Details for: SDGE Protest Reply - AL 3211-E.PDF


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Clay Faber - Director
CA & Federal Regulatory
8330 Century Park Ct
San Diego, CA 92123
cfaber@semprautilities.com

May 14, 2018
ED Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, California 94102
Re:

Reply of San Diego Gas & Electric to Protest of SDG&E Advice Letter 3211-E: San
Diego Gas & Electric Submission of Proposed Work Plans Pursuant to Ordering
Paragraph 2.K of Decision 18-02-004

In accordance with Section 7.4.3 of General Order 96-B, San Diego Gas & Electric Company
(“SDG&E”) hereby replies to the Protests filed by the Office of Ratepayer Advocates (“ORA”) and
the Response by the Interstate Renewable Energy Council (“IREC”) to SDG&E Advice Letter
(“AL”) 3211-E, SDG&E Submission of Proposed Work Plans Pursuant to California Public Utilities
Commission (“Commission”) Ordering Paragraph (“OP”) 2.k of Decision (“D.”) 18-02-004, filed on
April 16, 2018.
Background
Pursuant to D.18-02-004, OP 2.k, SDG&E filed AL 3211-E with proposed work plans presenting
the development and implementation of data compilation and reporting capabilities needed to
complete the annual Grid Needs Assessment (“GNA”) and Distribution Deferral Opportunities
Report (“DDOR”) exercise, including a high-level description of the steps necessary to develop
such internal capabilities and estimated interim milestones. The work plans also include proposed
formats for the GNA and DDOR datasets based on the requirements laid out in D.18-02-004.
SDG&E’s proposed work plans reflects redacting/modifying certain data in the applicable GNA
and/or DDOR datasets consistent with SDG&Es proposed data redaction criteria (AL 3210-E).
On May 7, 2018, ORA filed a protest and IREC filed a response to SDG&E’s AL 3211-E,
requesting the Commission address, in part, the following issue:
Work plans and provided data should comport with the Commission’s decision(s)
on redaction criteria: ORA and IREC each note that SDG&E’s proposed work plans
to develop and implement data compilation and reporting capabilities needed to
complete the GNA and DDOR exercise (AL 3211-E) reflect presumed approved
data redaction criteria that SDG&E proposes in concurrently filed AL 3210-E. ORA
and IREC request that SDG&E’s compilation and reporting of data associated with
the GNA and DDOR exercise reflect what the Commission has directed and not





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Public Utilities Commission May 14, 2018 reflect a presumed outcome of the advice letter with SDGE’s proposed redaction criteria. SDG&E’s Response SDG&E’s reported and compiled data will comport with Commission directives SDG&E understands the importance of complying with Commission directives, and will develop and implement data compilation and reporting capabilities needed to complete the annual GNA and DDOR exercise in a manner that reflects the Commission’s directives. As applicable, SDG&E will file a supplement to AL 3211-E modifying SDG&E’s proposed work plans to reflect the outcome of AL 3210-E. Conclusion SDG&E respectfully requests that ORA’s protest of AL 3211-E be rejected for the reasons stated above and SDG&E’s Advice Letter 3211-E is approved as written. Sincerely, ________________________ CLAY FABER Director – CA & Federal Regulatory cc: Edward Randolph – Energy Division Director Gabriel Petlin – Energy Division Marc Monbouquette – Energy Division Chloe Lukins – Office of Ratepayer Advocates Sky C. Stanfield – Attorney for IREC Aaron M. Stanton – Attorney for IREC Service List R.14-08-013 2
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