UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION. ) Southern California Edison Company ) Docket No.

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1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) Southern California Edison Company ) Docket No. ER JOINT PROGRESS REPORT OF PACIFIC GAS AND ELECTRIC COMPANY AND SOUTHERN CALIFORNIA EDISON COMPANY AND REQUEST FOR EXTENSION OF TEMPORARY WAIVER OF CERTAIN CAISO TARIFF PROVISIONS On March 31, 2011, the Commission issued an order 1/ granting Pacific Gas and Electric Company (PG&E) and Southern California Edison Company (SCE) temporary waivers from California Independent System Operator (CAISO) tariff sections and for all Qualifying Facility (QF) resource adequacy (RA) resources. 2/ The temporary waivers ran until June 30, / On June 30, 2011, the Commission issued an order granting an extension of these waivers until September 30, / The temporary waivers relate to certain forced outage reporting requirements and non-availability charges and availability incentive payments in the CAISO tariff that would otherwise be applicable to certain QF RA resources. In the Waiver Order, the Commission directed PG&E and SCE to file a joint progress report no later than June 30, 2011 to provide details on the CAISO s stakeholder process on this matter, as well as the remedy being proposed by PG&E, SCE and San Diego Gas and Electric Company (SDG&E) (together, the investor-owned utilities or IOUs). PG&E and SCE filed the required joint progress report on June 20, In its June 30, 2011 order extending the waiver to September 30, 2011, the Commission directed PG&E and SCE to submit an additional joint progress report no later than August 31, / 134 FERC 61,265 (Waiver Order). 2/ Waiver Order, P 15. 3/ Id. 4/ 135 FERC 61,282 (Extended Waiver Order). 1

2 PG&E and SCE are providing the required additional joint progress report in this pleading. PG&E and SCE also request a further extension of the temporary waiver until the earlier of December 31, 2011, or the effective date of the Commission order on the anticipated CAISO filing proposing tariff language to permanently resolve this matter. This additional time is needed to allow the CAISO to complete its stakeholder process and file its proposal with the Commission, and for the Commission to act on the CAISO s proposal. The CAISO stakeholder process is currently scheduled to conclude, and the CAISO to file its proposed tariff changes, by approximately September 30, PG&E and SCE anticipate that before the end of the extension requested here, the Commission will have acted on the CAISO s filed request for approval of the proposed amended tariff language. Thus, the proposed extension of the temporary waiver is necessary to cover the time between the expiration of the existing extended waiver and the Commission s issuance of an order addressing the CAISO s filing. SCE and PG&E are informed that the CAISO supports this request for extension. I. JOINT PROGRESS REPORT The IOUs have worked with the CAISO regarding the CAISO stakeholder process in this matter. The CAISO posted the Joint Proposal of the IOUs (joint proposal) 5/ on its website for comment on June 10, The basic premise of the joint proposal is that certain QF RA contracts without compliant and mandatory forced outage reporting requirements be grandfathered from the forced outage reporting requirements in the CAISO tariff. The IOUs contracts with these resources do not provide the IOUs (who act as the scheduling coordinator for most of these resources) 6/ the right to obtain the forced outage information from the resources in a manner that is consistent with the CAISO s tariff provisions. These QF contracts would 5/ The joint proposal can be referenced on the CAISO s website, 6/ Per the CAISO s tariff, the scheduling coordinators of the QF RA resource contracts are responsible for the forced outage reporting requirements. 2

3 include QF RA resources operating under contracts whose terms were executed prior to August 22, 2010 and have not been extended by order of the California Public Utilities Commission (CPUC) (known as grandfathered contracts for this issue), as well as those QF RA resource contracts whose terms were extended by order of the CPUC (known as CPUC-extended contracts for this issue). 7/ The CAISO hosted a stakeholder telephone conference on June 17, 2011 to discuss the topic. Stakeholder comments were submitted on June 24, 2011, and no comments opposed the joint proposal. 8/ After gathering input from stakeholders and evaluating the issue, the CAISO recently posted its recommendation on its website. 9/ The CAISO s recommendation proposes to develop and file modifications to Section 40.9 of the CAISO tariff language to: Exempt scheduling coordinators for grandfathered and CPUC-extended QF contracts from the forced outage reporting requirement; Exempt scheduling coordinators for CPUC-extended QF contracts from non-availability charges and availability incentive payments. The CAISO s recommendation proposes the following timeline to complete the resolution of this issue: September 9, 2011 Conference call regarding recommendation. September 14, 2011 Stakeholder comments due on recommendation. September 15, Post tariff language for a FERC filing consistent with the CAISO s recommendation. September 22, Gather stakeholder comments regarding tariff language. September 26, Stakeholder conference call. 7/ CPUC Decision (D.) / For a summary of the comments, see the CAISO s recommendation, at aiver.aspx. 9/ The CAISO s recommendation can be found on the CAISO s website, 3

4 September 30, File tariff language. After the stakeholder process for the revised tariff language is complete, the CAISO intends to make the necessary filing requesting approval of the revised tariff with the Commission. II. REQUEST FOR EXTENSION OF TEMPORARY WAIVER The stakeholder process for the CAISO s proposed tariff modification and Commission action on the resulting tariff changes the CAISO proposes for adoption is estimated to conclude approximately December 31, 2011 three months after the Commission s current temporary waiver expires. Therefore, PG&E and SCE respectfully request that the temporary waiver be extended to allow time to complete this stakeholder process and for the Commission s issuance of an order addressing the CAISO s filing seeking approval of amended tariff language. PG&E and SCE are informed that the CAISO supports their request for extension of the Commission s temporary exemption. Based on this, PG&E and SCE respectfully request that the temporary waiver of CAISO tariff sections and for QF RA resources, currently granted through September 30, 2011, be extended until the earlier of December 31, 2011, or the effective date of the Commission order on the anticipated CAISO filing proposing tariff language to permanently resolve this matter. 4

5 III. CONCLUSION PG&E and SCE respectfully submit this joint status report, as required by the Commission in its June 30, 2011 Order. SCE has PG&E s permission to sign on their behalf. PG&E and SCE also respectfully request that the temporary waiver of CAISO tariff sections and for QF RA resources, currently granted through September 30, 2011, be extended until the earlier of December 31, 2011, or the effective date of the Commission order on the anticipated CAISO filing proposing tariff language to permanently resolve this matter. Respectfully submitted, JONI A. TEMPLETON By: /s/ Joni A. Templeton JONI A. TEMPLETON 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Joni.Templeton@SCE.com Attorney for SOUTHERN CALIFORNIA EDISON COMPANY Dated: August 31,

6 CERTIFICATE OF SERVICE I hereby certify that I have this day served a copy of the foregoing document upon each person designated on the official service list in this proceeding, ER , in accordance with the requirements of Rule 2010 of the Commission s Rules of Practice and Procedure, and the additional parties listed below: Frank Lindh, General Counsel California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA frl@cpuc.ca.gov Anthony Ivancovich, Assistant General Counsel California Independent System Operator Corporation 250 Outcropping way Folsom, CA aivancovich@caiso.com Dated at Rosemead, California, this 31 st day of August, By: /s/ Sandra Rangel Sandra Rangel Case Analyst Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770