Details for: 4324-E (Part 1 of 1).pdf

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

October 29, 2020
(U 338-E)

Information-Only Advice Letter - Southern California Edison
Company’s Notification of Change to the Location of the
Photovoltaic System for the Microgrid Demonstration Project at
the Port of Long Beach

The purpose of this information-only advice letter is to inform the California Public
Utilities Commission (CPUC or Commission) of the change to the location of the
photovoltaic (PV) system, which is part of the microgrid demonstration project at the
Port of Long Beach (POLB).
On May 30, 2019, the Commission adopted Resolution E-5002 that approved Southern
California Edison Company’s (SCE) Advice 3808-E-C regarding a limited deviation from
Rule 18, Supply to Separate Premises and Use by Others, to accommodate the POLB’s
microgrid demonstration project.1 The approved microgrid demonstration project
included a PV system and battery energy storage systems (BESS) to be installed at the
POLB-owned Joint Command and Control Center (JCCC). To maximize the use and
benefit of the microgrid demonstration project, the POLB proposed to also install a lowvoltage cable between JCCC and its adjacent neighbor, Jacobsen Pilot Service (JPS).

Resolution E-5002 approved SCE’s Advice 3808-E-C limited deviation from Rule 18,
Section C to accommodate the POLB’s microgrid demonstration project. It rejected Advice
3808-E, 3808-E-A, and 3808-E-B that would have applied the change to any municipal
corporation. Pursuant to the Commission’s order in Resolution E-5002, SCE submitted a
compliance advice letter that effectively includes, in one document, all the information
relevant to the Port of Long Beach (POLB), the Joint Command and Control Center
(JCCC), Jacobsen Pilot Service (JPS), and the approved limited deviation from Section C of
Rule 18.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4324-E (U 338-E) -2- October 29, 2020 During an SCE outage, the microgrid would engage, provide electricity to JCCC, and deliver electricity to JPS via the installed low-voltage cable. Because the JCCC and JPS are independent enterprises, the JCCC was prohibited from supplying JPS with electricity received from SCE under Rule 18, Section C.2 Thus, to accommodate the POLB’s microgrid demonstration project, SCE requested, and the Commission approved, a limited deviation from Rule 18. The advice letters SCE submitted at that time and the Commission Resolution approving the deviation proposed in the advice letter specifically stated that the PV will be installed at the JCCC location. Due to certain changes in circumstances, the information submitted by SCE in describing the location of the PV for this microgrid project requires an update. Specifically, in August of 2020, the POLB informed SCE that while the BESS can be installed at the JCCC location as approved by the Commission, the PV cannot be installed as originally laid out in the advice letter seeking the deviation.3 Thus, SCE is submitting this updated advice letter to notify the Commission that the POLB has a new plan to install the PV on the roof of another enterprise, Crescent Warehouse, which is located across Pier F Avenue from JCCC. The PV will not be electrically connected or provide any electrical service to Crescent Warehouse, and the line connecting the PV to the BESS will not cross a public right of way.4 The POLB has agreed to implement technical solutions to ensure prudent electrical design and mitigate any potentially unsafe conditions and grid operation complexities around the proposed PV site.5 This is an information-only advice letter because SCE believes that the change in PV site needs no additional Rule 18 tariff deviation – the POLB microgrid still serves the same customers and the only change from the previously approved configuration is the location of the PV. As a general matter, SCE strongly believes in the important customer protections – from the safety and reliability of the electric grid to the assuring 2 3 4 5 Rule 18, Section C states: “A customer shall not use electricity received from SCE upon other Premises, except for SCE’s operating convenience, nor for other purposes than those specified in the customer’s application or in the rate schedule applied.” See footnote 1. Consistent with the Prudent Operation and Maintenance requirement in Rule 21, the interconnection line connecting the PV to the BESS will be installed, operated, and maintained by the POLB. The technical solution agreed to between SCE and the POLB includes but is not limited to: (1) Installation of permanent and visible signage at SCE isolation switch, BESS isolation switch, and PV isolation switch, main service at JCCC, JPS, and Crescent Warehouse; (2) Generation isolation switch/SCE isolation (at JCCC) switch shall meet the requirements specified in Rule 21, Section Hh.1.d; (3) PV isolation switch (at Crescent Warehouse) shall meet the requirements specified in Rule 21, Section Hh.1.d; (4) Installation of POLB-owned underground facilities must comply with applicable state laws, NEC, and local jurisdiction codes; (5) Project must comply with all Rule 21 interconnection requirements; (6) Microgrid equipment and operational requirements such as interlock schemes will be specified, verified, and approved as part of the interconnection process; (7) SCE to add notes to both Mast 12 kV and Ahoy 12 kV circuits, which the POLB 800V DC tie line will cross; and (8) SCE to perform informational session for the Long Beach operations.
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ADVICE 4324-E (U 338-E) -3- October 29, 2020 Commission oversight of customer costs – provided by SCE tariffs and the existing statutes. However, to accommodate the unique circumstances presented by the POLB microgrid demonstration project, SCE sought and the Commission approved a one-time deviation under Rule 18 of the SCE Tariff. The Commission should consider the POLB’s updated microgrid design as an approved legacy project under its prior order. Any future microgrids projects will need to conform with Commission decisions and rules established in the new microgrid proceeding, Rulemaking (R.)19-09-009. SCE and POLB, along with other stakeholders, have already been involved in the Commission’s microgrid proceeding, where general policy issues on microgrids can and should be raised. No cost information is required for this advice letter. This advice letter will not increase any rate or change, cause the withdrawal of service or conflict with any other schedule or rule. TIER DESIGNATION Pursuant to General Order (GO) 96-B, Energy Industry Rule 5.1, this advice letter is submitted with a Tier 1 designation. NOTICE In accordance with GO 96-B, General Rule 6.2, this information-only advice letter is not subject to protest. 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 service list. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at 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 Commission, log on to SCE’s web site at
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ADVICE 4324-E (U 338-E) -4- October 29, 2020 For questions, please contact Shiela Linao at (626) 302-4506 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:sl:cm Enclosures
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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: 1 Advice Letter (AL) #: 4324-E Subject of AL: Information-Only Advice Letter - Southern California Edison Company’s Notification of Change to the Location of the Photovoltaic System for the Microgrid Demonstration Project at the Port of Long Beach **No Protest Period*** Keywords (choose from CPUC listing): 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: 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: Diana S. Gallegos c/o Karyn Gansecki Title: Senior Advisor, 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: 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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