Details for: SDG&E Advice Letter 3558-E.pdf

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Clay Faber – Director
Regulatory Affairs
8330 Century Park Ct.
San Diego, CA 92123

June 25, 2020
(U 902-E)

DECISION 18- 11-029

San Diego Gas & Electric Company (“SDG&E”) hereby submits for approval by the California
Public Utilities Commission (“Commission”) this Advice Letter (“AL”) that revises SDG&E’s
Demand Response (“DR”) Disadvantage Communities (“DACs”) Pilot Plan and Objectives, with
respect to the Project Schedule as described in AL 3342-E and AL 3342-E-A1.
On February 8, 2019, SDG&E submitted AL 3342-E outlining its proposed DR pilot and
implementation plans for DACs pursuant to D.18-11-029. Subsequently, the Energy Division
(“ED:) requested SDG&E submit an addendum to its original AL in order to clarify pilot
objectives and amend the proposal submitted on February 8, 2019.
On August 5, 2019, SDG&E submitted Supplemental AL 3342-E-A providing the additional
requested information.
On August 19, 2019, Energy Division approved AL 3342-E and AL 3342-E-A effective
September 4, 2019.
On May 19, 2020, SDG&E met with Energy Division to provide an update regarding the
implementation of its DAC Pilot. SDG&E provided an updated timeline to ED, as well as
discussing potential alternate approaches for outreach activities pursuant to the COVID-19
Pandemic. During the meeting, SDG&E inquired as to whether an additional advice letter would
be required due to the revisions.

SDG&E Advice Letter 3342-E and SDG&E Advice Letter 3342-E-A, approved by the California Public
Utilities Commission August 19, 2020, effective September 4, 2020



