STATE OF CALIFORNIA EDMUND G. BROWN JR., Governor

PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102-3298

May 14, 2018

Advice Letter 5275-E

Erik Jacobson

Director, Regulatory Relations

Pacific Gas and Electric Company

77 Beale Street, Mail Code B10C

P.O. Box 770000

San Francisco, CA 94177

SUBJECT: Joint AL for PG&E and King City Notifying Agreement on Resource

Adequacy for Intra-Year Load Migration for 2018.

Dear Mr. Jacobson:

Advice Letter 5275-E is effective as of April 16, 2018.

Sincerely,

Edward Randolph

Director, Energy Division

Erik Jacobson Director Regulatory Relations

Pacific Gas and Electric Company 77 Beale St., Mail Code B13U P.O. Box 770000 San Francisco, CA 94177 Fax: 415-973-3582

April 16, 2018

Advice 5275-E (Pacific Gas and Electric Company ID U 39 E)

Advice 0001-E (King City Community Power)

Public Utilities Commission of the State of California

Subject: Joint Advice Letter for Pacific Gas and Electric Company and King

City Community Power Notifying Agreement on Resource Adequacy

for Intra-Year Load Migration for 2018

Purpose Pursuant to California Public Utilities Commission (“Commission”) Resolution E-4907 (“Resolution”), Pacific Gas and Electric Company (“PG&E”) and King City Community Power jointly submit a Tier 1 Advice Letter to notify the Commission of the mutual agreement on Resource Adequacy (“RA”) requirements and cost responsibility for King City Community Power’s intent to provide service of load to the King City beginning in July 2018.

Background The Resolution addresses cost responsibilities in the Community Choice Aggregators’ (CCA) first year of operation that require newly forming or expanding CCAs to participate in the annual RA load forecasting process prior to serving load for the following year. The Resolution offers a waiver process for CCAs that have submitted an implementation plan after December 8, 2017 but before March 1, 2018 to serve load prior to January 1, 2019. Through this Advice letter, PG&E and King City Community Power are requesting a waiver as described in the Resolution. Under Option A, if a mutual agreement between the CCA and the incumbent utility in whose service territory the CCA intends to begin service can be reached on the payment for and allocation of RA requirements and associated cost responsibility, the CCA and utility may jointly submit a Tier 1 Advice Letter no later than 75 days prior to the RA compliance month in which the CCA wishes to begin service.

Advice 5275-E - 2 - April 16, 2018

King City Community Power submitted its implementation plan to the Commission on December 15th, 2017. On February 20, 2018, PG&E confirmed that King City Community Power could move forward with data testing. On March 9, 2018, the Commission certified King City Community Power’s implementation plan. On March 15, with the exception of this Advice Letter, King City Community Power submitted all of the materials required to complete registration with the Commission. Service to all King City Community Power customers is scheduled to begin on July 2, 2018. This Advice Letter provides notification that PG&E and King City Community Power1 have come to a mutual agreement on March 30, 2018 (via combination of payment and allocation of RA) addressing the System, Local, and Flexible RA requirements and cost responsibility concerns raised by the intra-year load migration.

Attachments

In accordance with the Resolution, attached is the agreement between PG&E and King City Community Power.

Protests Anyone wishing to protest this submission may do so by letter sent via U.S. mail, facsimile or E-mail, no later than May 7, 2018, which is 21 days2 after the date of this submission. Protests must be submitted to:

CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: EDTariffUnit@cpuc.ca.gov

Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission:

1 Note that as indicated in King City Community Power’s implementation plan, Pilot Power

Group, Inc. is the full service administrator for the program. Pursuant to this arrangement, Pilot Power Group, Inc. provides all of the credit required for King City Community Power energy purchases. For this reason, the initial counter party for purchase of King City Community Power’s Resource Adequacy is Pilot Power Group, Inc., but the necessary Resource Adequacy will be re-sold (sleeved) to King City Community Power for reporting and compliance.

2 The 20-day protest period concludes on a weekend, therefore, PG&E is moving this date to the following business day.

Advice 5275-E - 3 - April 16, 2018

For PG&E Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: PGETariffs@pge.com For King City Community Power Pilot Power Group, Inc. 8910 University Center Lane Suite 520 San Diego, CA 92122 Facsimile: (858) 678-0118 E-mail: regulatory@pilotpowergroup.com

Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11).

Effective Date As directed in the Resolution, this advice letter has been jointly filed by PG&E and King City Community Power as a Tier 1 advice letter, which under General Order 96-B, Section 5.1 is effective upon date of submission pending final disposition by the Commission.

Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list. Address changes to the General Order 96-B service list should be directed to PG&E at email address PGETariffs@pge.com. For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com.

