VIA ELECTRONIC MAIL [email protected] board [email protected]...

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Andrew J. McNally Assistant General Counsel 609.909.7033 – Telephone 609.393.0243 – Facsimile [email protected] atlanticcityelectric.com Mailing Address: 92DC42 PO Box 6066 Newark, DE 19714-6066 Overnight Delivery: 500 N. Wakefield Drive Newark, DE 19702 May 7, 2020 VIA ELECTRONIC MAIL [email protected] [email protected] Aida Camacho-Welch Secretary of the Board Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, New Jersey 08625-0350 RE: In the Matter of the Petition of Atlantic City Electric Company Concerning the Initial Setting of the Regional Greenhouse Gas Initiative Recovery Charge (“Rider RGGI”) Associated with the New Jersey Solar Transition Incentive Program BPU Docket No. Dear Secretary Camacho-Welch: On behalf of Atlantic City Electric Company (“ACE”), enclosed herewith for filing is an electronic copy of a Petition, along with the supporting attachments in the above-referenced matter. A draft Public Notice is also attached to the Petition as Attachment C. Consistent with the Order issued by the Board in connection with In the Matter of the New Jersey Board of Public Utilities’ Response to the COVID-19 Pandemic for a Temporary Waiver of Requirements for Certain Non-Essential Obligations, BPU Docket No. EO20030254, Order dated March 19, 2020, these documents are being electronically filed with the Secretary of the Board and the New Jersey Division of Rate Counsel. No paper copies will follow. ACE respectfully requests that the Board retain jurisdiction of this matter and render a decision thereon so that rates can be put into effect by September 1, 2020. ER20050344

Transcript of VIA ELECTRONIC MAIL [email protected] board [email protected]...

Page 1: VIA ELECTRONIC MAIL aida.camacho@bpu.nj.gov board ......aida.camacho@bpu.nj.gov board.secretary@bpu.nj.gov. Aida Camacho-Welch . Secretary of the Board . Board of Public Utilities

Andrew J. McNally Assistant General Counsel

609.909.7033 – Telephone 609.393.0243 – Facsimile [email protected]

atlanticcityelectric.com

Mailing Address: 92DC42 PO Box 6066 Newark, DE 19714-6066

Overnight Delivery: 500 N. Wakefield Drive Newark, DE 19702

May 7, 2020

VIA ELECTRONIC MAIL [email protected] [email protected]

Aida Camacho-Welch Secretary of the Board Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, New Jersey 08625-0350

RE: In the Matter of the Petition of Atlantic City Electric Company Concerning the Initial Setting of the Regional Greenhouse Gas Initiative Recovery Charge (“Rider RGGI”) Associated with the New Jersey Solar Transition Incentive Program BPU Docket No.

Dear Secretary Camacho-Welch:

On behalf of Atlantic City Electric Company (“ACE”), enclosed herewith for filing is an electronic copy of a Petition, along with the supporting attachments in the above-referenced matter. A draft Public Notice is also attached to the Petition as Attachment C.

Consistent with the Order issued by the Board in connection with In the Matter of the New Jersey Board of Public Utilities’ Response to the COVID-19 Pandemic for a Temporary Waiver of Requirements for Certain Non-Essential Obligations, BPU Docket No. EO20030254, Order dated March 19, 2020, these documents are being electronically filed with the Secretary of the Board and the New Jersey Division of Rate Counsel. No paper copies will follow.

ACE respectfully requests that the Board retain jurisdiction of this matter and render a decision thereon so that rates can be put into effect by September 1, 2020.

ER20050344

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Aida Camacho-Welch May 7, 2020 Page 2

Thank you for your consideration and courtesies. Feel free to contact me with any questions or if I can be of further assistance.

Respectfully submitted,

Andrew J. McNally

Enclosure

cc: Service List

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IN THE MATTER OF THE PETITION OF ATLANTIC CITY ELECTRIC COMPANY CONCERNING THE INITIAL SETTING OF THE REGIONAL GREENHOUSE GAS INITIATIVE RECOVERY CHARGE (“RIDER RGGI”) ASSOCIATED WITH THE NEW JERSEY SOLAR TRANSITION INCENTIVE PROGRAM

STATE OF NEW JERSEY BOARD OF PUBLIC UTILITIES

BPU DOCKET NO.

