the actual 5

Green Rate revenue requirements (based on recorded costs reflecting all incremental operations 6

and maintenance, purchased power-related, and capital expenditures related to Green Rate 7

program activities).24 SCE proposes to use the same structure for the Community Renewables 8

program. Some education and outreach, implementation, and administrative costs may be 9

distributed to both Green Rate and Community Renewables participating customers through the 10

Program Administration Charge for each program. Other such costs may be allocated only to 11

Green Rate participating customers or only to Community Renewables participating customers, 12

in each case through the Program Administration Charge for the specific program. 13

The revenues collected from Community Renewables participating customers through the 14

Program Administration Charge, and all recorded education, outreach, and administrative costs 15

incurred for the Community Renewables Program, will be accounted for in the GRBA. The 16

operation of the GRBA will ensure that no more and no less than the actual education, outreach, 17

and administrative costs are ultimately collected from participating customers and that non-18

participating customers are held indifferent to the Community Renewables program. 19

24 See Prepared Testimony at 50-58. Similar to SCE’s other balancing and memorandum accounts, the

operation of the GRBA will be subject to audit and review to ensure that all entries to the account are stated correctly and are consistent with Commission decision(s).

20

As explained in SCE’s Prepared Testimony with respect to the Green Rate,25 SCE 1

proposes to amortize the total education, outreach, and administrative costs forecast over all 2

customers’ kWh subscriptions for the life of the offering, projected to be 2015-2018. Since the 3

proposed Program Administration Charge will amortize the forecast costs over the life of the 4

offering, this charge may be reset in SCE’s annual ERRA Forecast proceedings to account for 5

any prior over- or under-collection of education, outreach, and administrative costs by adjusting 6

the amortization of the remaining uncollected costs through January 1, 2019.7

25 See id. at 57.

21

VII. 1

BENEFITS OF SCE’S COMMUNITY RENEWABLES PROGRAM DESIGN 2

SCE’s Community Renewables program design provides benefits to participating 3

customers, community renewables providers, and non-participating customers. 4

SCE’s proposed program provides support for community renewables: 5

Allows participating customers to support the development of a specific local 6

community renewables facility. 7

Enables participating customers to directly contract with community renewables 8

providers and to structure their subscription in a variety of ways. 9

Provides a mechanism for participating customers to establish a long-term 10

financial commitment in renewable resources that will allow the customer to 11

reduce exposure to changing electricity market prices. 12

Ensures that participating customers remain SCE’s Bundled Service customers 13

with continued access to reliable electricity service. 14

Utilizes existing operational and administrative mechanisms to ensure that 15

administration costs are minimized. 16

SCE’s proposed program facilitates development of eligible renewable resources: 17

Provides an opportunity for community renewables providers to directly market 18

their proposed renewable projects to SCE’s Bundled Service customers. 19

Allows for community renewables providers to receive project funding through 20

customer subscriptions without competing against other renewable projects for a 21

power purchase agreement. 22

22

Utilizes SCE’s expertise as a scheduling agent and revenue coordinator with the 1

CAISO market, reducing operational burdens for the community renewables 2

provider. 3

Finally, SCE’s proposed program benefits non-participating customers by: 4

Ensuring that no Community Renewables program costs are shifted to non-5

participating customers. 6

Avoiding situations where non-participating customers are responsible for the 7

costs of long-term power purchase agreements if Community Renewables 8

participating customers depart from the program or projects do not achieve full 9

subscription. 10

SCE’s Community Renewables Program is reasonable and consistent with the legislative 11

findings and statements of intent of SB 43.26 In particular, the Community Renewables program 12

offers customers the opportunity to subscribe to a specific new community renewables facility 13

located in SCE’s service territory and receive a bill credit from SCE based on their subscription 14

to that facility’s production. Accordingly, the Community Renewables program will advance the 15

goal of building renewable generating facilities that will supply the State’s demand for 16

electricity, and provide financial, health, environmental, and workforce benefits, create jobs, 17

reduce emissions of greenhouse gases, and promote energy independence.27 The Community 18

