Details for: SDG&E Advice Letter 3544-E.pdf


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Clay Faber - Director
Regulatory Affairs
8330 Century Park Court
San Diego, CA 92123
cfaber@sdge.com

May 15, 2020
ADVICE LETTER 3544-E
(U902-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
SUBJECT:

San Diego Gas & Electric Company’s Prevalent Language Wildfire
Communications Plan in Compliance with D.20-03-004

San Diego Gas & Electric Company (SDG&E) hereby submits this Tier 1 Advice Letter (AL) to
demonstrate to the California Public Utilities Commission (Commission) how SDG&E will conduct
community awareness and public outreach before, during, and after a wildfire in any language
that is prevalent in its service territory.
PURPOSE
The purpose of this AL is to submit a prevalent language wildfire communications compliance
plan as required by Ordering Paragraph 1 of Decision (D.) 20-03-004 and Administrative Law
Judge (ALJ) Thomas’ May 14, 2020 E-mail Ruling.1
BACKGROUND
Senate Bill (SB) 901,2 among other things, amended Section 8386 of the Public Utilities Code3
(P.U. Code) to require electric corporations, including SDG&E, to “annually prepare and submit
a wildfire mitigation plan (WMP) to the commission for review and approval, according to a
schedule established by the commission.” On May 30, 2019 in Rulemaking (R.) 18-10-007, the
Commission issued decisions on all 2019 WMPs, including SDG&E’s, as well as guidance on the
legal meaning of such decisions pursuant to SB 901.4
The 2019 WMP Decisions established a Phase 2 of the Rulemaking, to handle a few issues that
the Commission could not resolve in Phase 1. Among the items the Commission deferred to
Phase 2 was community outreach before, during and after a wildfire as required by P.U. Code
1

SDG&E submits this compliance plan as a Tier 1 Advice Letter pursuant to Administrative Law
Judge Thomas’ May 14, 2020 E-mail Ruling re: R.18-10-007: Request for Clarification on Ordering
Paragraph 1 of D.20-03-004 re Indigenous Languages (ALJ Ruling), which provides: “The Investor
Owned Utilities and Small and Multijurisdictional Utilities covered by Decision 20-03-004 shall submit a
Tier 1 advice letter in order to conform with Ordering Paragraph 1.”
2
Stats. 2018, Ch. 626.
3
P.U. Code § 8386 was subsequently amended by Assembly Bill (AB) 1054, Stats. 2019, Ch. 79,
in July 2019.
4
See D.19-05-036 and D.19-05-039.