PETITION1

ATLANTIC CITY ELECTRIC COMPANY (“ACE” or the “Company”), a public

utility engaged in the transmission and distribution of electric energy to residential, commercial,

and industrial customers, across a service territory comprising eight counties located in southern

New Jersey and including approximately 556,000 customers,2 respectfully requests that the Board

of Public Utilities (“BPU” or the “Board”) accept this Petition as the Company’s proposal for cost

recovery and the establishment of its initial annual Rider Regional Greenhouse Gas Initiative

Transition Renewable Energy Certificate (“TREC”) Recovery Charge (“Rider RGGI TREC

charge”). The Company submits this Petition pursuant to the Board’s Orders issued in connection

with BPU Docket No. QO19010068 (the “TREC Orders”). The Company hereby seeks approval

of the proposed Rider RGGI TREC charge for the period September 1, 2020 to August 31, 2021

and cost recovery contained herein.

1 In light of exigencies created by the COVID-19 pandemic and the Executive Orders issued pursuant thereto, this Petition is being submitted under Certification in lieu of an Affidavit of Verification.

2 ACE is a direct, wholly owned subsidiary of Pepco Holdings LLC (“PHILLC”), a limited liability company under the laws of the State of Delaware. PHILLC is, in turn, a wholly owned subsidiary of PH Holdco LLC (“PHLLC”), a limited liability company, existing under the laws of the State of Delaware. PHLLC is, in turn, 99.9% owned by Exelon Energy Delivery Company, LLC (“EEDC”), a Delaware limited liability company, existing under the laws of the State of Delaware. EEDC is, in turn, a limited liability company wholly owned by Exelon Corporation.

ER20050344

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I. INTRODUCTION AND BACKGROUND

1. On May 23, 2018, the Clean Energy Act of 2018 (“Clean Energy Act” or “Act”)

was signed into law. The Clean Energy Act required that the Board adopt rules and regulations to

terminate the Solar Renewable Energy Certificate Programs (“SREC”, ”SRP” or “Legacy SREC

Programs”) upon the Board’s determination that 5.1 percent of the kilowatt-hours (“kWh”) sold in

the State by each electric power supplier and each basic generation supplier has been produced by

solar electric power generators connected to the distribution system (the “5.1 percent Milestone”).

2. By Order dated December 6, 2019 (the “December 6, 2019 Order”), the Board

created the Transition Incentive Program (the “TREC Program”), designed to bridge the gap

between the Legacy SREC Program and a to-be-determined Successor Program. The TREC

Program is designed to provide a transition for projects submitted to the Board prior to the adoption

of the Successor Solar Incentive Program. This includes projects that applied to the Legacy SREC

Programs after October 29, 2018, that have yet to commence commercial operations, and that

remain in the SRP pipeline at the time the 5.1 percent Milestone is achieved.3

3. The December 6, 2019 Order required the New Jersey Electric Distribution

Companies (“EDCs”) to work with Staff to jointly procure an administrator (“TREC

Administrator”) to acquire the TRECs on behalf of the EDCs and assist with the retirement of

TRECs for the benefit of load serving entities. The EDCs were ordered to purchase all TRECs

that are created by solar projects in the TREC program at a fixed price, to be set by future Board

Order. The December 6, 2019 Order further provided that:

3 By Order dated April 6, 2020 in BPU Docket No. QO19010068, the Board determined that the 5.1% Milestone would be achieved by April 30, 2020. Note, also that the Board, in its March 27, 2020 Order in Docket No. QO18070698 (the “March 27, 2020 Order”), provided an exception from inclusion in the TREC Program. In pertinent part, the March 27, 2020 Order states “[f]or example, projects that applied to the Board for SREC eligibility pursuant to Subsection t on or before October 29, 2018 and were approved for conditional certification, which provides a two-year registration length, maintain their eligibility for SRECs regardless of when the state attains the 5.1 percent Milestone.” See March 27, 2020 Order, at 3.

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[T]he EDCs may recover reasonable and prudent costs for TRECs procurement and TREC Administrator fees. Recovery shall be based on each EDC’s proportionate share of retail electric sales. Each EDC shall make an annual filing for its costs and the recovery method, which shall be subject to approval by the Board.4

4. During the process of working with Staff the EDCs were provided a schedule of

estimated TREC procurement costs prepared by Staff (“TREC Procurement Schedule”). The

TREC Procurement Schedule provided that the EDCs will make periodic payments for the

procurement of TRECs based on TRECs generated following initiation of the TREC Program. As

of the date of this filing, the TREC program has not yet been initiated.

5. In accordance with the December 6, 2019 Order, ACE shall recover its portion of

the costs to procure the TRECs generated by projects in the TREC Program and the TREC

Administrator’s fees, as well as any other direct costs associated with its’ obligations for

participation in the TREC Program, through a separate component of its Rider RGGI tariff.

6. After issuance of the December 6, 2019 Order, the EDCs began working together

on the joint procurement of a TREC Administrator. As of the date of this filing, the EDCs are in

the process of evaluating bids received for the Request for Proposal (“RFP”) for the TREC

Administrator. For purposes of this filing, the EDCs have agreed that a reasonable estimate of the

projected annual costs for the TREC Administrator fees is estimated to be $900,000 annually

(“TREC Administrator Fee”).