Renewables Program will also offer customers (including large institutional customers and 19

public institutions) who may not be able to develop or own onsite generation or achieve their 20

own renewable energy goals the opportunity to subscribe to community renewables facilities that 21

26 See Cal. Pub. Util. Code §§ 2831, 2832(c).

27 See id. §§ 2831(a), 2831(e).

23

are additional to the State’s RPS targets.28 This will help to facilitate a sustainable market for 1

offsite renewable generation facilities.29 Further, SCE’s Community Renewables program 2

includes rate design and cost recovery requirements to allow participating customers benefit 3

from their subscriptions while ensuring non-participating customer indifference.30 4

28 See id. §§ 2831(b)-(d), 2831(f).

29 See id. § 2831(g).

30 See id. § 2831(h).

24

VIII. 1

COMPARISON OF COMMUNITY RENEWABLES AND GREEN RATE PROGRAMS 2

SCE’s Community Renewables and Green Rate programs share many similarities. 3

Notably, the programs will utilize very similar generation credits and adjustments. Table VIII-2 4

below provides a comparison of SCE’s Green Rate and Community Renewables programs. 5

25

Table VIII-2 Comparison of SCE’s Green Rate and Community Renewables Programs

Program Component

SCE Green Rate SCE Community Renewables

Offering Program Name Green Rate Community Renewables

Program Start 2015 2015

Combined: Maximum of 269 MW Community Renewables is 40 MW pilot

Program End Sunset date Jan 1, 2019 Sunset date Jan 1, 2019

Customer Subscriptions, Eligibility, and

Enrollment

Subscription Levels Two levels: 50% and 100% Subscription must be sized to customer load

Subscription Length Requirements

None (no exit fees) None (no exit fees); subscriptions are transferable between SCE customers

Eligible Customers All Bundled Service customers All Bundled Service customers

Enrollment Channels

Targeting online enrollment; will also provide call center support, customer representative support, and a paper

option

Targeting online enrollment; will also provide call center support, customer representative support, and a paper

option Rate Design Procurement

Charge Average of Green Rate Portfolio

contract prices None; customer will pay separate charge

to generator Administrative

Charges Volumetric; all costs amortized over

customers’ subscriptions until program sunset date

All costs amortized over customers’ subscriptions until program sunset date

Additional Charges Integration charges (including WREGIS / CAISO fees), indifference

charges, RA charges

Integration charges (including WREGIS / CAISO fees), indifference

charges, RA charges Generation Credit Class-average cost of energy and

capacity, adjusted for any renewable value and TOD value

Class-average cost of energy and capacity, adjusted for additional charges

listed above Procurement Eligible Generators Renewable resources 20 MW and

below, located in California Renewable resources sized 500 kW to 3 MW, located in SCE’s service territory

and connected to SCE’s system CalEPA Set-Aside Combined: Portion of 100 MW, as determined using 2013 RPS Compliance Reports

Procurement for Green Rate

Portfolio-based approach, whereby kWh are drawn from eligible projects already in SCE’s portfolio to serve Green Rate

subscriptions

None, customer will initiate contact with community renewables provider

REC Retirement All RECs retired on behalf of participating customers; RECs not used for RPS compliance

