Details for: SDG&E AL 3571-E-A.pdf


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

February 17, 2021
ADVICE LETTER 3571-E-A
(U 902-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
SUBJECT:

SUPPLEMENTAL - SAN DIEGO GAS & ELECTRIC COMPANY’S PLANS
TO CONDUCT SEMI-ANNUAL WORKSHOPS, DEVELOP A PROJECT
ENGAGEMENT GUIDE, AND PROVIDE DEDICATED STAFFING FOR
LOCAL AND TRIBAL GOVERNMENTS PURSUANT TO DECISION 2006-017

PURPOSE
San Diego Gas & Electric Company (“SDG&E”) hereby submits for approval by the
California Public Utilities Commission (“Commission”) this supplemental advice letter (AL)
to replace the original AL 3571-E in its entirety. SDG&E submitted its original AL 3571-E
for Commission approval of its plans to conduct semi-annual workshops, develop a
resiliency project engagement guide, and provide a dedicated staff team for local and
tribal government projects in compliance with Ordering Paragraphs (“OPs”) 7, 9, and 10
of Decision (“D.”) 20-06-017. Although AL 3571-E was not protested, the CPUC’s Energy
Division provided additional guidance and questions for SDG&E to address in order to
comply with the intent of the Decision. In this supplement, SDG&E has reorganized the
contents of the original AL 3571-E to follow the OPs. Energy Division’s follow up
questions are italicized, with SDG&E’s responses following each question.
BACKGROUND
On September 12, 2019, the Commission initiated Rulemaking (“R.”) 19-09-009 to design
a framework for the commercialization of microgrids in accordance with Senate Bill (“SB”)
1339 and to account for the Commission’s commitment to technologies and activities that
may be useful for achieving overall resiliency goals.
The Assigned Commissioner’s Scoping Memo and Ruling for Track 1 adopted a schedule
for this proceeding, divided into three tracks.1 Track 1 encompasses the Commission’s
goal of deploying resiliency solutions in areas that are prone to outage events and
1

Assigned Commissioner’s Scoping Memo and Ruling for Track 1 (December 20, 2019), at 2.





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Public Utilities Commission 2 February 17, 2021 wildfires, with the goal of putting some microgrid and other resiliency strategies in place by spring or summer 2020, if not sooner.2 On June 11, 2020, the Commission adopted D.20-06-017 (“Decision”) that included a number of requirements to accelerate the interconnection of resiliency projects in advance of the upcoming wildfire season; modernize tariffs to maximize social resiliency benefits; and promote collaborative engagement between large investor-owned utilities (“utilities”) and local and tribal governments.3 The Decision addresses how the utilities should share information with local and tribal governments, adopting four mandates: • • 4 5 6 7 Dedicated Staff Team: The utilities must demonstrate dedicated staffing for local and tribal government projects to provide advice and guidance before planning and proposal development begins, assisting local jurisdictions with consulting advice on the types of resiliency projects that can be expedited through the permitting and interconnection process. This assistance includes providing preproject information about load points, customer connectivity, load profiles, and the relevant maps and infrastructure data to facilitate local jurisdiction planning. Once a project is submitted, the utilities must prioritize projects to ensure that resources are directed to the most urgent for public health, safety, and public interest.6 • 3 Resiliency Project Engagement Guide: The utilities must develop a resiliency project engagement guide to assist local and tribal governmental entities and their community members in the early stages of resiliency project planning to better prepare for emergencies, including wildfires and PSPS outages.5 • 2 Semi-Annual Workshops: The utilities must conduct semi-annual workshops designed to help empower local and tribal jurisdictions with a better understanding of grid operations, utility infrastructure, and the nature of weather events alongside utilities’ Public Safety Power Shutoff (“PSPS”) mitigation initiatives in order to make informed decisions on where to focus their resiliency planning efforts, capital investments, and pre-PSPS event operations.4 Separate, Access-Restricted Data Portal: The utilities must develop a separate, access-restricted data portal for sharing information with local and tribal governments to help identify microgrid and resiliency project development opportunities. The Commission’s goal is that the information provided through the portal will enable the development of higher quality interconnection applications that take less process cycle time for the utilities to approve.7 Id. at 3. Decision at 2. Id. at 51-52. Id. at 57. Id. at 61-62. Id. at 65.