7. Additionally, by Order dated March 9, 2020 in Docket No. QO19010068 (the

“March 9, 2020 Order”) the Board determined that the appropriate base compensation for solar

developers in the Transition Incentive program should be set at $152 per TREC. As noted in the

March 9, 2020 Order, the specific value of a TREC earned would be calculated by multiplying the

“factor” assigned to each TREC project with the base compensation for the appropriate year.

4 December 6, 2019 Order, at 34.

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8. Annexed hereto as Attachment A is ACE’s calculation of the annual total revenue

requirement necessary to recover its portion of the costs of the TREC program, including the

estimated TREC Administrator Fee for the first year of the TREC program. As noted above, for

purposes of this calculation, the estimated TREC Administrator Fee for the initial program year is

$900,000. In accordance with the December 6, 2019 Order, ACE’s share of the program costs is

based on its percentage allocation of retail electric billed sales during calendar year 2019. The

estimated TREC procurement costs are based on the TREC Procurement Schedule provided by

Staff. Based on the foregoing, the Company’s projected revenue requirement for the period July

1, 2020 through August 31, 2021 (“the initial program year”) is $4,468,211.

9. Based on the Company’s projected revenue requirement of $4,468,211, ACE

proposes to set the rate for the TREC component of its Rider RGGI recovery charge at $0.000559

per kWh (the “initial TREC charge”), to be effective September 1, 2020. The initial TREC charge

shall recover program costs incurred for the initial program year. Following the initial program

year, all subsequent program years shall be for the period September 1st through August 31st of

the following year. For each subsequent program year thereafter, the Company shall file a petition

seeking to reconcile any over/under recovery from the prior program year and set the TREC charge

for the succeeding program year. As with other programs included in ACE’s Rider RGGI tariff,

namely ACE’s SREC I and SREC II programs (the “SREC programs”)5, revenues received from

the TREC Program will be applied to reduce the costs to be recovered through the RGGI Rider

TREC charge. As with the SREC programs, ACE proposes that the interest rate on over and under

recoveries will be the interest rate based on two-year constant maturity Treasuries as published in

the Federal Reserve Statistical Release on the first day of each month (or the closest day thereafter

5 Currently, ACE’s Rider RGGI also includes its Residential Controllable Smart Thermostat Program, which is scheduled to be terminated as of May 31, 2020.

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on which rates are published), plus sixty basis points, but will not exceed the overall rate of return

for ACE as authorized by the Board. The interest rate will be reset each month and its calculation

will be based on the net of tax beginning and ending average monthly balance. ACE will accrue

simple interest with an annual roll-in at the end of each year.

II. BASIS FOR RELIEF

10. By this Petition, the Company seeks approval by the Board of a proposed initial

tariff provision in the Rider RGGI associated with the TREC Program.6

11. As noted in Attachment A, ACE will incur a total annual revenue requirement for

the initial TREC Program year of $4,468,211, inclusive of its proportionate share of the estimated

TREC procurement costs and the Administrator Fee. Based upon calculations performed by the

EDCs, ACE’s proportionate percentage of total electric retail sales in 2019 has been determined

to be 12.36 percent.

12. Based upon ACE’s total annual revenue requirement for the initial TREC Program

year of $4,468,211 ACE proposes to establish its initial TREC charge to be $0.000559 per kWh.

For an average residential customer using approximately 679 kWh per month, the implementation

of the TREC charge represents an increase of approximately $0.38 or 0.29% on a total monthly

bill. Included herewith as Attachment B is the proposed initial Rider RGGI tariff page for the

TREC Program.

III. PUBLIC NOTICE AND SERVICE

13. Inasmuch as the Company is seeking a new tariff charge for the TREC Program,

there will be an increase in the overall rates and charges on customers resulting from the

implementation of the TREC Program. Accordingly, the Company is required to publish and serve

6 It should be noted that the TREC Program that is the subject of the instant Petition is not associated with -- and has no impact on – the SREC Financing Programs (SREC I and SREC II) that were previously approved by the Board.

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a Public Notice, which shall set forth the dates and times for public hearings in the Company’s

service area pursuant to N.J.A.C. 14:1-5.12(b)1 and 3, (c) and (d). Due to the COVID-19

pandemic, the Company proposes that telephonic hearings on the Petition be conducted at a date

and times to be agreed upon by the parties, and to be included in the Public Notice. A copy of the

Company’s proposed Public Notice is included herewith as Attachment C.

