Details for: 4067-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)

Rule 21 Data Integrity Clarification

This purpose of this advice letter is to provide clarification on what Southern California
Edison Company (SCE) considers confidential design information pursuant to Rule 21,
Section D.7.a. as it relates to monthly submissions to the California Public Utilities
Commission (Commission or CPUC) and Energy Solutions involving Rule 21
interconnection data, which is posted by Energy Solutions to the California Distributed
Generation (DG) Stats website.
In a memorandum from Edward Randolph, Director of the Energy Division, dated
August 21, 2018 (Memorandum), the Investor Owned Utilities (IOUs) were authorized to
work with Energy Solutions to regularly publish data on all Rule 21 interconnections to
the California DG Stats website ( beginning March 1, 2019,
and for Energy Solutions to create basic charts and graphs using this interconnection
data by June 1, 2019.
As stated in this Memorandum, the vision for DG Stats is to provide easy access to
high-quality, up-to-date distributed generation data which delivers valuable information
to the Commission, program administrators, market participants, researchers and the
general public to support research, innovation, and decision-making in the public and
private sectors. Providing data on all Distributed Energy Resources (DERs), rather than
a subset of DERs, increases the scope and relevancy of analyses that may be
performed using this data.2 Additionally, DG data collection is funded by ratepayers and


California DG Statistics is the official public reporting site of the California Solar Initiative
(CSI), presented jointly by the CSI Program Administrators, GRID Alternatives, the California
IOUs, and the California Public Utilities Commission (Commission or CPUC).
Until recently, DG Stats only hosted data on projects participating in Self-Generation

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4067-E (U 338-E) -2- August 30, 2019 should be made available to the extent it does not contain personally identifiable information. To this end, the Energy Division directed the IOUs to work with Energy Solutions to publish application-level data, charts, and graphs on all Rule 21 interconnections, regardless of technology type, size, tariff, incentive program, or other project characteristics. Specific data fields to be published were determined by Energy Division staff in consultation with Energy Solutions and the IOUs. The Memorandum ordered that no confidential information or personally identifiable information pursuant to the Commission’s General Order (GO) 66-D, and in accordance with any privacy requirements specified in Decision (D.)14-05-016 and Rulemaking 08-09-133, would be published. SCE began submitting its Rule 21 datasets in response to the Memorandum in March 2019. Monthly datasets are submitted to the Commission under the terms of a GO 66-D declaration, requesting confidential treatment of certain fields. Similarly, when SCE submits the dataset to Energy Solutions, it is under the terms of a nondisclosure agreement between SCE and Energy Solutions. The same fields are marked as confidential in both the dataset submitted to the Commission and the dataset submitted to Energy Solutions, but there are procedural differences in how SCE must request confidential treatment. It is important to note that the effect of SCE marking certain data as confidential is that these data fields cannot be posted to DGStats. Among other things, SCE has requested confidential treatment of the model, manufacturer name, and number of inverters and generators that make up a customer’s generating facility (interconnection design data) and considers this treatment to be consistent with Rule 21, Section D. General, Rules, Rights and Obligations, Subsection 7.a. which states: “Confidential Information shall include, without limitation, confidential, proprietary or trade secret information relating to the present or planned business of Applicant, Customer, Producer, or Distribution Provider (individually referred to in Section D.7 as Party or collectively as Parties), including all information relating to a Party's technology, research and development, business affairs, and pricing… Information is Confidential Information only if it is clearly designated or marked in writing as confidential on the face of the document (including electronic materials), or, if the information is conveyed orally or by inspection, if the Party Incentive Program or customer-sited solar programs (e.g. CSI, Net Energy Metering, New Solar Homes Partnership). In January, March, and June of 2018, Energy Division communicated to the IOUs the vision for DG Stats to host data on all DG projects regardless of technology type, program, or tariff, and requested the IOUs identify the steps necessary to publish this data.
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ADVICE 4067-E (U 338-E) -3- August 30, 2019 providing the information orally informs the Party receiving the information that the information is confidential. For purposes of this Rule all design, operating specifications, and metering data provided by Applicant shall be deemed Confidential Information regardless of whether it is clearly marked or otherwise designated as such, except as provided in section D.7.b. below. If requested by either Party, the other Party shall provide in writing, the basis for asserting that the information referred to in this Article warrants confidential treatment, and the requesting Party may disclose such writing to the appropriate Governmental Authority. Each Party shall be responsible for the costs associated with affording confidential treatment to its information. (Emphasis added.) In addition to these monthly datasets, SCE submits quarterly Rule 21 cost report datasets to the Commission (e.g., Q4 Rule 21 CPUC Cost Report). In all of these datasets, SCE has consistently treated descriptions of physical components of a generating facility as “design” information that is confidential under Rule 21 Section D.7.a, regardless of whether it is marked or otherwise designated as confidential. To avoid any uncertainty, in accordance with the instructions set forth in Decision 16-08-024 and Decision 17-09-023, which govern the submission of confidential documents to the Commission, SCE offers the following list of physical equipment / design elements that SCE believes it is required to keep confidential pursuant to Section D.7.a of Rule 21, and which it thus considers to be confidential for purposes of submitting Rule 21 datasets in response to the Memorandum: Inverter Model Inverter Manufacturer Inverter Quantity Generator Model Generator Manufacturer Generator Quantity 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 GO 96-B, Energy Industry Rule 5.2, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice letter will become effective on September 29, 2019, the 30th calendar day after the date submitted.
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ADVICE 4067-E (U 338-E) -4- August 30, 2019 NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail: Copies of protests should also be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. 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 GO 96-B, R.11-09-011, and R.17-07-007 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-4039. For changes to all other service lists, please contact the CPUC’s Process Office at (415) 703-2021 or by electronic mail at
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ADVICE 4067-E (U 338-E) -5- 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 CPUC, log on to SCE’s web site at For questions, please contact Darrah Morgan at (626) 302-2086 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:dm:jm
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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: 2 Advice Letter (AL) #: 4067-E Subject of AL: Rule 21 Data Integrity Clarification Keywords (choose from CPUC listing): Compliance, Rule 21 AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: 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: 9/29/19 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: (415) 929-5515 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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