Details for: SDGE Protest Reply to AL 3227-E.pdf


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

June 12, 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 Advice Letter 3227-E: San Diego
Gas & Electric Proposed Work Plan for Implementing the Distribution Resources
Planning Data Access Portal Pursuant to 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 Green Power Institute (“GPI”) to SDG&E
Advice Letter (“AL”) 3227-E, San Diego Gas & Electric Proposed Work Plan for Implementing
the Distribution Resources Planning (“DRP”) Data Access Portal Pursuant to Decision 18-02004, filed on May 16, 2018.
Background
Pursuant to California Public Utilities Commission (“Commission”) Decision 18-02-004 (“D.”),
Ordering Paragraph (“OP”) 2.m, SDG&E submitted a Tier 3 advice letter detailing work plans
which include a high-level description of the steps necessary to develop the DRP data access
portal and proposes estimated interim milestones and deadline for implementation based on
those steps outlined in D.18-02-004. As referenced in AL 3227-E, SDG&E’s proposed
workplan to implement the DRP data access portal incorporates applicable aspects of a data
redaction criteria proposal SDG&E filed with AL 3210-E. The disposition of AL 3210-E has
been suspended, and a ruling was issued on June 8, 2018 by the Administrative Law Judge to
the DRP proceeding informing of next steps to addressing and resolving SDG&E’s proposed
data redaction criteria.
On June 5, 2018, Green Power Institute (“GPI”) filed a protest to SDG&E’s AL 3227-E,
requesting the Commission address, in part, the following issue:
Aspects of SDG&E’s proposed Data Access Portal work plan do not comply with the
Commission’s requirements:
SDG&E’s proposed Data Access Portal work plan fails to provide any pathway
for developing an Application Programming Interface (“API”) for the Data Access
Portal as required in Commission D.18-02-004.





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Public Utilities Commission June 12, 2018 SDG&E’s Response to Protest of AL 3227-E As mentioned in SDG&E’s proposed data redaction criteria, SDG&E feels very strongly that some of the data required to be made public and available by APIs places the electric system at greater and unacceptable physical and cyber security risk. SDG&E’s proposed workplan to implement a DRP data access portal specifically informs that the plan aligns with SDG&E’s proposed data redaction criteria, and accordingly, excludes incorporating an API. As mentioned in the work plan, as applicable, SDG&E will file an updated DRP Data Access Portal work plan to reflect the outcome of AL 3210-E. Conclusion SDG&E respectfully requests that the protests of GPI be rejected for the reasons stated above and SDG&E’s Advice Letter 3227-E is approved as written. Sincerely, ________________________ CLAY FABER Director – CA & Federal Regulatory cc: Edward Randolph – Energy Division Director Greg Morris – GPI Director 2
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