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Public Utilities Commission 2 June 25, 2020 On June 5, 2020, ED requested SDG&E submit a Tier 2 advice letter providing the revisions to the DAC Pilot timeline and outreach activities, including the reasons for the changes. This Tier 2 AL hereby revises and replaces the Project Schedule included in AL 3342-E-A SDG&E Addendum to Demand Response Pilot Plan for Disadvantaged Communities. This Tier 2 AL makes no other modifications to the Demand Response Pilot Plan for Disadvantaged Communities. DISCUSSION This AL includes SDGE’s revised implementation schedule, modified outreach plans, and reasons for the required modifications. Due to the COVID-19 pandemic, some of the implementation strategies for SDG&E’s DAC pilot have been delayed, specifically finalization of contracts, installation of the battery, and key outreach activities. In March 2020, stay-at-home orders caused SDG&E’s pilot location to close; and, the City of National City and County of San Diego offices were closed delaying SDG&E’s ability to obtain permits. In addition, the stay-at-home orders have impacted SDG&E’s ability to move forward with scheduled outreach activities and in-person communications for the DAC Pilot. As required, SDG&E is adhering to all guidelines set by local and state government to ensure public safety and protect the public and its employees. Planned in-person and community outreach events are now scheduled closer to the end of the pilot timeline (2021) in anticipation of the lifting of stay-at home orders and the expected resuming of community events. Surveys are now planned for 4th Quarter 2020, barring any new issues or shutdowns arising as a result of COVID-19. For the reasons identified above, SDG&E has modified the DAC Pilot Implementation Schedule, included herein as Attachment A. EFFECTIVE DATE SDG&E believes that this submittal is subject to Energy Division disposition and should be classified as Tier 2 (effective upon approval) and respectfully requests an approval date of July 25, 2020, 30 days after the date submitted. PROTEST Anyone may protest this advice letter to the California Public Utilities 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 received by July 15, 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 June 25, 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 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: Greg Anderson Regulatory Tariff Manager E-Mail: NOTICE A copy of this filing has been served on the utilities and interested parties shown on the attached list including interested parties in A.17-01-019, et. al. by either providing them a copy electronically or by mailing them a copy hereof, properly stamped and addressed. Address changes should be directed to SDG&E Tariffs by e-mail at /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: 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) #: 3558-E Subject of AL: Revised Project Schedule – SDG&E’s Demand Response Pilot Plan for Disadvantage Communities in Compliance with Decision 18-11-029 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. 18-11-029 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: 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: 7/25/20 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: Name: Gregory Anderson 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) 654-1717 Facsimile (xxx) xxx-xxxx: Email: 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: Clear Form
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cc: (w/enclosures) General Order No. 96-B ADVICE LETTER SUBMITTAL MAILING LIST Public Utilities Commission Clean Energy Renewable Fuels, LLC Office of Ratepayer Advocates (ORA) P. DeVille R. Pocta Clean Power Research T. Schmid Energy Division M. Ghadessi G. Novotny M. Salinas Davis Wright Tremaine LLP L. Tan J. Pau R. Ciupagea Douglass & Liddell Tariff Unit D. Douglass CA Energy Commission D. Liddell B. Penning Ellison Schneider Harris & Donlan LLP B. Helft E. Janssen Advantage Energy C. Kappel C. Farrell Energy Policy Initiatives Center (USD) Alcantar & Kahl LLP S. Anders M. Cade Energy Regulatory Solutions Consultants K. Harteloo L. Medina AT&T Energy Strategies, Inc. Regulatory K. Campbell Barkovich & Yap, Inc. EQ Research B. Barkovich General Braun & Blaising, P.C. Goodin, MacBride, Squeri, & Day LLP S. Blaising B. Cragg D. Griffiths J. Squeri CA Dept. of General Services Green Charge H. Nanjo K. Lucas California Energy Markets Hanna and Morton LLP General N. Pedersen California Farm Bureau Federation JBS Energy K. Mills J. Nahigian California Wind Energy Keyes & Fox, LLP N. Rader B. Elder City of Poway Manatt, Phelps & Phillips LLP Poway City Hall D. Huard City of San Diego R. Keen L. Azar McKenna, Long & Aldridge LLP J. Cha J. Leslie D. Heard Morrison & Foerster LLP F. Ortlieb P. Hanschen H. Werner MRW & Associates LLC M. Rahman General NLine Energy M. Swindle NRG Energy D. Fellman 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: A.17-01-019, et. al.
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SDG&E Advice Letter 3558-E ATTACHMENT A Revised SDG&E DAC Pilot Implementation Schedule
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Revised SDG&E DAC Pilot Implementation Schedule Revised Timeline Date Start Date Stop New Stop Task Description Present 9/1/2019 Completed Secure initial battery participation commitment from pilot host site(s) 9/1/2019 9/2/2019 Completed SOW Approved by CPUC. Notice to proceed received. 11/2/2019 12/15/2019 Completed Develop Full Scope of Work (for both battery installations and surveys) 9/2/2019 10/1/2019 Completed Secure Battery Vendors/Installers 9/2/2019 10/1/2019 Completed Finalize Securing SMB DAC battery Site(s) 9/2/2019 11/1/2019 Completed Finalize and sign Contract w/ Survey & Outreach Vendors 9/2/2019 11/1/2019 June - July 2020 Perform site inspection and submit permits 1/1/2020 3/1/2020 June - July 2020 Battery project Install 3/2/2020 5/1/2020 July 2020 3/1/2020 4/1/2020 Jan - June 2021 Host battery project launch "Kick-Off Event" at site and outreach events.* 4/2/2020 5/1/2020 July- Dec 2020 Survey deployment with commercial and residential customers. 5/2/2020 5/1/2021 Dec 2020 5/2/2021 7/15/2021 7/15/2021 Project Commissioning Post Project Evaluation and Verification EM&V Report *Note: COVID-19 may continue to impact SDG&E’s outreach approach in terms of face to face meetings and events. SDG&E’s contractor will follow guidelines set by local and state government in terms of health and safety codes and may adjust strategies and tactics in order to reach goals and objectives.
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