14. Notice of this filing along with any and all schedules, exhibits, and attachments,

shall be sent to the Department of Law and Public Safety, 25 Market Street, P.O. Box 112, Trenton,

New Jersey 08625, and to the Director of the Division of Rate Counsel, 140 East Front Street, P.O.

Box 003, Trenton, New Jersey 08625, by electronic mail only. Electronic copies of the Petition,

along with all schedules, exhibits, and attachments, shall be sent to the persons identified in the

Service List attached hereto. This is consistent with the Order issued by the Board in connection

with In the Matter of the New Jersey Board of Public Utilities’ Response to the COVID-19

Pandemic for a Temporary Waiver of Requirements for Certain Non-Essential Obligations, BPU

Docket No. EO20030254 (March 19, 2020).

IV. COMMUNICATIONS

15. Communications and correspondence regarding this matter should be sent to

Petitioner’s counsel at the following address:

Andrew J. McNally, Esquire Assistant General Counsel Atlantic City Electric Company – 92DC42 500 North Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 Phone: (609) 909-7033 [email protected]

and

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Philip J. Passanante, Esquire Assistant General Counsel Atlantic City Electric Company – 92DC42 500 North Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 Phone: (609) 909-7034 [email protected]

with copies to the following representatives of the Company:

Susan DeVito Director, Pricing and Regulatory Services Pepco Holdings LLC – 92DC56 500 North Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 [email protected]

Thomas M. Hahn Principal Rate Analyst Atlantic City Electric Company – 63ML38 5100 Harding Highway Mays Landing, NJ 08330 [email protected]

and

Heather Hall Manager, Regulatory Affairs – New Jersey Pepco Holdings LLC – 92DC56 500 North Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 [email protected]

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WHEREFORE, the Petitioner, ATLANTIC CITY ELECTRIC COMPANY,

respectfully requests that the Board of Public Utilities issue an Order as follows:

A. approving the Company’s proposed participation in the TREC Program, as well as

its proposals regarding the timing and methodology for recovery of its just and

reasonable program costs associated with its participation in the TREC Program, as

more fully set forth herein. The Company further requests that the Board accept

and approve the setting of its initial TREC Rider RGGI charge at $0.000559 per

kWh for recovery of its TREC Program’s direct costs; and

B. granting such other or further relief as may be necessary to implement the purposes

stated herein.

Respectfully submitted,

ATLANTIC CITY ELECTRIC COMPANY

Dated: May 7, 2020 ______________________________ Andrew J. McNally Assistant General Counsel Atlantic City Electric Company – 92DC42 500 N. Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 Phone: 609.909.7033 Fax: 609.393.0243 [email protected]

Philip J. Passanante Assistant General Counsel Atlantic City Electric Company – 92DC42 500 N. Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 Phone: 609.909.7034 [email protected]

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May 6, 2020

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Attachment A

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Attachment APage 1 of 3

ATLANTIC CITY ELECTRIC COMPANYRGGI Recovery ChargeTransition Renewable Energy Certificate (TREC) Solar Program

SECTION I FORECASTED YEAR RECOVERY SCHEDULE

Table 1 - Forecasted Program Year Monthly ACE Delivered Sales (MWH)

Sep-20 1,007,961Oct-20 543,657Nov-20 582,417Dec-20 621,099Jan-21 737,005Feb-21 690,017Mar-21 681,000Apr-21 572,431May-21 566,136June-21 655,893July-21 911,112Aug-21 968,315

8,537,043

Table 2 - TREC Forecasted Program Year Revenue Requirement(ACE's Share -12.18%)

(1) (2) (3) (4)= Col 2 +Col 3

Monthly TREC Administrator RevenueMonth TREC Costs Fee Requirement

Jul-20 8,599$ 9,273$ 17,872$ Aug-20 64,319$ 9,273$ 73,593$ Sep-20 117,874$ 9,273$ 127,147$ Oct-20 129,198$ 9,273$ 138,471$ Nov-20 135,840$ 9,273$ 145,113$ Dec-20 153,826$ 9,273$ 163,099$ Jan-21 228,032$ 9,273$ 237,305$ Feb-21 290,223$ 9,273$ 299,496$ Mar-21 405,781$ 9,273$ 415,054$ Apr-21 471,756$ 9,273$ 481,029$ May-21 526,604$ 9,273$ 535,877$ June-21 608,303$ 9,273$ 617,576$ July-21 602,039$ 9,273$ 611,312$ Aug-21 595,993$ 9,273$ 605,266$

4,338,386$ 129,825$ 4,468,211$

SECTION II RGGI RECOVERY CHARGE (TREC COMPONENT) CALCULATION

Forecasted Revenue Requirement (Jul20-Aug21) 4,468,211$

Retail Sales - kwh 8,537,042,858$/KWH Surcharge 0.000523$ BPU Assessment 0.000001$ $/KWH Surcharge with SUT 0.000559$

