Details for: PG&E's Reply to Protest of AL 4117-G_5582-E.pdf

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Erik Jacobson
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

August 1, 2019

California Public Utilities Commission - Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102

Pacific Gas and Electric Company’s Reply to the Protest of Advice
Letter 4117-G/5582-E Regarding Plans for the Communication of Fire
and Weather Data and Modeling Information As Required by
Decision 19-05-037

Dear Energy Division Tariff Unit:
In Decision (D.) 19-05-037, the California Public Utilities Commission (Commission)
directed Pacific Gas and Electric Company (PG&E) to submit a Tier 1 Advice Letter
addressing PG&E’s plan for communicating fire and weather data and modeling
information. PG&E submitted Advice Letter 4117-G/5582-E (Advice Letter) on July 5,
2019, and included detailed information on the tools and information available to
PG&E’s Wildfire Safety Operations Center (WSOC), its current and future plans for
communicating this information, the process for communications, and additional
communications during emergency events.
Protests and responses to the Advice Letter were filed by: (1) the Northern California
Power Agency (NCPA); (2) the Counties of Mendocino, Napa and Sonoma and the City
of Santa Rosa (Joint Local Governments); (3) the California Municipal Utilities
Association (CMUA); and (4) Sonoma Clean Power, Marin Clean Energy, Pioneer
Community Energy, and San Jose Clean Energy (Joint CCAs).
In general, the responses and protests supported and recognized the significant efforts
that PG&E has made to communicate data and information. For example, the Joint
Local Governments expressed appreciation for PG&E’s “efforts in increase its own
situational awareness” and its engagement with local governments “to better
understand the challenges faced by utilities’ public safety partners . . ..” 1 The Joint
Local Governments also noted that PG&E’s proposals for information sharing are a


Joint Local Governments Protest at p. 1.


