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CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED by LSE (Attach Additional Pages As Needed)

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CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED by LSE (Attach Additional Pages As Needed) CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY LSE (Attach additional pages as needed) Company name/CPUC Utility No. Liberty Utilities (CalPeco Electric) LLC Utility type: Contact Person for questions and approval letters: Gregory Campbell_ ELC GAS Phone #: 562-299-5117 PLC HEAT WATER E-mail: [email protected] EXPLANATION OF UTILITY TYPE (Date Filed/ Received Stamp by CPUC) ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water Advice Letter (AL) #: 89-E Subject of AL: GHG Emission Performance Standard (EPS) filing 2017 Tier Designation: 1 2 3 Keywords (choose from CPUC listing): AL filing type: Monthly Quarterly Annual One-Time Other Does AL replace a withdrawn or rejected AL? If so, identify the prior AL 1 Summarize differences between the AL and the prior withdrawn or rejected AL : Requested effective date: March 15, 2018 No. of tariff sheets: Estimated system annual revenue effect: (%): Estimated system average rate effect (%): 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 proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Utility Info (including e-mail) Liberty Utilities (CalPeco Electric) LLC Attention: Tariff Unit 505 Van Ness Ave., Attention: Advice Letter Protests San Francisco, CA 94102 933 Eloise Avenue [email protected] South Lake Tahoe, CA 9696150 Email: [email protected] 1 Discuss in AL if more space is needed. 1 Liberty Utilities (CalPeco Electric) LLC 933 Eloise Avenue South Lake Tahoe, CA 96150 Tel: 800‐782‐2506 Fax: 530‐544‐4811 February 21, 2018 California Public Utilities Commission Energy Division Attention: Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, CA 94102-3298 Advice Letter 89-E Pursuant to Ordering Paragraph No. 4 of Decision (“D.”) 07-01-039, issued in R. 06-04-009 on January 25, 2007, Liberty Utilities (CalPeco Electric) LLC (U 933-E) (“Liberty CalPeco”) submits this annual Attestation Letter affirming that the financial commitments Liberty CalPeco has entered into for generation during the prior calendar year are in compliance with the greenhouse gas (“GHG”) emissions performance standard (“EPS”). Specifically, Liberty Utilities is in compliance with the EPS. Other than the 12 MW Kings Beach Generating Station which is uses for only emergency back- up support and whose generation is restricted by air permits to no more than 1440 MWh in each calendar year, Liberty CalPeco has no generation facilities and no long-term financial commitments for generation. Liberty CalPeco entered into a contract with NV Energy for a period of less than five years beginning 1-1-2016, expiring 12-30-2020. The commission approved the purchase power agreement in Decision 15-12-021. In the Purchase Power Agreement, Valmy coal fires generating facility was removed for this contract period. Effective Date: March 15, 2018 Tier Designation: Tier 2 Designation Purpose This Attestation Letter provides information and documentation required by D.07-01-039. This Attestation Letter demonstrates that for 2017 Liberty Utilities has entered into financial commitments that are in compliance with the EPS (long-term financial commitments defined on Page 3 of Attachment 7 in D.07-01-039). 1 Liberty Utilities (CalPeco Electric) LLC 933 Eloise Avenue South Lake Tahoe, CA 96150 Tel: 800‐782‐2506 Fax: 530‐544‐4811 Background D.07-01-039 requires all Load Serving Entities (“LSEs”) to file annual Attestation Letters, due February 15th of each year, attesting to the Commission that the financial commitments entered into for generation during the prior calendar year are in compliance with the EPS. D.07-01-039 requires LSEs to file Attestation Letters as an advice letter and serve the Attestation Letter on the service list in Rulemaking (“R.”) 06-04-009. This Attestation Letter is filed pursuant to that process. D.07-01-039 requires LSEs to include a listing of long-term financial commitments of five years or longer that they have entered into during the prior year. Furthermore, D.07-01-039 requires additional documentation demonstrating that LSEs have complied with the EPS. Specifically, D.07-01-039 requires LSEs to provide documentation to demonstrate: (a) That the commitments were not “covered procurements” under the interim EPS rule and/or (b) For those that represent covered procurements, documentation demonstrating that such procurements are EPS-compliant, including