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Attachment APage 2 of 3

ATLANTIC CITY ELECTRIC COMPANYNJ EDC TREC ForecastTransition Renewable Energy Certificate (TREC) Solar Program

Annual Administrator Fee $900,000TREC $/MWh $152.00

12.36%

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14)

Program Assumption

Program Assumption

Program Assumption

Col 2 * Col 3Program

AssumptionProgram

AssumptionProgram

Assumption

([Factor Col 5] * Col 5 + [Factor Col 6] * Col 6 + [Factor Col 7] * Col 7) *

[TREC Price] * Col 4

Prior Col 10 + Col 8

Sum of Col 4 per Col 9

Program Assumption

Col 8 + Col 12Col 13 * [ACE

Share] per Month

Calendar

New TI Project

Capacity by Month's End

Effective Generating

CapacityProduction

Estimate TRECs Created

Sub t, Sub r Roof & NM

NR Roof Comm Solar

Sub r Grnd, Resi Grnd & roof,NM NR

GrndTREC Procurement

Payments

Cumulative TREC Cost / Energy Year

TRECs / Energy Year

TREC Administrator

Fee

TRECProcurement

Payment + Administrator

Fee

Month

TREC Procurement Payments +

Administrator Fee -

ACE ShareYear Month (MWdc) (MWdc) (MWh/MW) (MWh) 1.00 0.85 0.6 ($) EY ($) (MWh) ($) ($)

1 2020 July 30 5 123 615 36% 0% 64% $69,549 21 $69,549 $75,000 $144,549 1 Jul-20 $17,8722 August 40 40 115 4,600 36% 0% 64% $520,205 21 $589,754 $75,000 $595,205 2 Aug-20 $73,5933 September 35 80 100 8,000 46% 0% 54% $953,344 21 $1,543,098 $75,000 $1,028,344 3 Sep-20 $127,1474 October 30 110 84 9,240 36% 0% 64% $1,044,933 21 $2,588,031 $75,000 $1,119,933 4 Oct-20 $138,4715 November 35 145 67 9,715 36% 0% 64% $1,098,650 21 $3,686,681 $75,000 $1,173,650 5 Nov-20 $145,1136 December 30 180 58 10,440 46% 0% 54% $1,244,114 21 $4,930,795 $75,000 $1,319,114 6 Dec-20 $163,0997 2021 January 30 220 72 15,840 34% 12% 54% $1,844,283 21 $6,775,078 $75,000 $1,919,283 7 Jan-21 $237,3058 February 20 240 84 20,160 34% 12% 54% $2,347,269 21 $9,122,347 $75,000 $2,422,269 8 Feb-21 $299,4969 March 30 270 102 27,540 40% 12% 47% $3,281,887 21 $12,404,234 $75,000 $3,356,887 9 Mar-21 $415,054

10 April 20 290 113 32,770 34% 12% 54% $3,815,477 21 $16,219,710 $75,000 $3,890,477 10 Apr-21 $481,02911 May 20 310 118 36,580 34% 12% 54% $4,259,083 21 $20,478,793 175,500 $75,000 $4,334,083 11 May-21 $535,87712 June 15 325 118 38,350 46% 12% 47% $4,919,845 22 $4,919,845 $75,000 $4,994,845 12 Jun-21 $617,57613 July 15 340 123 41,820 34% 12% 54% $4,869,186 22 $9,789,031 $75,000 $4,944,186 13 Jul-21 $611,31214 August 20 360 115 41,400 34% 12% 54% $4,820,285 22 $14,609,316 121,570 $75,000 $4,895,285 14 Aug-21 $605,266

Notes: 1Allocations for certain months intentionally do not add to 100%.

Column (1): Program assumption from BPU Staff that represents the solar capacity (MWdc) that is available to generate TRECs at the end of each month.Column (2): Program assumption from BPU Staff that represents the effective solar generation capacity (MWdc) that is available throughout each month.Column (3): The amount of solar generation output that is expected from each MWdc of Effective Generating Capacity (MWh/MWdc). It is based upon data sourced from PVWatts® Calculator (“PVWatts”),

which is an interactive website made available by the National Renewable Energy Laboratory (NREL). BPU Staff utilized PVWatts by entering typical system parameters for NJ solar facilities and using PVWatts output to develop the monthly Production Rate Estimates.