Advice 5275-E - 4 - April 16, 2018

Advice letter submissions can also be accessed electronically at: http://www.pge.com/tariffs/. /S/ Erik Jacobson Director, Regulatory Relations Attachments

CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER SUBMITTAL SUMMARY

ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed)

Company name/CPUC Utility No. Pacific Gas and Electric Company (ID U39 E)

Utility type: Contact Person: Annie Ho

ELC GAS Phone #: (415) 973-8794

PLC HEAT WATER E-mail: AMHP@pge.com and PGETariffs@pge.com EXPLANATION OF UTILITY TYPE

ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water

(Date Submitted/ Received Stamp by CPUC)

Advice Letter (AL) #: 5275-E Tier: 1 Subject of AL: Joint Advice Letter for Pacific Gas and Electric Company and King City Community Power Notifying

Agreement on Resource Adequacy for Intra-Year Load Migration for 2018 Keywords (choose from CPUC listing): Compliance AL submittal type: Monthly Quarterly Annual One-Time Other _____________________________ If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Resolution E-4907 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: ____________________ Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: Yes

Confidential information will be made available to those who have executed a nondisclosure agreement: Yes. See the attached matrix that identifies all of the confidential information. Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential information: Vincent K. Loh, (415) 972-5664 Resolution Required? Yes No Requested effective date: April 16, 2018 No. of tariff sheets: N/A Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed: N/A Pending advice letters that revise the same tariff sheets: N/A

Protests, dispositions, and all other correspondence regarding this AL are due no later than 21 days1 after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: California Public Utilities Commission Pacific Gas and Electric Company Energy Division EDTariffUnit 505 Van Ness Ave., 4th Flr. San Francisco, CA 94102 E-mail: EDTariffUnit@cpuc.ca.gov

Attn: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, CA 94177 E-mail: PGETariffs@pge.com

1 The 20-day protest period concludes on a weekend, therefore, PG&E is moving this date to the following business

day.

Advice 5275-E April 16, 2018

Attachment 1

Master Power Purchase and Sale Agreement Resource Adequacy Confirmation Letter between

Pilot Power Group, Inc. and Pacific Gas and Electric Company (Public Version)

Advice 5275-E April 16, 2018

Attachment 2

Confidentiality Declarations and Matrix

PACIFIC GAS AND ELECTRIC COMPANY (U 39 E)

Joint Advice Letter 5275-E for Resolution E-4907 April 16, 2018

IDENTIFICATION OF CONFIDENTIAL INFORMATION

Redaction Reference

Category from D.06-06-066, Appendix 1, or

Separate Confidentiality Statute or Order That Data Corresponds To

Justification for Confidential Treatment Length of Time Data To Be Kept Confidential

Document: MASTER POWER PURCHASING AND SALE AGREEMENT RESOURCE ADEQUACY CONFIRMATION LETTER BETWEEN KING CITY COMMUNITY POWER AND PACIFIC GAS AND ELECTRIC COMPANY

Attachment 1, Appendix B, page 16-21, Contract Quantity and

Contract Price for System,

Local and Flexible

RAR Product

Attributes

Item VII) B) Contracts and power purchase agreements between

utilities and non-affiliated third parties (except RPS)

The table contains confidential information about the contract price ($/kW-mo) which is confidential per matrix line item VII) B) which states that contracts are confidential for three years from the date contract states deliveries to begin, or until one year following expiration, whichever comes first. The System RAR contract delivery terms begin in July 2018, and would remain confidential through July 2021.

The contract should be confidential through

July 2021.

PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV

AT&T Downey & Brand Pioneer Community Energy Albion Power Company Ellison Schneider & Harris LLP Praxair Alcantar & Kahl LLP Energy Management Service Regulatory & Cogeneration Service, Inc. Anderson & Poole Evaluation + Strategy for Social

Innovation SCD Energy Solutions

Atlas ReFuel GenOn Energy, Inc. SCE BART Goodin, MacBride, Squeri, Schlotz &

Ritchie SDG&E and SoCalGas

Barkovich & Yap, Inc. Green Charge Networks SPURR Braun Blaising Smith Wynne P.C. Green Power Institute San Francisco Water Power and Sewer CalCom Solar Hanna & Morton Seattle City Light California Cotton Ginners & Growers Assn ICF Sempra Utilities California Energy Commission International Power Technology Southern California Edison Company California Public Utilities Commission Intestate Gas Services, Inc. Southern California Gas Company California State Association of Counties Kelly Group Spark Energy Calpine Ken Bohn Consulting Sun Light & Power Casner, Steve Keyes & Fox LLP Sunshine Design Cenergy Power Leviton Manufacturing Co., Inc. Tecogen, Inc. Center for Biological Diversity Linde TerraVerde Renewable Partners City of Palo Alto Los Angeles County Integrated Waste

Management Task Force Tiger Natural Gas, Inc.

City of San Jose Los Angeles Dept of Water & Power TransCanada Clean Power Research MRW & Associates Troutman Sanders LLP Coast Economic Consulting Manatt Phelps Phillips Utility Cost Management Commercial Energy Marin Energy Authority Utility Power Solutions County of Tehama - Department of Public Works

McKenzie & Associates Utility Specialists

Crossborder Energy Modesto Irrigation District Verizon Crown Road Energy, LLC Morgan Stanley Water and Energy Consulting Davis Wright Tremaine LLP NLine Energy, Inc. Wellhead Electric Company Day Carter Murphy NRG Solar Western Manufactured Housing

Communities Association (WMA) Dept of General Services Office of Ratepayer Advocates Yep Energy Don Pickett & Associates, Inc. OnGrid Solar Douglass & Liddell Pacific Gas and Electric Company