Details for: SCE's Reply to Kern and SB Counties Protest of SCE Advice 4294-E.pdf

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

October 14, 2020
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Southern California Edison Company’s Reply to Protest of Kern and
Santa Barbara Counties of Advice 4294-E

Dear Energy Division Tariff Unit:
In accordance with Section 7.4.3 of General Order (GO) 96-B, Southern California
Edison Company (SCE) hereby replies to the Kern and Santa Barbara Counties (The
Counties) protest to SCE’s Advice 4294-E.
On September 17, 2020, SCE submitted Advice 4294-E discussing its work plan and
cost estimate for developing a new microgrid data portal to better allow local and tribal
governments to make informed decisions around their own resiliency planning efforts,
capital investments, and pre-PSPS event operations. SCE provided a narrative
describing how the work plan related to other planned work, a list of key tasks, an
associated schedule, and interdependencies among tasks and milestones.
In Advice 4294-E, SCE demonstrated compliance with Ordering Paragraph (OP) 11 of
Decision 20-06-017 (the Decision). The Counties submitted their protest to Advice
4294-E on October 7, 2020. Importantly, the Counties do not oppose the substance of
SCE’s work plan or estimated costs but express concerns with the timing to deploy the
portal. They recommend SCE work with Pacific Gas & Electric (PG&E) to understand
their best practices that will allow them to deploy the portal in late 2021, a year before
SCE expects to be able to deploy the portal. The Counties add that if SCE cannot
deploy the portal in 2021, SCE should provide the same type of basic planning
information as PG&E through other means. Lastly, they recommend SCE adopt PG&E’s
“single checkbox” permission for confidential information.
SCE understands the concerns raised by the Counties regarding the timing to deploy
the microgrid portal and is working to deploy it expeditiously. While PG&E may deliver
the portal by late 2021, there are factors specific to SCE preventing it from doing so.
P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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Energy Division Tariff Unit Page 2 October 14, 2020 The infrastructure behind SCE’s Distributed Resources Plan External Portal (DRPEP) is out of capacity to accommodate the data and functions needed to implement both the Microgrid Data Portal requirements and the recent required reforms to the DRPEP, mandated in the April 2020 ruling in the DRP proceeding1. SCE’s IT development team must adhere to internal business and compliance processes to plan, procure, build, and test the new infrastructure and the migration work that follows, which likely cannot be completed by late 2021. DRP Reforms 8, 9, 10 and 11 must be implemented by the third quarter of 2021 and will make up the bulk of SCE’s IT team’s workload during that timeframe. These reforms and Microgrid Data Portal requirements call for developing new IT components and new business processes, which are time-consuming and labor-intensive. Additionally, developing the user authentication functions to protect confidential information within the Microgrid Data Portal is a new undertaking for SCE, whereas PG&E is experienced with such processes, as discussed in the Counties’ protest. While SCE expects these challenges to prevent it from being able to deploy the full Microgrid Data Portal until 2022, SCE will consult with PG&E on their best practices that will allow them to deploy the portal by 2021. In addition, SCE has already reached out to PG&E to better understand their “single checkbox” permission approach to confidential information and will consider utilizing the same or a similar approach. WHILE SCE’S MICROGRID PORTAL WILL MOST LIKELY NOT BE ACTIVE UNTIL LATE 2022, MUCH OF THE INFORMATION THE PORTAL WILL PROVIDE WILL BE PUBLICLY AVAILABLE BY LATE 2021 Irrespective of the aforementioned challenges, SCE will provide the information required to be implemented within the Microgrid Data Portal via other means as requested by the Counties. As discussed above, in August 2021, SCE will be deploying a significant update to its DRPEP. This update will provide identical or near-identical information to the four layers required by the Decision. As such, users seeking Microgrid-related information will have access once SCE publishes the DRP reforms within DRPEP, which will occur on or before August 30, 2021. The DRPEP can be accessed at: 1 R. 14-08-013, Administrative Law Judge’s Ruling Modifying the Distribution Investment Deferral Framework Process, issued April 13, 2020.
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Energy Division Tariff Unit Page 3 October 14, 2020 CONCLUSION SCE appreciates the opportunity to submit this reply to the Counties’ Protests. For the foregoing reasons, SCE recommends the Commission approve SCE’s Advice 4294-E. Sincerely, /s/ Gary A. Stern /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D. GAS:ea:jm cc: Edward Randolph, Director, CPUC Energy Division Franz Cheng, CPUC Energy Division Forest Kaser, CPUC Energy Division Julian Enis, CPUC Energy Division Megan Somogyi, Counsel for Kern and Santa Barbara Counties Service List R. 19-09-009
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