Submission Description: (doc-less) Motion to Intervene of Power and Water
`Resources Pooling Authority under ER20-2878-000, et. al.
`
`Submission Date: 9/23/2020 4:24:19 PM
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`Filed Date: 9/23/2020 4:24:19 PM
`
`Dockets
`-------
`ER20-2878-000 Pacific Gas and Electric Company submits tariff filing per
`35.13(a)(1): Wholesale Distribution Tariff Rate Case 2020 (WDT3) submitted on
`9/14/2020 6:54:09 PM, Filing Type code: 320
`ER20-2878-003 Pacific Gas and Electric Company submits tariff filing per
`35.17(b): Third Amendment to Wholesale Distribution Tariff Rate Case 2020
`(WDT3), PWRPA 30 submitted on 9/16/2020 2:17:26 PM, Filing Type code: 130
`ER20-2878-004 Pacific Gas and Electric Company submits tariff filing per
`35.17(b): Fourth Amendment to Wholesale Distribution Tariff Rate Case 2020
`(WDT3), PWRPA56 submitted on 9/16/2020 2:39:36 PM, Filing Type code: 130
`ER20-2878-006 Pacific Gas and Electric Company submits tariff filing per
`35.17(b): Sixth Amendment to Wholesale Distribution Tariff Rate Case 2020
`(WDT3), Western submitted on 9/16/2020 3:02:57 PM, Filing Type code: 130
`
`Filing Party/Contacts:
`
`Filing Party Signer (Representative)
`Other Contact (Principal)
`------------ -----------------------
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`Power and Water Resources Pooling Autho michael@mccarty-legal.com
`bcm@cameron-daniel.com
`Power and Water Resources Pooling Autho AHewitt.Rose@hklaw.com
`
`Basis for Intervening:
`Pursuant to Rule 214 of the Commission s Rules of Practice and Procedure, the
`Power and Water Resources Pooling Authority (PWRPA) hereby moves to intervene in
`these dockets, in which Pacific Gas and Electric Company (PG&E) has filed to
`replace the rates, rate methodologies, and certain non-rate terms of its
`Wholesale Distribution Tariff (WDT) and various service agreements entered into
`pursuant to the WDT.
`
`PWRPA is a joint powers authority with eight member irrigation districts
`organized under Title I, Division 7, Chapter 5 (Sections 6500, et seq.) of the
`California Government Code. PWRPA provides retail electric service to its
`member districts and seven other public agency customers. Each customer is an
`end-user of electricity for agricultural pumping, municipal water supply, or
`other water-related functions.
`
`PWRPA is a preference customer of the Western Area Power Administration (WAPA),
`from which PWRPA purchases and resells  base resource  hydropower generated
`by the federal Central Valley Project (CVP) under WAPA s current marketing
`plan for the Sierra-Nevada Region. PWRPA has seven long-term power purchase
`agreements and one ownership agreement with California-eligible renewable
`electricity resources to serve portions of its customers  loads. PWRPA also
`has a share of the output from the Lodi Energy Center, a 302-megawatt, natural
`gas-fired, combined cycle electrical generating facility in Lodi, California. As
`required, PWRPA purchases and supplies its customers with supplemental power
`acquired at wholesale through bilateral transactions in the California
`Independent System Operator Corporation (CAISO) balancing area.
`
`PWRPA currently serves approximately 630 metered accounts at retail. The
`majority of PWRPA s delivery points are served under the Wholesale
`Distribution Tariff (WDT) Service Agreement between WAPA and PG&E, designated as
`Service Agreement No. 17 under FERC Electric Tariff Volume No. 4 (SA 17). Under
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`back-to-back agreements with each of its Sierra-Nevada Region customers, WAPA
`requires the customer, among other things, to reimburse WAPA for transmission
`and distribution charges assessed by the CAISO and/or PG&E in connection with
`service to that customer.
`
`In addition to its customer loads served under SA 17, PWRPA has twelve
`individual WDT service agreements directly with PG&E for service to PWRPA
`customer delivery points that do not qualify for service under SA 17. Three of
`those service agreements are consolidated in Service Agreement No. 30 under FERC
`Electric Tariff Volume No. 4 (SA 30). The other nine PG&E-PWRPA WDT service
`agreements are consolidated in Service Agreement No. 56 under FERC Electric
`Tariff Volume No. 4 (SA 56). PWRPA is entitled to add new qualifying points of
`delivery under the terms of SA 17 and SA 56.
`
`PG&E has proposed to replace its existing stated WDT rates with a formula rate
`model. The formula rate model, and the initial rates produced thereunder as
`filed by PG&E, would substantially increase the wholesale distribution service
`rates and other charges that PWRPA currently pays under SA 17, SA 30, and SA 56.
`PG&E also has proposed extensive modifications to the non-rate terms of its WDT
`that will impact PWRPA, including but not limited to a change from billing on
`the basis of metered demand or energy to billing on the basis of Contract
`Demand; and a discontinuation of Secondary distribution service for new or
`modified points of delivery (with limited exceptions for certain WAPA customers
`under SA 17).
`
`Additionally, the Protocols accompanying the proposed formula rate model would,
`among other impacts, substantially limit the rights of PWRPA and other WDT
`distribution customers to contest the data inputs used to populate annual
`updates and true-ups under the new formula rate.
`
`Accordingly, PWRPA will be directly and significantly affected by PG&E s
`proposed tariff revisions in these dockets. Because PWRPA s interests cannot
`adequately be represented by any other existing or prospective party to these
`proceedings, PWRPA is entitled to intervene as a matter of right under Rule 214.
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