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Public Utilities Commission 3 February 17, 2021 In order to implement these requirements, the Decision requires the utilities to file Tier 2 advice letters within 30 days that include the utilities’ proposals for each of these directives. However, OP 21 provides that the utilities “are permitted to consolidate Advice Letter filings related to information sharing as directed in Ordering Paragraphs 7-11 to aid efficient processing.” On July 17, 2020, SDG&E submitted AL 3571-E with its proposals for complying with OPs 7, 9, and 10 to support local and tribal governments in their resiliency planning efforts, including access to relevant information from SDG&E. Although AL 3571-E was not protested, SDG&E submits this supplemental advice letter to replace AL 3571-E in its entirety, addressing additional guidance from Energy Division. A) SEMI-ANNUAL WORKSHOPS FOR SHARING INFORMATION The Decision asks the utilities to develop plans for semi-annual workshops designed to empower local and tribal jurisdictions with a better understanding of grid operations, utility infrastructure, and the nature of weather events alongside the utilities’ PSPS mitigation initiatives in order to make informed decisions on where to focus their resiliency planning efforts, capital investments, and pre-PSPS event operations.8 To comply with the Decision, SDG&E proposes to leverage its existing and ongoing working relationships, partnerships, and forums, where the County of San Diego Office of Emergency Services (“County OES”) and local and tribal governments participate to provide the most value and cohesion for each agency. Local resiliency project planning is not a one-size-fits-all need; each agency has different resources, needs, goals, and timing which require more specific discussions. SDG&E intends to continue to perform and refine its existing best practices for community engagement and outreach, with its formal plans established in its annual Wildfire Mitigation Plan and to continue to leverage the ongoing relationships with its local and tribal governments. 1) SDG&E Will Ensure Effective Internal Communication Processes for Interfacing with Local and Tribal Governments Consistent with SDG&E’s relationship-driven approach to local and tribal government engagement, SDG&E proposes to conduct collaborative planning sessions about enhancing grid resiliency in SDG&E’s service territory through the following activities. a) Designating utility interface roles and responsibilities Building on this long history and broad range of collaborative efforts with the community, SDG&E has established an effective internal communication processes to manage interfacing with local and tribal governments. SDG&E has dedicated staff from Regional Public Affairs, Business Services, and Emergency Management in place for each local 8 OP 7.
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Public Utilities Commission 4 February 17, 2021 and tribal government and partner organizations. These dedicated staff members work closely together, establish direct relationships with each agency, act as liaisons across all of SDG&E’s internal departments and processes, and will provide ongoing support for SDG&E’s proposed semi-annual workshops. As outlined in more detail below under the “Dedicated Staffing” of this advice letter, SDG&E has a core team that supports each local and tribal government within its service territory. Through its assigned staffing in Regional Public Affairs, Business Services, and Emergency Management, SDG&E has been effectively meeting the unique needs of its partners. In addition to SDG&E’s existing efforts, the Decision provides more prescriptive requirements in planning, coordination and reporting, given the breadth of content crossing multiple internal technical groups and issues. These new requirements are outside the scope of the existing duties of the dedicated core team. Coordination across governments and Decision requirements may require that a new program manager be hired on a full-time basis to manage local government resiliency planning requirements outlined within the Decision. Since the time of the Decision, SDG&E added two Municipal Infrastructure Advisors in Regional Public Affairs to enhance communication, support, and coordination efforts with municipal and tribal government on both SDG&E and external infrastructure projects. The Municipal Infrastructure Advisors are partnering with the Project Coordinators within Business Services to build upon current processes and add deeper layers of support to local and tribal governments as new requirements and opportunities arise. At this time, SDG&E believes that existing staffing can support this work. However, SDG&E will reevaluate whether to hire additional staff as SDG&E further develops its implementation of the Microgrid OIR Track 2 decision, as additional needs may arise and local government projects increase. b) Managing engagement with local and tribal government and building and sustaining effective relationships SDG&E has spent decades developing and nurturing collaborative relationships with the community, providing close, customized support and single points of contact for local and tribal governments to obtain the information and support they seek. Additionally, as leadership and roles change within our jurisdictions, SDG&E’s dedicated core team reach out to establish relationships with the new partners. When the Emergency Operations Center is activated, each public safety partner is provided with the designated point of contact from Regional Public Affairs, Business Services, and Emergency Management. This staff is available 24 hours per day to ensure timely communications. c) Establishing and maintaining open, accurate, and consistent lines of communication
