Details for: SCE's Comments to CSE Advice 82-E.pdf

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Russell G. Worden
Managing Director, State Regulatory Operations

August 23, 2017
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue, 4th Floor
San Francisco, CA 94102

Southern California Edison Company’s Comments on the
Center for Sustainable Energy’s Advice Letter 82

Dear Energy Division Tariff Unit:
On August 3, 2017, the Center for Sustainable Energy (CSE) filed Advice Letter (AL)
82, Advice Filing to Propose Modifications to the Self-Generation Incentive Program to
Incorporate California Contractors State License Board’s C-46 Solar Contractor License
Classification into List of SGIP-Eligible Licenses for the Combined Installation of Solar
Photovoltaics and Energy Storage, with the California Public Utilities Commission
(CPUC or Commission). In AL 82, CSE proposes the Commission authorize it to modify
the SGIP Handbook to make C-46 contractors eligible to install energy storage (ES)
systems paired with solar photovoltaic systems. CSE proposes to allow C-46
contractors to work on both the solar photovoltaic and ES components of the system.
AL 82 follows joint advice filings previously made on June 13, 2017 by the three SGIP
administrators, in SCE’s case AL 3616-E. Those filings also proposed the Commission
permit C-46 contractors to work on paired systems. As the Commission is aware, as a
result of valid protests by International Brotherhood of Electrical Workers (IBEW) and
National Electric Contractors Association (NECA) to the joint advice filings, all three
SGIP administrators withdrew their respective advice letters on July 11, 2017.
The informal guidance CSE attached to AL 82 does not alter the existing regulatory
framework discussed in SCE’s withdrawal of AL 3616-E. SCE therefore stands by the
reasoning set forth in its withdrawal of AL 3616-E.

/s/ Russell G. Wordenn
Russell G. Worden


P.O. Box 800

Edward Randolph, Director, CPUC Energy Division
James Loewen, CPUC Energy Division
8631 Rush Street

Rosemead, California 91770

(626) 302-4177

FAX (626) 302-5210


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Energy Division Tariff Unit Page 2 August 23, 2017 Patrick Doherty, CPUC Energy Division Sephra Ninow, CSE Service List R.12-11-005
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