Details for: 4066-E (Part 1 of 1).pdf

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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

August 30, 2019
(U 338-E)

Information-Only Advice Letter
Southern California Edison Company’s Expedited
Interconnection Process for Non-Exporting Storage Facilities
Pilot Pursuant to Decision 16-06-052

Pursuant to California Public Utilities Commission (Commission or CPUC) Decision
(D.)16-06-052,1 Southern California Edison Company (SCE) respectfully submits this
information-only Advice Letter (AL) to convey the results of its extended Expedited
Interconnection Process for Non-Exporting Storage Facilities Pilot (Pilot).
On October 21, 2016, SCE submitted Advice 3493-E to implement a new expedited
interconnection process for eligible non-exporting storage facilities in accordance with
Commission D.16-06-052 (or the Decision). Specifically, SCE proposed to process
these eligible projects in a timeframe not to exceed 15 business days (BD) from the
date the applicant’s interconnection request (IR) was deemed valid and complete, and
all applicable fees were received, through the issuance of a draft Generator
Interconnection Agreement (GIA). The standard compliance timeframe for Fast Track
projects from deemed complete to issuance of a draft GIA (without upgrades) was 30
BD. SCE proposed to fully launch this new process no later than the end of Q2 2017,
with interim milestones occurring throughout the beginning of 2017.2


D.16-06-052 - Alternate Decision Instituting Cost Certainty, Granting Joint Motions to
Approve Proposed Revisions to Electric Tariff Rule 21, and Providing Smart Inverter
Development a Pathway Forward for Pacific Gas and Electric Company, Southern
California Edison Company, and San Diego Gas & Electric Company, was adopted on June
23, 2016.
See Advice 3493-E-A at p. 7.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4066-E (U 338-E) -2- August 30, 2019 In Advice 3493-E-B, submitted on January 31, 2017, SCE proposed to report on the outcome of the new expedited process, in part by including a comparison of interconnection timelines for projects interconnected in 2015-2016 to those for projects interconnecting after the launch of the expedited process.3 The projects would be tracked under the new process from July 1, 2017 through June 30, 2018. On August 31, 2018, SCE submitted Advice 3858-E, which proposed extending the Pilot for one (1) year in order to gather additional data.4 SCE hereby submits this advice letter to report on the outcome of the second year of the Pilot. This advice letter includes successes, challenges and lessons learned, and proposed changes, including: a. whether the expedited process is still necessary and if it should continue to be implemented like a pilot; b. consideration of changes to any fees; and c. any other items that warrant consideration as identified during the reporting period. PILOT RESULTS AND OBSERVATIONS Non-exporting storage facilities that met the agreed upon eligibility criteria included in Attachment B of Advice 3493-E were eligible to participate in the Pilot. These IRs would be processed in a timeframe not to exceed 15 BD from the date the IR is deemed valid and complete by SCE, and all applicable fees are received.5 Attachment A herein contains data comparing interconnection timelines from July 1, 2018 to July 31, 2019. The data displays there were fewer data outliers and a more consistent average in the number of days from deemed complete to the applicant receiving a draft GIA. The median decreased from 23 days in 2015 and 2016 to 16 days after implementation of the Pilot in 2017, to a 15 BD median in the second year of the pilot. Between July 1, 2018 and July 31, 2019, only 34 requests were eligible to proceed with the Pilot. This is a significant decline from the 87 eligible Pilot requests that were included in the reporting data for Advice 3858-E in 2018. 3 4 5 See Advice 3493-E-B at p. 2. See Advice 3858-E at p. 3. Advice 3858-E was effective as of August 31, 2018. Processing the IR means that SCE will complete the technical review process and issue a draft GIA to the applicant within 15 BD of deeming the applicant’s IR valid and complete and receiving payment of all applicable fees (i.e., the $800 IR fee).
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ADVICE 4066-E (U 338-E) -3- August 30, 2019 THE EXPEDITED PROCESS PURSUANT TO SECTION N IS NO LONGER NECESSARY SCE proposes to discontinue the Pilot. Advice 3858-E proposed extending the Pilot to allow additional time to refine the established manual processes and seek improvement opportunities that can be factored into the development of a new online interconnection portal. The lessons learned from this Pilot will be utilized in the future online IR portal. The decision regarding discontinuing this Pilot will not impact SCE’s commitment to any proposed expedited processes that are under consideration. CONSIDERATION OF CHANGES TO FEES SCE does not propose any changes to the existing Rule 21 $800 IR fee. The expedited process pursuant to Section N is a manual process, which contains redundancies for quality assurance purposes. For this reason, SCE has not identified any significant internal processing changes that would support a fee change. ADDITIONAL ITEMS THAT WARRANT CONSIDERATION IDENTIFIED DURING THE REPORTING PERIOD There are no additional items proposed by SCE at this time. No cost information is required for this advice letter. This advice letter will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.1, this advice letter is submitted with a Tier 1 designation. NOTICE In accordance with GO 96-B, General Rule 6.2, this information-only advice letter is not subject to protest. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached service lists for GO 96-B and R.11-09-011 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at
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ADVICE 4066-E (U 338-E) -4- August 30, 2019 Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at For questions, please contact Mary J. Brown at (626) 302-8103 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:mb:cm Enclosures
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 4066-E Subject of AL: Information-Only Advice Letter - Southern California Edison Company’s Expedited Interconnection Process for Non-Exporting Storage Facilities Pilot Pursuant to Decision 16-06-052 Keywords (choose from CPUC listing): Compliance, Storage AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 16-06-052 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: No. of tariff sheets: -0- Estimated system annual revenue effect (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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Attachment A
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Attachment A About the Data Section N of Southern California Edison’s (SCE’s) Electric Tariff Rule 21, Generating Facility Interconnections, contains the Expedited Interconnection Process for Non-Export Energy Storage Generating Facilities pilot. For the purpose of this report, data relating to Section N has been labelled as the “Expedited Process.” Note that only projects that were eligible to proceed under the Expedited Process and received a Draft Interconnection Agreement have been included in the data set. Between July 3, 2018 and July 31, 2019, SCE received a total of 116 Rule 21 Non-Export requests that selected the Expedited Process pursuant to Section N. Of the 116 requests, only 34 were eligible to proceed with the Expedited Process pursuant to Section N. Of those 34 eligible expedited projects, 33 have received a Draft Interconnection Agreement; one project is still pending Fast Track results as of 8/9/2019. For comparison data, please see Attachment A to Advice 3858-E submitted to the CPUC by SCE on August 31, 2018. Note that the “Median” listed in the graphs below is the median for the entire data set for either the Expedited Process or the Standard Process, as applicable. A copy of SCE’s Rule 21 Tariff is available at the following website:
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