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Public Utilities Commission 5 February 17, 2021 Some jurisdictions (whether tribal or municipal) have regular meetings with SDG&E to discuss both the jurisdiction’s projects and SDG&E projects planned within that jurisdiction. In other jurisdictions, meetings are ad hoc to discuss planning and projects. In all instances, SDG&E maintains open lines of communications and checks in regularly with its jurisdictional partners. SDG&E’s service territory consists of two county governments (all of San Diego County and a portion of Orange County), 27 incorporated cities, and 18 federally recognized tribal nations. In both culture and practice, SDG&E has adopted a collaborative, relationshipdriven approach to local government engagement and has an existing skilled and expert dedicated team that supports local and tribal governments. Each local and tribal government within SDG&E’s distribution service area is assigned to either a Regional Public Affairs (“RPA”) Manager or Tribal Liaison and an Account Executive, both of whom are dedicated points of contact available to answer any question the government has as it relates to SDG&E. RPA Managers, Tribal Liaisons, and Account Executives work together as a team along with support staff, which includes dedicated Municipal Advisors and Project Coordinators. This team provides comprehensive support to government customers, covering infrastructure projects, account inquiries, distributed energy resources, clean transportation, and other energy- and gas-related needs. This staffing acts as a liaison across the various departments and internal SDG&E activities to meet the specific needs of each local and tribal government. This core team has regional expertise for each local and tribal government. For example, each jurisdiction, such as the City of San Diego, has its own RPA manager, Account Executive, Business Analyst, Project Coordinator and municipal advisors.9 These assignments ensure that each entity has access to individualized expertise and the ease of direct phone and email contacts. The needs of local and tribal governments are met as quickly and easily as possible, providing more customized advice and guidance, grounded in familiarity with an individual jurisdiction. With this comprehensive staffing, SDG&E is able to work collaboratively and crossfunctionally to ensure the most comprehensive outreach and effective engagement throughout project lifecycles. SDG&E has dedicated staffing in place to meet the objectives of the Decision, as outlined in this advice letter. d) Involving local and tribal government in planning and vetting of utility actions impacting local and tribal government SDG&E’s public safety partners are engaged in SDG&E’s efforts throughout the year in preparation for the wildfire season. SDG&E conducts multiple outreach opportunities to share and discuss draft plans that impact local and tribal governments. At the end of every wildfire season, SDG&E conducts a robust After-Action Review for quality 9 For a complete listing of core dedicated team assignments, see Attachment A.
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Public Utilities Commission 6 February 17, 2021 assurance and control. Internal and external partners are invited to a series of workshops to help SDG&E understand what went well and what needs improvement. This collaboration informs a subsequent improvement plan. SDG&E applies the lessons learned from these workshops to update its plans, protocols, and processes. As outlined in this advice letter, there are a plethora of forums that SDG&E leverages to establish focused, specific outreach and collaboration on a broad range of emergency management, wildfire mitigation, and resiliency planning. This outreach is complemented by project specific outreach that is customized to each unique project and local community. Some projects impact traffic flows and warrant partnership with local governments to minimize impacts. Other complex projects require ongoing meetings and outreach to understand opposition and opportunities for win-win solutions. With SDG&E’s strategic underground projects that will provide direct underground feeds to critical facilities within local jurisdictions, including tribal lands, SDG&E has initial discussions with the appropriate government staff and tribal leaders to brief them of the potential project. Moving forward SDG&E works collectively with these governments to determine where there may be efficiencies with other planned jurisdictional work, or moratoriums on road paving, and coordinates input based on government needs, cultural resources, and other items of relevance or concern. e) Executing agreements impacting local and tribal governments SDG&E has successfully shared information needed with local and tribal governments for decades to support their project planning, including resiliency projects. SDG&E is sensitive to the evolving needs and desires of its communities and values ongoing collaboration and problem-solving. SDG&E is confident in its ability to meet the needs of each agency. SDG&E currently has one non-disclosure agreement with San Diego County Office of Emergency Services for the sharing of medical baseline customer data. Emergency Management, in consultation with the Legal department, administers this agreement. Depending on future needs of other local and tribal governments, SDG&E will execute non-disclosure agreements to protect sensitive information. SDG&E’s dedicated Regional Public Affairs Managers and Account Executives have worked diligently for decades to build close, strong relationships with our local and tribal governments. In addition to timely and consistent responses to their inquiries and requests, SDG&E proactively engages local and tribal governments in a variety of forums, as discussed above, regarding SDG&E’s wildfire mitigation efforts, including PSPS protocols. These forums are supported by many more SDG&E teams and personnel. Since the time of the Decision, SDG&E added two Municipal Infrastructure Advisors in Regional Public Affairs to enhance communication, support, and coordination efforts with municipal and tribal government on both SDG&E and external infrastructure projects. The Municipal Infrastructure Advisors are partnering with the Project Coordinators within Business Services to build upon current processes and add deeper layers of support to