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Public Utilities Commission 2 May 15, 2020 Section 8386(c)(18)(B), including outreach in-language to those with limited English language proficiency. DISCUSSION The Commission’s Phase 2 Decision, D.20-03-004, among other things, requires electric utilities to demonstrate that they conduct community awareness and public outreach before, during, and after a wildfire in any language that is “prevalent” in its service territory or portions thereof. Specifically, OP 1 of D.20-03-004 requires: No later than May 15, 2020, each Investor Owned Utility (IOU) and Small and Multi-Jurisdictional Utility (SMJU) shall demonstrate to the Commission’s satisfaction that it conducts community awareness and public outreach before, during, and after a wildfire in any language that is “prevalent” in its service territory or portions thereof. A language is “prevalent” if it is spoken by 1,000 or more people in the affected IOU’s or SMJU’s service territory. Such languages shall include languages spoken by indigenous communities, such as Mixteco and Zapoteco, spoken by indigenous people that occupy significant roles in California’s agricultural economy regardless of prevalence. An IOU or SMJU may conduct outreach in languages that are less prevalent at its option, but prevalent languages are a minimum requirement for all IOUs and SMJUs. Further, the ALJ Ruling clarifies: The Investor Owned Utilities and Small and Multijurisdictional Utilities covered by Decision 20-03-004 shall submit a Tier 1 advice letter in order to conform with Ordering Paragraph 1. They shall serve the advice letter on the service list for R.18-10-007, and send a copy to the Wildfire Safety Division, wildfiresafetydivision@cpuc.ca.gov. Attachment A hereto provides SDG&E’s Prevalent Language Wildfire Communications Compliance Plan. EFFECTIVE DATE SDG&E believes this submittal is subject to Energy Division disposition and should be classified as Tier 1 (effective pending disposition) pursuant to General Order (GO) 96-B. SDG&E respectfully requests that this submittal be effective on May 15, 2020, which is the date filed. PROTEST Anyone may protest this Advice Letter to the Commission. The protest must state the grounds upon which it is based, including such items as financial and service impact, and should be submitted expeditiously. The protest must be made in writing and must be received no later than June 4, 2020 which is 20 days after the date this Advice Letter was submitted with the Commission. There is no restriction on who may submit a protest. The address for mailing or delivering a protest to the Commission is:
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Public Utilities Commission 3 May 15, 2020 CPUC Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Copies of the protest should also be sent via e-mail to the attention of the Energy Division at EDTariffUnit@cpuc.ca.gov. A copy of the protest should also be sent via e-mail to the address shown below on the same date it is mailed or delivered to the Commission. Attn: Megan Caulson Regulatory Tariff Manager E-mail: MCaulson@sdge.com NOTICE A copy of this Advice Letter is being sent to SDG&E’s GO 96-B service list, the Commission’s service list in R.18-10-007, and the Wildfire Safety Division, by providing them a copy hereof either electronically or via the U.S. mail, properly stamped and addressed. Address changes should be directed to SDG&E Tariffs by email to SDGETariffs@sdge.com. /s/ Clay Faber _______________________________ CLAY FABER Director – Regulatory Affairs
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: San Diego Gas & Electric Company (U902-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Brittany Malowney Phone #: 858-637-3714 E-mail: BMalowney@sdge.com E-mail Disposition Notice to: BMalowney@sdge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 3544-E Subject of AL: San Diego Gas & Electric Company’s Prevalent Language Wildfire Communications Plan in Compliance with D.20-03-004 Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.20-03-004 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: N/A Summarize differences between the AL and the prior withdrawn or rejected AL: N/A 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: 5/15/20 No. of tariff sheets: 0 Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A 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: N/A Service affected and changes proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 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: EDTariffUnit@cpuc.ca.gov Name: Megan Caulson Title: Regulatory Tariff Manager Utility Name: San Diego Gas & Electric Company Address: 8330 Century Park Court; CP 31D 92123 City: San Diego State: California Telephone (xxx) xxx-xxxx: (858) 654-1748 Facsimile (xxx) xxx-xxxx: Email: MCaulson@sdge.com Name: SDG&E Tariff Department Title: Utility Name: San Diego Gas & Electric Company Address: 8330 Century Park Court; CP 31D 92123 City: San Diego State: California Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: SDGETariffs@sdge.com Clear Form
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cc: (w/enclosures) Public Utilities Commission Office of Ratepayer Advocates (ORA) R. Pocta Energy Division M. Ghadessi M. Salinas L. Tan R. Ciupagea Tariff Unit CA Energy Commission B. Penning B. Helft Advantage Energy C. Farrell Alcantar & Kahl LLP M. Cade K. Harteloo AT&T Regulatory Barkovich & Yap, Inc. B. Barkovich Braun & Blaising, P.C. S. Blaising D. Griffiths CA Dept. of General Services H. Nanjo California Energy Markets General California Farm Bureau Federation K. Mills California Wind Energy N. Rader City of Poway Poway City Hall City of San Diego L. Azar J. Cha D. Heard F. Ortlieb H. Werner M. Rahman General Order No. 96-B ADVICE LETTER SUBMITTAL MAILING LIST Clean Energy Renewable Fuels, LLC P. DeVille NLine Energy M. Swindle Clean Power Research T. Schmid G. Novotny NRG Energy D. Fellman Davis Wright Tremaine LLP J. Pau Douglass & Liddell D. Douglass D. Liddell Ellison Schneider Harris & Donlan LLP E. Janssen C. Kappel Energy Policy Initiatives Center (USD) S. Anders Energy Regulatory Solutions Consultants L. Medina Energy Strategies, Inc. K. Campbell EQ Research General Goodin, MacBride, Squeri, & Day LLP B. Cragg J. Squeri Green Charge K. Lucas Hanna and Morton LLP N. Pedersen JBS Energy J. Nahigian Keyes & Fox, LLP B. Elder Manatt, Phelps & Phillips LLP D. Huard R. Keen McKenna, Long & Aldridge LLP J. Leslie Morrison & Foerster LLP P. Hanschen MRW & Associates LLC General Pacific Gas & Electric Co. M. Lawson M. Huffman Tariff Unit RTO Advisors S. Mara SCD Energy Solutions P. Muller Shute, Mihaly & Weinberger LLP O. Armi Solar Turbines C. Frank SPURR M. Rochman Southern California Edison Co. K. Gansecki TerraVerde Renewable Partners LLC F. Lee TURN M. Hawiger UCAN D. Kelly US Dept. of the Navy K. Davoodi US General Services Administration D. Bogni Valley Center Municipal Water Distr G. Broomell Western Manufactured Housing Communities Association S. Dey Interested Parties in: R.18-10-007 Cc: Wildfire Safety Division wildfiresafetydivision@cpuc.ca.gov
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SDG&E Advice Letter 3544-E Attachment A San Diego Gas & Electric Company’s Prevalent Language Wildfire Communications Compliance Plan