Column (4): The monthly quantity of TRECs created by TREC eligible solar generation facilities. It is calculated based upon Effective Generation Capacity (Column 2) multiplied by the Production Estimate (Column 3).Column (5): The respective allocation percentage of the monthly generation amount from the classification of TREC eligible solar generation systems and their associated TREC Factor.Column (6): The respective allocation percentage of the monthly generation amount from the classification of TREC eligible solar generation systems and their associated TREC Factor.Column (7): The respective allocation percentage of the monthly generation amount from the classification of TREC eligible solar generation systems and their associated TREC Factor.Column (8): The sum product of monthly TRECs Created (Column 4) and the Solar System Allocation Percentages and their corresponding TREC Price Multipliers (Columns 5, 6 & 7).Column (12): The monthly expense for the TREC Administrator to manage and implement the TREC Program on behalf the NJ EDCs.Column (13): The sum of the TREC Procurement Payment (Column 8) and the TREC Administrator Fee (Column 12).Column (14): ACE’s share of the TREC Procurement Payments + Administrator Fee.

NJ EDC TREC Forecast

TREC Revenue Requirements

Solar System Allocation Percentages and TREC Price Multipliers1

ACE Share

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Attachment APage 3 of 3

ATLANTIC CITY ELECTRIC COMPANYEDC 2019 Actual Billed Sales (kWh) Transition Renewable Energy Certificate (TREC) Solar Program

1 2 3 4 5 6 7 8 9 10 11 122019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019

January February March April May June July August September October November December Total

PSE&G 3,472,005,204 3,351,621,056 3,202,163,059 2,923,580,867 2,822,983,863 3,248,911,858 4,133,299,028 4,325,839,886 3,745,915,833 3,151,586,382 2,927,014,413 3,336,064,044 40,640,985,493 57.12%JCP&L 1,812,110,003 1,679,817,468 1,575,269,797 1,390,698,301 1,355,704,052 1,571,256,544 2,050,540,188 2,262,213,672 1,951,237,791 1,568,621,399 1,372,331,356 1,599,589,737 20,189,390,308 28.37%ACE 749,418,969 678,560,889 655,578,040 586,121,430 592,639,954 701,061,303 955,470,107 1,040,966,487 917,258,921 667,991,887 596,450,488 656,071,962 8,797,590,437 12.36%RECO 127,661,261 114,237,067 104,885,088 109,253,614 110,132,430 123,975,834 168,634,790 173,412,533 141,636,572 117,380,024 114,699,379 119,500,727 1,525,409,319 2.14%

Total 6,161,195,437 5,824,236,480 5,537,895,984 5,009,654,212 4,881,460,299 5,645,205,539 7,307,944,113 7,802,432,578 6,756,049,117 5,505,579,692 5,010,495,636 5,711,226,470 71,153,375,557 100.00%

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Attachment B Clean

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Attachment B Page 1 of 1

ATLANTIC CITY ELECTRIC COMPANY BPU NJ No. 11 Electric Service - Section IV Revised Sheet Replaces Revised Sheet No. 64

RIDER RGGI

Regional Greenhouse Gas Initiative Recovery Charge

A. Applicability

This Rider is applicable to Rate Schedules RS, MGS Secondary, MGS Primary, AGS Secondary, AGS Primary, TGS, DDC, SPL and CSL. Amounts billed to customers shall include a charge to reflect regional greenhouse gas initiative program costs. Except where indicated otherwise, Rider “RGGI” will be determined annually based on projections of program costs (including an adjustment for variances between budgeted and actual prior year expenditures) and forecasts of kilowatt hour sales. The charge (in dollars per kilowatt hour) will be computed by dividing the total annual amount to be recovered for by forecasted retail sales (in kilowatt hours). RGGI Programs Residential Controllable Smart Thermostat Program (RCSTP) ($/kWh) $0.000000 This charge component is intended to recover costs associated with the Residential Controllable Smart Thermostat Demand Response Program. Solar Renewable Energy Certificate (SREC) ($/kWh) $0.000334 This charge component is intended to recover net costs associated with the Solar Renewable Energy Certificate Program. Solar Renewable Energy Certificate (SREC II) ($/kWh) $0.000000 This charge component is intended to recover net costs associated with the Solar Renewable Energy Certificate II Program. Transition Renewable Energy Certificate (TREC) ($/kWh) $0.000559 This charge component is intended to recover net costs associated with the Solar Transition Incentive Program. Date of Issue: Effective Date: Issued by:

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Attachment B Redlined

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Attachment B Page 1 of 1

ATLANTIC CITY ELECTRIC COMPANY BPU NJ No. 11 Electric Service - Section IV Seventeenth Revised Sheet Replaces Sixteenth Revised Sheet No. 64

