Details for: PGE Reply to Protest to AL 5837-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

June 29, 2020
California Public Utilities Commission - Energy Division
Tariff Unit
505 Van Ness Avenue, 4th Floor
San Francisco, CA 94102

Pacific Gas and Electric Company’s Reply to the Protest from Protect
Our Communities Foundation to Pacific Gas and Electric Company
Advice Letter 5837-E

Dear Energy Division Tariff Unit:
Pursuant to General Order (GO) 96-b, Pacific Gas and Electric Company (PG&E)
provides its reply to the protest of the Protect Our Communities Foundation (PCF) to
PG&E’s Advice Letter 5837-E: Reports of Possible Off Ramps.
In accordance with Ordering Paragraph (OP) 1 of Decision (D.) 19-05-036, made
effective on May 30, 2019, PG&E submitted AL 3549-E on June 1, 2020. In AL 5837-E,
PG&E identifies one program in the PG&E 2020 Wildfire Mitigation Plan (WMP) that
requires a modification, which may impact its effectiveness, due to the COVID-19
pandemic. As described in AL 5837-E, PG&E’s 2020 Customer Outreach and
Awareness Campaign has been impacted and required modifications to implement
social distancing for employee and community safety. For 2020, PG&E will replace the
Wildfire Safety Open House events with webinars, which will allow for the safe
distribution of preparedness materials.
On June 22, 2020 PG&E received the PCF protest to San Diego Gas and Electric
Company (SDG&E) AL 3549-E, Southern California Edison Company (SCE) AL 4222E, and PG&E AL 5837-E.
PCF protested the above ALs on the following grounds:


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PG&E Reply to Protest of Advice Letter 5837-E • • • • -2- June 29, 2020 The relief requested in the advice letter would violate statute or Commission order, or is not authorized by statute or Commission order on which the utility relies; The analysis, calculations, or data in the advice letter contain material errors or omissions; The relief requested in the advice letter is pending before the Commission in a formal proceeding; The relief requested in the advice letter requires consideration in a formal hearing, or is otherwise inappropriate for the advice letter process PG&E hereby replies to PCF protest to PG&E AL 5837-E. PG&E’S REPLY PCF raises a number of misleading claims regarding the utilities’ second off-ramp reports. PCF contends there are deficiencies in the off-ramp reports, but its claims lack both merit and an understanding of the processes and procedures the Commission or Wildfire Safety Division have established with respect to Wildfire Mitigation Plans. First, PCF asserts that the utilities fail to mention that the Commission previously evaluated off-ramp reports in the context of R.18-10-007 and, more specifically, D.2003-004, and that the utilities should not have filed Advice Letters for their off-ramp reports. 1 It is not clear how not mentioning these facts results in an alleged “failure” by the utilities, as the Commission is aware of the mechanism it used to evaluate the offramp reports. What PCF fails to understand is that the Commission has not lifted the requirement that utilities file off-ramp reports as Advice Letters, which is what PG&E did. Second, PCF misinterprets the requirements set forth in D.19-05-036 regarding what the off-ramp reports are intended to communicate, and the clear clarification provided in D.20-03-004. To start, the utilities are required by D.19-05-036 to describe “any concerns about the effectiveness of any program in their individual Wildfire Mitigation Plans,” but PCF contends the utilities failed to describe concerns raised by other parties and the Commission. 2 The off-ramp process established in D.19-05-036 is not intended to capture “concerns” raised by parties and the Commission. The “concerns” to be addressed in the off-ramp process are instead the utility’s own concerns about the effectiveness of programs within its Wildfire Mitigation Plan. The Commission confirmed this in D.20-03-004 when it resolved the utilities’ first off-ramp advice letters. Per D.20-03-004, the Commission clarified, “The provision [off-ramp Advice Letter] asks the IOU to describe concerns, not other parties. While the Commission may disagree with an IOU's or SMJU's determination in its Off Ramp Advice Letter of whether a mitigation measure is effective, the Commission's process for determining effectiveness 1 2 PCF Protest, pp. 1-2. PCF Protest, p. 2.
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PG&E Reply to Protest of Advice Letter 5837-E -3- June 29, 2020 is separate from the Off-Ramp Advice Letter process.” 3 The Commission has been clear that the purpose of the off-ramp advice letter process is not for the utilities to capture concerns of any party regarding the effectiveness of their WMPs, but rather provide the utilities an opportunity to inform the Commission and stakeholders of any WMP program changes if an activity is found to be ineffective. PCF has misinterpreted the purpose of the off-ramp advice letter process and its distinction from the clearly articulated procedural processes set forth by the Commission and WSD for resolving WMP issues. In D.19-05-036 and D.20-03-004, the Commission provides the intent and scope of the off-ramp advice letter process, as noted above. In the Resolutions issued by WSD that conditionally approved the utilities’ WMPs, WSD provides the process and requirements of additional reporting by the utilities to aid in stakeholder review of the effectiveness of the mitigation activities, among other things. Accordingly, PCF has simply misinterpreted the Commission’s and WSD’s clearly articulated processes and procedures for resolution of WMP issues. CONCLUSION In accordance with PG&E’s reply to the protest above, PG&E respectfully requests that the California Public Utilities Commission approve AL 5837-E as filed. Sincerely, /S/ Erik Jacobson Director, Regulatory Relations cc: Service List R.18-10-007 Malinda Dickenson, The Protect Our Communities Foundation 3 D.20-03-004, p. 28.
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