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San Diego Gas & Electric Company’s Prevalent Language Wildfire Communications Compliance Plan May 15, 2020
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I. Introduction Pursuant to Ordering Paragraph (OP) 1 of California Public Utilities Commission (Commission or CPUC) Decision (D.) 20-03-004, San Diego Gas & Electric Company (SDG&E or Company) submits this compliance plan detailing how it will conduct community awareness and public outreach before, during, and after a wildfire in any language that is prevalent in its service territory. 1 II. Prevalent Language Communications Communicating, engaging and empowering customers and communities is critically important to SDG&E’s wildfire preparedness, and even more critical during emergency events such as a wildfire. SDG&E understands the importance of communicating with those it serves in a manner that will be understood, which includes communicating in multiple languages. In accordance with D.20-03-004, SDG&E has identified approximately 17 “prevalent” languages in its service territory or portions thereof, in which it will conduct community awareness and public outreach before, during and after a wildfire. This language count is inclusive of the languages adopted in D.19-05-039, SDG&E’s 2019 WMP Decision, and is subject to change due to additional feedback from community-based organizations (CBOs) and other societal factors. In alignment with the Commission’s guidelines (set forth in Appendix A of D.20-03-004), these counts include prevalent languages that 1,000 or more people speak in SDG&E’s service territory, and are representative of target populations that are over the age of five (5) years old from households that speak English “less than very well” according to U.S. Census data. The Company also examined the languages spoken within the High Fire Threat District (HFTD) of its service territory and included those languages as part of the final list of languages. The method used to determine the prevalent languages in the service territory include using data analytics and soliciting input from CBOs. Specifically, SDG&E identified its prevalent languages with data collected from the American Community Survey and California Complete Count Reports. SDG&E Customer Contact Center data was also assessed. SDG&E submits this compliance plan as a Tier 1 Advice Letter pursuant to Administrative Law Judge Thomas’ May 14, 2020 E-mail Ruling re: R.18-10-007: Request for Clarification on Ordering Paragraph 1 of D.20-03-004 re Indigenous Languages, which states: “The Investor Owned Utilities and Small and Multijurisdictional Utilities covered by Decision 20-03-004 shall submit a Tier 1 advice letter in order to conform with Ordering Paragraph 1.” 1 1
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The languages identified as meeting the Commission’s parameters of “prevalent” within SDG&E’s service territory or portions thereof are as follows: 2 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. English Spanish Tagalog Chinese (Mandarin & Cantonese) Vietnamese Arabic Korean Russian French German Farsi Japanese Punjabi Khmer Somali Mixteco Zapoteco SDG&E will continue to ascertain additional language preferences by soliciting feedback from CBOs in the region that engage in multiple languages with minority communities and vulnerable populations. The feedback will be used to identify any material gaps in the list of prevalent languages identified. Several of these CBOs already collaborate with SDG&E to amplify inlanguage wildfire safety messaging to their constituents during emergencies and other events. Finally, SDG&E is proactively meeting with regional stakeholders and conferring with parties to this proceeding to ensure outreach is conducted to and information is solicited from the most appropriate CBOs prior to the wildfire season. A. Community Education and Engagement – Before Wildfire All communications and outreach efforts associated with SDG&E’s wildfire mitigation measures are part of its Company Wildfire Safety Education initiative. The initiative includes strategies and tactics that will, if successful, result in more empowered and educated customers that will be able to traverse the inherent adversities associated with wildfires. The strategies being deployed as part of the initiative include direct and in-direct customer engagement through community outreach, customer education through marketing and materials, and briefings with key stakeholders. D.20-03-004 at 37, OP 1 states that prevalent languages “shall include languages spoken by indigenous communities, such as Mixteco and Zapoteco, spoken by indigenous people that occupy significant roles in California’s agricultural economy regardless of prevalence.” (Emphasis added). SDG&E’s analysis for prevalent languages (performed pursuant to Appendix A of D.20-03-004) showed that Mixteco and Zapoteco are not present in SDG&E’s service territory, however, consistent with OP 1 SDG&E includes them as prevalent languages. 2 2
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In-language community education materials consist of important wildfire safety and resiliency messaging. Campaign messaging will be translated into the “prevalent” languages spoken in the territory and made available to minority and hard-to-reach audiences and the CBOs that serve them. SDG&E is also working with these organizations to help identify the most effective communication methods and materials to reach these target audiences in 2020. B. Real-Time Situational Awareness – During Wildfire During wildfire events, SDG&E provides real-time situational awareness via in-language communications to its customers and the general public with emphasis to the HFTD within the service territory. The company also plans to expand this effort in the identified prevalent languages. This year’s Wildfire Safety Education initiative will continue to encourage customers and the public to update contact information and sign up for in-language emergency notifications via SDG&E’s Enterprise Notification System (ENS) enrollment portal. These inlanguage notifications are broadcast using ENS, via email, text and recorded voice messages. Each of these communications are translated into the required languages based on communication type. Voice recordings are created, and email and text translations are produced and added to SDG&E’s website, sdge.com. Additionally, SDG&E provides real-time updates in multiple languages via broadcast media, social media, the SDG&E NewsCenter and website (sdge.com) during wildfire emergencies. C. Post-Event Engagement and Communications – After Wildfire SDG&E employs the same methodology and communication platforms referenced in Section II.B above after a wildfire event. The messaging is updated to convey the end of the event as well as power restoration updates. Key stakeholders, CBOs, customers and impacted communities are engaged, as part of a quality assurance measure to enhance the Wildfire Safety Education initiative moving forward. SDG&E will conduct separate after-action reports that will address the operational effectiveness of the communications systems deployed during the event, ensuring future enhances or fixes can be made, if need be. 3
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