RIDER RGGI

Regional Greenhouse Gas Initiative Recovery Charge

A. Applicability

This Rider is applicable to Rate Schedules RS, MGS Secondary, MGS Primary, AGS Secondary, AGS Primary, TGS, DDC, SPL and CSL. Amounts billed to customers shall include a charge to reflect regional greenhouse gas initiative program costs. Except where indicated otherwise, Rider “RGGI” will be determined annually based on projections of program costs (including an adjustment for variances between budgeted and actual prior year expenditures) and forecasts of kilowatt hour sales. The charge (in dollars per kilowatt hour) will be computed by dividing the total annual amount to be recovered for by forecasted retail sales (in kilowatt hours). RGGI Programs Residential Controllable Smart Thermostat Program (RCSTP) ($/kWh) $0.000000 This charge component is intended to recover costs associated with the Residential Controllable Smart Thermostat Demand Response Program. Solar Renewable Energy Certificate (SREC) ($/kWh) $0.000334 This charge component is intended to recover net costs associated with the Solar Renewable Energy Certificate Program. Solar Renewable Energy Certificate (SREC II) ($/kWh) $0.000000 This charge component is intended to recover net costs associated with the Solar Renewable Energy Certificate II Program. Transition Renewable Energy Certificate (TREC) ($/kWh) $0.000559 This charge component is intended to recover net costs associated with the Solar Transition Incentive Program. Date of Issue: February 19, 2019 Effective Date: March 1, 2020 Issued by: David M. Velazquez, President and Chief Executive Officer – Atlantic City Electric Company Filed pursuant to Board of Public Utilities of the State of New Jersey directives associated with the BPU Docket Nos. ER19060697 AND ER19070816 Issued by:

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Attachment C

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Attachment C Page 1 of 2

NOTICE OF FILING AND PUBLIC HEARINGS

TO CUSTOMERS OF ATLANTIC CITY ELECTRIC COMPANY

In the Matter of the Verified Petition of Atlantic City Electric Company concerning the

Initial Setting of the Regional Greenhouse Gas Initiative Recovery Charge (“Rider RGGI”) Associated with the New Jersey Solar Transition Incentive Program (2020)

BPU Docket No. _________________

PLEASE TAKE NOTICE that, on or about May 7, 2020, Atlantic City Electric Company (“ACE” or the “Company”) filed a Petition (the “Petition”) with the New Jersey Board of Public Utilities (the “Board” or “BPU”) to establish an initial Rider Regional Greenhouse Gas Initiative Transition Renewable Energy Certificate (“TREC”) Recovery Charge (“Rider RGGI TREC Charge”). ACE’s Rider RGGI TREC charge is intended to allow the Company to recover its costs and expenses incurred as a result of its compliance with the Board’s Orders in BPU Docket No. QO19010068 establishing the TREC Program. The TREC Program was created by the Board to foster the continued development of solar renewable power generation in the State of New Jersey. As filed, the Petition proposed to set the initial Rider RGGI TREC charge to become effective on and after September 1, 2020 reflecting projected program costs and revenues for the period July 1, 2020 through August 31, 2021. The Company’s projected program revenue requirement of $4,468,211 is primarily based upon forecasts developed by the Staff of the Board. The proposed Rider RGGI TREC charge for all rate classes is $0.000559 per kWh. The approximate impact of the proposed increase on a typical residential customer’s monthly bill, subject to Board approval of the proposed change to Rider RGGI, is demonstrated in Table 1.

TABLE 1

IMPACT OF RIDER RGGI CHANGE ON RESIDENTIAL ELECTRIC BILLS

Monthly kWh Use

Present Bill

Proposed Bill

Proposed Increase ($)

Proposed Increase (%)

100 $24.11 $24.17 $0.06 0.25% 300 $60.80 $60.97 $0.17 0.28% 500 $97.50 $97.78 $0.28 0.29% 750 $143.35 $143.77 $0.42 0.29% 1000 $190.94 $191.50 $0.56 0.29% 2000 $381.26 $382.38 $1.12 0.29% 2500 $476.42 $477.82 $1.40 0.29% 3000 $571.59 $573.26 $1.67 0.29%

Based upon the Company’s filing, a typical residential customer using 679 kWh per month would see an increase in the customer’s monthly bill of $0.38 or 0.29%.

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Attachment C Page 2 of 2

It is important to note that the resolution of this Petition and the reconciliation of these accounts will not result in any profit to the Company. The Board has the statutory and regulatory authority to approve and establish the reconciliation of these accounts and charges at levels it finds just and reasonable. Therefore, the BPU may determine and establish these charges at levels other than those proposed by ACE. This Petition was filed with the Board and copies were also served upon Rate Counsel. Copies of the Petition are posted on ACE’s website at www.atlanticcityelectric.com/PublicPostings. The following date, time(s), and location for virtual public hearings have been scheduled on the Petition so that members of the public may present their views:

Date: , 2020 Date: , 2020 Time: ___________ Time: ___________ Dial-in Number: 1-855-470-3100 Passcode: 617161#

Dial-in Number: 1-855-470-3100 Passcode: 617161#

Due to the COVID-19 pandemic, a telephonic hearing on the Petition will be conducted at the date and times listed above by a hearing officer designated by the Board. Representatives of the Board’s Staff and the Division of Rate Counsel will participate via phone in the public hearing. Members of the public are invited to listen and participate by phone via the above designated dial-in number and passcode and may express their views on this filing. Such comments will be made a part of the final record of the proceeding to be considered by the Board. Customers may also file written comments with the Secretary of the Board of Public Utilities at 44 South Clinton Avenue, 9th Floor, Trenton, New Jersey 08625-0350 or [email protected], whether or not they participate in the public hearings.