All RECs retired on behalf of participating customers; RECs not used

for RPS compliance Marketing,

Education, and Outreach

Overall Marketing, Education, and

Outreach

Leveraging low-cost channels (no mass media), targeted at those most likely to

adopt

Leveraging low-cost channels to educate customers about their

Community Renewable options Low Income Marketing,

Education, and Outreach

All residential marketing (plus translation); additionally, grassroots

outreach through minority- and community-based organizations

Educate customers about their Community Renewables options

Cost Recovery Cost Recovery Proposal

Establish Green Rate Balancing Account to record and recover all costs

of program from Green Rate subscribers

Establish Green Rate Balancing Account to record and recover all costs

of program from Community Renewables subscribers

Appendix A

Witness Qualifications

A-1

SOUTHERN CALIFORNIA EDISON COMPANY 1

QUALIFICATIONS AND PREPARED TESTIMONY 2

OF BRANDI M. ANDERSON 3

Q. Please state your name and business address for the record. 4

A. My name is Brandi Anderson, and my business address is 1515 Walnut Grove Avenue, Rosemead, 5

California 91770. 6

Q. Briefly describe your present responsibilities at Southern California Edison Company (“SCE”). 7

A. I am a Manager in the Customer Programs and Services division of SCE’s Customer Service 8

Business Unit. I am responsible for the design, development and implementation of customer 9

programs and services. 10

Q. Briefly describe your educational and professional background. 11

A. I earned a Bachelor of Arts Degree from the University of California, San Diego and a Master of 12

Business Administration Degree from the University of California, Los Angeles. I have worked at 13

SCE for 20 years in a variety of leadership and project management positions in Consumer Affairs, 14

Customers Service Operations, Customer Program Development, Transmission and Distribution, 15

Business Planning, and Employee Training. 16

Q. What is the purpose of your testimony in this proceeding? 17

A. The purpose of my testimony in this proceeding is to sponsor portions of Southern California Edison 18

Company’s Community Renewables Program, Exhibit SCE-3, as identified in the Table of Contents 19

thereto. 20

Q. Was this material prepared by you or under your supervision? 21

A. Yes, it was. 22

Q. Insofar as this material is factual in nature, do you believe it to be correct? 23

A-2

A. Yes, I do. 1

Q. Insofar as this material is in the nature of opinion or judgment, does it represent your best judgment? 2

A. Yes, it does. 3

Q. Does this conclude your qualifications and prepared testimony? 4

A. Yes, it does.5

Appendix B

Redline of Amended Community Renewables Program in Comparison to Community

Renewables Program

Application No.: A.12-01-008/A.12-04-020/14-01-007 (Consolidated)

Exhibit No.: SCE-35 Witnesses: Kathleen Sloan

Brandi Anderson Amir Angha Robert Thomas Jessica Lim Douglas Snow

(U 338-E)

AMENDED SOUTHERN CALIFORNIA EDISON

COMPANY’S COMMUNITY RENEWABLES

PROGRAM

Before the

Public Utilities Commission of the State of California

Rosemead, California

March 21,April 11, 2014


Table Of Contents


i

I. INTRODUCTION .............................................................................................1 K. Sloan

II. COMMUNITY RENEWABLES PROGRAM STRUCTURE .........................4

A. Relationship Between Participating Customer and Community Renewables Provider .........................................................4

B. Relationship Between Community Renewables Provider and SCE .................................................................................................4

C. Relationship Between Participating Customer and SCE .......................7

III. COMMUNITY RENEWABLES PROGRAM SCOPE AND REQUIREMENTS .............................................................................................8 B. Anderson

A. Community Renewables Program Scope...............................................8

B. Community Renewables Participating Customer Requirements .........................................................................................9

C. Community Renewables Facility Requirements ..................................11 A. Angha

IV. COMMUNITY RENEWABLES RATE DESIGN .........................................13 R. Thomas

A. Generation Credit Components ............................................................13

1. Class Average Retail Generation Rate .....................................13

2. Adjustments .............................................................................14

a) Indifference Adjustment ..............................................14

b) Resource Adequacy Charge .........................................14 A. Angha

c) Renewable Integration and Market Participation Charge.................................................1415

B. Program Administration Charge ..........................................................15 B. Anderson

C. Balance of Payments in the Community Renewables Program ............................................................................................1516 K. Sloan