any contracts with a term of five years or longer that include provisions for substitute energy purchases. (c) For any requested reliability-based exemptions that have been pre- approved by the Commission, a reference to the application and Commission decision number. D.07-01-039 requires all LSEs to disclose the investment amount and type of alteration to retained generation, by generation facility and unit. D.07-01-039 also advises LSEs to present documentation regarding the design and intended use of the powerplant(s) underlying their new long-term financial commitments utilizing the sources of information listed in § 8341(b)(4), as well as any other sources of documentation that they believe will be relevant to this determination. D.07-01-039 emphasizes that the key concept is to establish the design and intended use of the powerplant. Accordingly, documentation of the annualized plant capacity factor for the powerplant should include historical annual averages in order to help determine whether the plant is “designed and intended” to be used for baseload generation. D.07-01-039 requires LSEs to provide documentation of capacity factors, heat rates and corresponding emissions rates that reflect the actual, expected operations of the plant. This Attestation Letter comports with the requirements outlined above. 2 Liberty Utilities (CalPeco Electric) LLC 933 Eloise Avenue South Lake Tahoe, CA 96150 Tel: 800‐782‐2506 Fax: 530‐544‐4811 Protests This compliance filing is not subject to protest pursuant to General Order 96-B, Energy Industry Rule 9. Correspondence Any correspondence regarding this compliance filing should be sent by email to the attention of: Greg Campbell, Rate Analyst, Rates and Regulatory Affairs Liberty Utilities (CalPeco Electric) LLC Attention: Advice Letter Protests 933 Eloise Avenue South Lake Tahoe, CA 96150 [email protected] Certification (1) I have reviewed, or have caused to be reviewed, this compliance submittal. (2) Based on my knowledge, information, or belief, this compliance submittal does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements true. (3) Based on my knowledge, information, or belief, this compliance submittal contains all of the information required to be provided by Commission orders, rules, and regulations. Include the name and contact information for the LSE officer(s) certifying the above: Sharon Yang, Director of Legal Services Liberty Utilities (CalPeco Electric) LLC 933 Eloise Avenue South Lake Tahoe, CA 96150 3 ************ SERVICE LIST *********** Last Updated on 17-AUG-2016 by: AMT R0604009 NOPOST ************** PARTIES ************** Evelyn Kahl 3 PHASES RENEWABLES LLC SEEMA SRINIVASAN 2100 SEPULVEDA BLVD, SUITE 37 Attorney At Law MANHATTAN BEACH CA 90266 ALCANTAR & KAHL, LLP For: 3 Phases Renewables 345 CALIFORNIA ST., STE. 2450 SAN FRANCISCO CA 94104 (415) 421-4143 Michael Mazur [email protected] Principal For: Energy Producers & Users Coalition 3 PHASES RENEWABLES, LLC EMAIL ONLY EMAIL ONLY CA 00000 Michael P. Alcantar (310) 798-5275 S. SRINIVISAN [email protected] Attorney At Law For: 3 Phases Energy Services ALCANTAR & KAHL, LLP 345 CALIFORNIA ST., STE. 2450 SAN FRANCISCO CA 94104 Marc D. Joseph (415) 421-4143 Attorney At Law [email protected] ADAMS BROADWELL JOSEPH & CARDOZO For: Cogeneration Association of California/Energy Producers and 601 GATEWAY BLVD. STE 1000 Users Coalition SOUTH SAN FRANCISCO CA 94080 (650) 589-1660 [email protected] Nora Sheriff For: Coalition of California Utility Employees ALCANTAR & KAHL, LLP 345 CALIFORNIA ST., STE. 2450 SAN FRANCISCO CA 94104 Eric Pendergraft (415) 421-4143 AES SOUTHLAND LLC [email protected] 690 NORTH STUDEBAKER ROAD For: Energy Producers & Users Coalition LONG BEACH CA 90803 (562) 493-7891 [email protected] Mike Lamond For: AES Southland, LLC Chief Financial Officer ALPINE NATURAL GAS OPERATING CO. #1 LLC EMAIL ONLY Robert R. Taylor EMAIL ONLY CA 00000 AGRICULTURAL IMPROVEMENT AND POWER DIST. (209) 772-3006 1600 NORTH PRIEST DRIVE, PAB221 [email protected] TEMPE AZ 85281 (602) 236-3487 Paul Delaney [email protected] V.P. AMERICAN UTILITY NETWORK (A.U.N.) Donald Brookhyser 10705 DEER CANYON DRIVE Attorney At Law ALTA LOMA CA 91737 ALCANTAR & KAHL (805) 390-5632 345 CALIFORNIA ST., STE. 2450 [email protected] SAN FRANCISCO CA 94014 For: American Utility Network (415) 421-4143 [email protected] For: Cogeneration Association of California/Energy Producers and Gloria Britton Users Coalition ANZA ELECTRIC COOPERATIVE, INC. (909) PO BOX 391909 / 58470 HWY 371 ANZA CA 92539 [email protected] For: Anza Electric Cooperative
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