Dated: __________, 2020 Atlantic City Electric Company

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IN THE MATTER OF THE PETITION OF ATLANTIC CITY ELECTRIC COMPANY CONCERNING THE INITIAL SETTING OF THE REGIONAL GREENHOUSE GAS INITIATIVE RECOVERY CHARGE (“RIDER RGGI”) ASSOCIATED WITH THE NEW JERSEY SOLAR TRANSITION INCENTIVE PROGRAM

STATE OF NEW JERSEY

BOARD OF PUBLIC UTILITIES

CERTIFICATION OF SERVICE

ANDREW J. MCNALLY, of full age, certifies as follows:

1. I am an attorney at law of the State of New Jersey and I am Assistant General

Counsel to Atlantic City Electric Company, the Petitioner in the within matter, with which I am

familiar.

2. I hereby certify that, on the date below, I caused the within Petition and the

supporting attachments thereto, to be filed with the New Jersey Board of Public Utilities through

its eFiling Portal. I also caused an electronic copy to be sent to the Board Secretary’s office at

[email protected].

3. I further certify that, on the date below, I caused a complete copy of the Petition

and the supporting schedules, attachments and/or exhibits thereto, to be sent by electronic mail to

each of the parties listed in the attached Service List.

4. Consistent with the Order issued by the Board in connection with In the Matter of

the New Jersey Board of Public Utilities’ Response to the COVID-19 Pandemic for a Temporary

Waiver of Requirements for Certain Non-Essential Obligations, BPU Docket No. EO20030254,

Order dated March 19, 2020, only electronic copies of this Petition have been served on persons

on the service list.

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5. I further and finally certify that the foregoing statements made by me are true. I

am aware that, if any of the foregoing statements made by me are willfully false, I am subject to

punishment.

Dated: May 7, 2020 ANDREW J. MCNALLY

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In the Matter of the Petition of Atlantic City Electric Company Concerning the Initial Setting of the Regional Greenhouse Gas Initiative Recovery Charge (“Rider RGGI”) Associated with the

New Jersey Solar Transition Incentive Program BPU Docket No.

Service List

BPU Aida Camacho-Welch Secretary of the Board Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected] [email protected]

Abraham Silverman, Esquire Chief Counsel Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Stacy Peterson Director, Division of Energy Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Rachel Boylan, Esquire Legal Specialist Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Ilene Lampitt, Esquire Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Paul Lupo Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Stephan Luma Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Andrea Hart Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

B. Scott Hunter Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Christine Lin Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Ryan Moran Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

Jackie O’Grady Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350 [email protected]

DIVISION OF LAW Pamela L. Owen, Esquire Division of Law Hughes Justice Complex 25 Market Street P.O. Box 112 Trenton, NJ 08625 [email protected]

Jenique Jones Division of Law Hughes Justice Complex 25 Market Street P.O. Box 112 Trenton, NJ 08625 [email protected]

RATE COUNSEL Stefanie A. Brand, Esquire Director Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected]

Maura Caroselli, Esquire Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected]

Ami Morita, Esquire Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected]

Felicia Thomas-Friel, Esquire Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected]

Sarah Steindel, Esquire Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected]

Brian O. Lipman, Esquire Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected]

ER20050344

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James Glassen, Esquire Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected] Kurt Lewandowski, Esquire Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected] Shelley Massey Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ 08625-0003 [email protected] ACE Andrew J. McNally, Esquire Atlantic City Electric Company 92DC42 500 N. Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 [email protected] Philip J. Passanante, Esquire Atlantic City Electric Company 92DC42 500 N. Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 [email protected] Susan DeVito Director Pricing & Regulatory Services 92DC56 Pepco Holdings, LLC 500 N. Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 [email protected] Thomas M. Hahn Principal Rate Analyst 63ML36 Atlantic City Electric Company 5100 Harding Highway Mays Landing, NJ 08330 [email protected]

Heather Hall Manager, Regulatory Affairs NJ Atlantic City Electric Company 92DC56 500 N. Wakefield Drive P.O. Box 6066 Newark, DE 19714-6066 [email protected]