V. COMMUNITY RENEWABLES EDUCATION AND OUTREACH ....................................................................................................18 J. Lim


Table Of Contents (Continued)


ii

VI. COMMUNITY RENEWABLES COST RECOVERY ...................................19 D. Snow

VII. BENEFITS OF SCE’S COMMUNITY RENEWABLES PROGRAM DESIGN ......................................................................................21 K. Sloan

VIII. COMPARISON OF COMMUNITY RENEWABLES AND GREEN RATE PROGRAMS ..........................................................................24

Appendix A Witness Qualifications

Appendix B Redline of Amended Community Renewables Program in Comparison to Community Renewables Program


List Ofof Tables

Table Page

iii iii

Table IV-1 Balance of Payments in the Community Renewables Program ..............................................16

Table VIII-2 Comparison of SCE’s Green Rate and Community Renewables

Programs ....................................................................................................................................................25

iv

Southern California Edison Company (“SCE”) is serving this Amended Southern

California Edison Company’s Community Renewables Program, Exhibit SCE-5 (“Amended

Community Renewables Testimony”), in order to consolidate all changes to Southern California

Edison Company’s Community Renewables Program, Exhibit SCE-3, served on March 21, 2014

(“Community Renewables Testimony”) into one document.

SCE is changing the witness designations from witness Robert Thomas to witnesses Amir

Angha and Brandi Anderson in certain portions of Chapter IV, Sections A and B. SCE made

changes to the table of contents to reflect these changes. Additionally, SCE corrected a

typographical error.

A redline identifying the changes in SCE’s Amended Community Renewables Testimony

compared to SCE’s Community Renewables Testimony is included as Appendix B.

1

I. 1

INTRODUCTION 2

On January 10, 2014, Southern California Edison Company (“SCE”) filed an application 3

(“Application”) requesting California Public Utilities Commission (“Commission” or “CPUC”) 4

approval of an optional green rate (the “Green Rate”).1 SCE’s proposed Green Rate complies 5

with Senate Bill (“SB”) 43’s requirement that electrical corporations with 100,000 or more 6

customer accounts in California request Commission approval to administer a green tariff shared 7

renewables program.2 In particular, the Green Rate will expand customers’ access to renewable 8

generation by allowing SCE’s Bundled Service customers to voluntarily subscribe to receive 9

either 50 or 100 percent of their electricity from a portfolio of eligible renewable resources. 10

SB 43 also states that “[a] participating utility shall provide support for enhanced 11

community renewables programs to facilitate development of eligible renewable energy resource 12

projects located close to the source of demand.”3 To implement this statutory provision, SCE 13

proposes to offer an enhanced community renewables program called the Community 14

Renewables program. The Community Renewables program will further increase customers’ 15

renewable energy options by allowing SCE’s Bundled Service customers to subscribe to a share 16

of a specific renewable generating facility to be built in SCE’s service territory, and to receive a 17

bill credit from SCE based on their subscription to that facility’s production. 18

1 SCE concurrently served its Prepared Testimony of Southern California Edison Company in Support

of Application for Approval of Optional Green Rate, Exhibit SCE-1 (“Prepared Testimony”), which was subsequently amended in the Amendments to Prepared Testimony of Southern California Edison Company in Support of Application for Approval of Optional Green Rate, Exhibit SCE-2, served March 11, 2014. Any citations to SCE’s Prepared Testimony refer to the testimony as amended.