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PG&E’s Reply to Protest of Advice Letter 4117-G/ 5582-E -2- August 1, 2019 “good start.” 2 CMUA indicated that it “strongly supports PG&E’s proactive efforts to reduce the fire risk associated with operation of its electric infrastructure.” 3 However, parties filing protests/responses did propose some modifications to PG&E’s plans for communication of fire and weather data and modeling information. The issues raised by these parties are addressed below. 1. Process For Communicating WSOC Tools and Information In the Advice Letter, PG&E provided a detailed overview of its plan and timelines for sharing WSOC tools and information with key stakeholders. 4 No party opposed this proposal, but NCPA and CMUA asked that they be included in these meetings. 5 PG&E proposed limiting these meetings to key state-wide stakeholders including CAL FIRE, the California Office of Emergency Services (Cal OES), the US Forest Service, and the Commission. These stakeholders have a state-wide perspective on fire risk issues. PG&E has found that increasing the numbers of stakeholders in meetings can result in slowing down the ability to communicate information and can also impact dialogue regarding proposed plans. Given that fire season has already started, and the critical need to work directly with these state-wide entities, PG&E believes that limiting participation in these initial meetings will ensure that they are productive and accomplish the desired purpose. PG&E understands, however, NCPA’s and CMUA’s interest in participating in information sharing meeting. PG&E does not oppose expanding these types of meetings in the future to include NCPA, CMUA members, cities, counties, Community Choice Aggregators (CCAs), and other interested parties, and welcomes the future involvement and feedback of these parties. PG&E plans to continue to expand its outreach regarding information sharing as its WSOC program evolves. However, for 2019, with fire season already started and the critical need to transmit information, PG&E recommends that the participation in these meetings be limited as currently proposed in the Advice Letter. 2. Access to Fire, Weather, and Modeling Information The Advice Letter outlines in detail the fire, weather, and modeling information that PG&E has developed, and how it currently communicates this information and plans to do so in the future. 6 NCPA, CMUA and Joint Local Governments request that PG&E share its fire danger forecasts and Storm Outage Prediction Project (SOPP) model information with local utilities and electrical cooperatives connected to PG&E’s system, as well as local 2 3 4 5 6 Id. at p. 5. CMUA Protest at p. 1. Advice Letter at pp. 5-6. NCPA Protest at pp. 2-3; CMUA Protest at p. 3. Advice Letter at pp. 2-5.
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PG&E’s Reply to Protest of Advice Letter 4117-G/ 5582-E -3- August 1, 2019 agencies. 7 As PG&E explained in the Advice Letter, this information is utility-specific and may cause confusion for first responders and other parties because the information focuses on utility assets, not the most at-risk overall locations for damage or hazard to people and property. 8 NCPA and CMUA acknowledge this concern. 9 More importantly, other agencies, including CAL FIRE who has overall responsibility for wildfires in California, are the appropriate authorities and resources for wildfire risk forecasts for local jurisdictions, first responders and others. The Joint Local Governments request that PG&E make Public Safety Power Shutoff (PSPS) information available on a portal. 10 Since the Advice Letter was filed, PG&E has continued to develop new ways to communicate information to its safety partners, as well as the public. PG&E is developing a comprehensive weather and PSPS outlook website that will soon be live and will provide detailed information and forecasts that will assist safety partners and our communities regarding the weather and utility-specific fire risk outlook. 11 This site will feature a seven-day PSPS potential forecast that will be published daily by PG&E’s operational meteorologists and fire weather specialists. It will include a written forecast discussion that describes the weather forecast and any upcoming events (e.g., offshore wind events), of concern. In addition, it will also include a forecast table indicating the potential for PSPS from “not expected” to “PSPSWarning”, in nine broad geographic areas in PG&E’s service territory for a quick overview of expectations over the next week. The site will also feature an interactive map that displays the latest weather station data from hundreds of weather stations in the territory, as well as any red flag warnings from the National Weather Service. This site is also being designed to be accessible on mobile devices. PG&E believes that this website, once complete, will provide much of the insight being requested by the Joint Local Governments. In addition, PG&E recently deployed a Satellite-based Fire Detection and Alerting system that leverages 5 satellites including the next generation of geosynchronous satellites. More details on the system can be found in this news release: _introduces_revolutionary_wildfire_monitoring_using_satellite_technology_in_the_fight _against_california_wildfires. PG&E is actively working to make this data publicly available, which is currently planned for late Q3 2019. Joint Local Governments also request that PG&E’s Public Safety Specialists contact local OES and government agencies directly. 12 PG&E agrees that coordination with NCPA Protest at pp. 3-4; CMUA Protest at pp. 2-3; Joint Local Governments Protest at p. 3. 8 Advice Letter at p. 4. 9 NCPA Protest at p. 3; CMUA Protest at 2. 10 Joint Local Governments Protest at pp. 1-2. 11 PG&E’s Safety Action Center will be available at: www.safetyactioncenter.pge 12 Joint Local Governments Protest at pp. 2-3. 7
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PG&E’s Reply to Protest of Advice Letter 4117-G/ 5582-E -4- August 1, 2019 local agencies is important and will continue to work on the appropriate communication methods for state and local entities, following California’s Standardized Emergency Management System (SEMS). 3. PSPS Issues Raised by the Joint CCAs The Joint CCAs’ protest is primarily focused on the communication of PSPS-related information to local agencies and CCAs. PG&E has several concerns with the Joint CCAs’ arguments. First, as the Joint CCAs acknowledge, these issues are being addressed in Rulemaking 18-12-005 and thus are beyond the scope of the Advice Letter. 13 While the issues raised by the Joint CCAs are important, they should not and need not be addressed here. Second, the Joint CCAs fail to describe the substantial outreach and efforts that PG&E has already made with these entities regarding PSPS events. For example, PG&E has had extensive meetings with San Jose regarding the very issues raised in the Joint CCAs protest. These issues can and should continue to be addressed through these discussions, rather than in a protest to the Advice Letter. Third, the Joint CCAs request improvements to PG&E’s PSPS web portal. 14 As explained above in Section 2, PG&E is continuing to evolve and improve the PSPS information provided to the public. PG&E’s new Safety Action Center should address many of the issues raised by the Joint CCAs. Finally, even if the Joint CCAs were raising issues within the scope of the Advice Letter, which they are not, their proposals raise significant concerns regarding access to market-sensitive information. The Joint CCAs are active participants in California’s energy markets. Providing potential outage information related to PSPS events 15 could create market manipulation issues and raises concerns about the potential violation of Federal Energy Regulatory Commission (FERC) and Commission market rules. In addition, the Joint CCAs are requesting customer data that is protected by Commission rules and policies and that PG&E is already willing to provide pursuant to a standard non-disclosure agreement which complies with the Commission’s privacy rules 16. In short, the Joint CCAs’ requests raise potential concerns that are well-beyond the scope of the Advice Letter. The Joint CCAs’ request requires careful consideration and should not be addressed simply through a protest to an advice letter. Joint CCAs Protest at p. 2 (acknowledging that PSPS issues are being addressed by the Commission in R.18-12-005). 14 Joint CCAs Protest at pp. 5-6. 15 See Joint CCAs Protest at p. 6. 16 Under the PSPS decision and implementation, numerous local governments and agencies already have executed PG&E’s NDA for access to customer information during PSPS events with no significant objections. 13
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PG&E’s Reply to Protest of Advice Letter 4117-G/ 5582-E 4. -5- August 1, 2019 Conclusion For the foregoing reasons and based on the information provided in the Advice Letter, PG&E respectfully requests that the Energy Division approve PG&E’s Advice Letter to become effective July 5, 2019. /S/ Erik Jacobson Director, Regulatory Relations cc: Laura Fernandez, Attorney, Braun Blaising Smith Wynne, P.C., Megan Somogyi, Counsel for the Counties of Mendocino, Napa, and Sonoma, and the City of Santa Rosa, Counsel for the Northern California Power Agency, and David Peffer, Braun Blaising Smith Wynne, P.C., on behalf of Marin Clean Energy, Sonoma Clean Power, Pioneer Community Energy and City of San Jose,
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