2 See Cal. Pub. Util. Code §§ 2832(a), 2833(a).

3 Id. § 2833(o).

2

Under the Community Renewables program, SCE’s Bundled Service customers may 1

enter into agreements with renewable developers, communities, or other entities developing local 2

distributed renewable projects (“community renewables providers”) to subscribe to a portion of 3

the output of a renewable project (“community renewables facility”). These agreements could 4

take a variety of forms. For example, a customer could buy a share in a solar facility by 5

purchasing a number of solar panels. The agreement could also provide for a per kilowatt-hour 6

(“kWh”) charge or a monthly payment by the customer. The community renewables provider 7

would fund the development of the community renewables facility from the payments received 8

through customer subscriptions or with other funding sources obtained by the provider. Thus, 9

customers would directly support the development of new renewable projects within SCE’s 10

service territory. SCE would not be a party to the agreement between the customer and the 11

community renewables provider. Nor would SCE dictate the terms and conditions of that 12

transaction, or play any role in marketing community renewables facilities, agreement structures, 13

or community renewables providers to customers. 14

Community renewables providers developing renewable generating facilities that meet 15

the requirements of the Community Renewables program will be able to enter into a Community 16

Renewables agreement with SCE. This agreement will not be a renewable power purchase 17

agreement, but will instead provide that SCE will act as scheduling agent and revenue 18

coordinator for the community renewables facility. The community renewables provider will be 19

responsible for providing information about customer subscriptions of its facility to SCE. 20

Community Renewables participating customers will remain SCE’s Bundled Service 21

customers. SCE will retain the obligation to procure energy on their behalf and serve their load. 22

Moreover, SCE will continue to bill participating customers under their otherwise applicable 23

3

tariff for their electricity usage. With respect to the participating customer’s share of the 1

community renewables facility’s production, however, the customer will receive a bill credit 2

based on the customer’s Class Average Retail Generation Rate. SCE will adjust this credit based 3

on several charges detailed herein in order to ensure non-participating customer indifference.4 4

Participating customers will also be charged an administrative fee. 5

As discussed below, SCE proposes to open the Community Renewables program to new 6

renewable facilities sized between 500 kilowatts (“kW”) and 3 megawatts (“MW”) (AC) that 7

will be located in SCE’s service territory and connected to SCE’s system, in addition to meeting 8

certain other eligibility requirements.5 As a pilot, SCE will offer up to 40 MW under the 9

Community Renewables program (“Community Renewables Cap”), released incrementally over 10

the course of the program, with the potential to expand that amount based on the initial response 11

to the program. SCE will close the Community Renewables program to new customer 12

enrollment on January 1, 2019, or when the Community Renewables Cap is met. 13

4 See Chapter IV of this testimony.


4

II. 1

COMMUNITY RENEWABLES PROGRAM STRUCTURE 2

SCE’s proposed Community Renewables program involves relationships between three 3

different parties: the participating customer, the community renewables provider, and SCE. This 4

Chapter explains the relationships between each of these parties. 5

A. Relationship Between Participating Customer and Community Renewables 6

Provider 7

Under SCE’s Community Renewables program structure, a project developer, a 8

community, a local organization, or another entity planning to develop a new renewable 9

generating facility in SCE’s service territory has the option to market subscriptions in such 10

facility to customers. These community renewables providers may enter into an agreement with 11

a customer – or a group of customers – whereby the customers provide the renewable project’s 12

development funding through payment for subscriptions in the project. The subscribing 13

customer’s payment to the community renewables provider to fund the renewable project could 14

take several forms, including an upfront payment to fund “shares” of the facility, a per kWh 15

payment, or a monthly charge. Although SCE will establish eligibility requirements for 16

renewable facilities and customers participating in the Community Renewables program, SCE 17

will not be a party to the transactions between community renewables providers and customers, 18

and SCE will not control the terms of those agreements. 19

B. Relationship Between Community Renewables Provider and SCE 20

Subject to the terms and conditions of the Community Renewables program, SCE will 21

enter into Community Renewables agreements with community renewables providers 22

5

developing renewable generating facilities that meet the requirements of the program.6 A 1

Community Renewables agreement will not be a typical renewable power purchase agreement 2

obligating SCE to purchase the renewable energy produced by the facility. Rather, the 3

Community Renewables agreement will, among other things, provide for the following: 4

The community renewables facility will be obligated to maintain prudent 5

electrical operations and meet the requirements for facilities participating in the 6

Community Renewables program. 7

The community renewables provider will provide SCE with a list of customers to 8

receive bill credits based on the community renewables facility’s generation, 9

including the amount of each customer’s subscription (i.e., a portion of the 10

facility’s capacity). The community renewables provider will be responsible for 11

informing SCE of any changes to customer subscriptions, including subscription 12

terminations and transfers of subscriptions among customers. 13

SCE will provide scheduling agent and revenue coordinator services for the 14

community renewables facility, and will collect all revenue earned from sale of 15

the facility’s energy into the California Independent System Operator (“CAISO”) 16

energy market. Additionally, SCE will calculate the value associated with any 17

Resource Adequacy provided by the community renewables facility, using the 18

same methodology described for the Resource Adequacy Adjustment in 19

connection with SCE’s Green Rate.7 For all energy produced by the community 20

renewables facility that is subscribed by participating customers, SCE will retain 21


7 See Prepared Testimony at 20-21, 25-26.

6

the energy revenues earned from the sale of the associated energy and the 1

capacity revenues as calculated. For unsubscribed energy, SCE will pass the 2

energy revenues through to the community renewables provider. SCE will also 3

pass through a value associated with any unsubscribed Resource Adequacy, but 4

will structure this payment to ensure that the payment does not incent gaming of 5

the program by facilities seeking a lucrative Resource Adequacy payment. In 6

both cases, SCE will count any Resource Adequacy credit received toward its 7

total Resource Adequacy requirements. 8

The agreement will include monthly settling of the difference between: (1) the 9

revenues from the sale of the community renewables facility’s subscribed energy 10

and calculated capacity value as discussed above, and (2) the generation-related 11

credit provided to participating customers. If the energy revenues plus capacity 12

value exceed the credit, SCE will provide the difference to the community 13

renewables provider. If the credit exceeds the energy revenues and capacity 14

value, the community renewables provider will provide the difference to SCE. 15

The community renewables provider will provide SCE with all renewable energy 16

credits (“RECs”) associated with the community renewables facility’s generation 17

that has been subscribed by participating customers. SCE will retire all such 18

RECs on behalf of participating customers in a designated Western Renewable 19

Energy Generation Information System (“WREGIS”) Retirement Sub-Account 20

separate from those used to meet SCE’s Renewables Portfolio Standard (“RPS”) 21

compliance. The community renewables provider will retain any RECs 22

associated with the community renewables facility’s unsubscribed generation. 23

7

SCE will not count any Community Renewables program generation toward its 1

RPS requirements. 2

C. Relationship Between Participating Customer and SCE 3

Community Renewables participating customers will remain Bundled Service customers 4

of SCE. SCE will retain the obligation to procure energy to reliably serve their load. Likewise, 5

SCE will continue to schedule participating customers’ load into the CAISO energy market and 6

procure energy and capacity on their behalf. Furthermore, SCE will bill participating customers 7

under their otherwise applicable tariffs for all electricity usage. SCE will provide a bill credit 8

that is based on the customer’s Class Average Retail Generation Rate and commensurate to the 9

size of the participating customer’s Community Renewables program subscription. As discussed 10

in Chapter IV, SCE will adjust this credit by various charges (e.g., indifference adjustment) to 11

ensure non-participating customer indifference. Participating customers will also be charged a 12

fee for program administration. 13

As explained above, SCE will not count any renewable generation associated with a 14

participating customer’s subscription toward its RPS requirements, instead retiring the RECs on 15

the customer’s behalf in a designated WREGIS Retirement Sub-Account separate from those 16

used to meet SCE’s RPS targets. The kWh of Community Renewables participating customers’ 17

subscriptions, however, will be deducted from SCE’s bundled retail sales for the purpose of 18

calculating RPS procurement quantity requirements.8 19

8 SeeCal. Pub. Util. Code § 2833(t).