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Public Utilities Commission 7 February 17, 2021 local and tribal governments as new requirements and opportunities arise. SDG&E will continue to update its internal processes and procedures with additional information on emergency preparedness and SDG&E’s wildfire risk and PSPS impact mitigation efforts as needed to provide effective communication with its local and tribal governments. 2) Draft Agenda Items to Meet the Specific Content Requirements of the Workshops SDG&E details its tentative approach to planning the agendas for the semi-annual workshops in Attachment B. Though the meetings will evolve and conform to the changing and unique needs and interests of the entities participating, the content of these semi-annual workshops will include, at a minimum: • • • • • • • • Explanations of how the electric transmission system and distribution system operates in the area Explanations of local grid topology and circuit configuration Informing local and tribal governments about electric transmission and distribution infrastructure investment and operational plans Discussion and visualization for context purposes of prior PSPS events Weather and climatology analysis predictions for anticipated PSPS events Case studies of outage scenarios a county is likely to experience based on predictable weather events Granular, local reporting of reliability statistics How the SDG&E plans to incorporate and reflect community and local and tribal government input 3) SDG&E’s Coordination and Outreach to Local Government Entities a) Outreach to county office of emergency services or other, similar government organizations responsible for implementing the State Emergency Plan SDG&E has existing collaborative relationships with its county OES groups and other emergency management groups within its service territory. Notably, SDG&E has many former local jurisdiction and American Red Cross emergency managers on staff. These individuals have established relationships embedded within these organizations, plus the expertise and experience of jurisdictional emergency management. SDG&E meets regularly with the emergency management teams in its territory and will invite representatives that support local emergency services to its semi-annual workshops. b) Moderated by county office of emergency services administrator, or other similar government organization, (unless administrator specifically declines invitation to do so, and either designates another government organization or has the utility moderate)
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Public Utilities Commission 8 February 17, 2021 SDG&E is in the initial stages of meeting with the County OES administrators to determine their commitment to moderating the workshops or whether they intend to designate SDG&E or another entity to act as the moderator. As of this filing, County OES has informally indicated their preference is for SDG&E to assume the role of moderator. c) Outreach to community and tribal organizations, including representation of disadvantaged communities and access and functional needs populations SDG&E has over 400 community partners that help support disadvantaged and AFN populations. These are partners where SDG&E has an ongoing relationship and utilizes these partners to help amplify SDG&E’s messages about wildfire safety and PSPS events. SDG&E is also launching the AFNAC that will meet at least semi-annually to further discuss the needs of AFN communities. Through these channels, SDG&E has regular discussions with community organizations. SDG&E will invite representatives from these organizations to its semi-annual workshops, both to present on challenges these organizations face with resiliency and for them to access the information they need. Throughout the year SDG&E has touchpoints with its local governments at different levels and aspects of the organization, including through the departments described in this advice letter. These touchpoints are managed by dedicated staffing in Regional Public Affairs, Business Services, and Emergency Management. SDG&E has hosted in-person, and more recently virtual meetings and webinars, to provide information on new projects and developments. For example, in the fall of 2020 SDG&E held a number of PSPS webinars which explained WMP work which is being deployed to benefit local governments, including tribal governments. SDG&E held webinars on the Tribal Land Transfer Policy and Section 851 filings for local governments and tribes to introduce them to this new process and policy. SDG&E also has regular and ad hoc meetings with local governments to discuss projects, both SDG&E’s projects and the government’s projects. In addition to the annual sessions SDG&E’s Emergency Management conducts in February, SDG&E also attends the quarterly Regional Emergency Managers meeting to collaborate and provide updates. Additionally, SDG&E meets with County OES in August to discuss any changes to PSPS or wildfire response plans. Finally, in addition to any land use consultation requirements under GO 131-D, Section XI, SDG&E typically hosts a community open house prior to commencing any large-scale infrastructure project. For projects smaller in scope where an open house is not appropriate, SDG&E meets with local community groups, such as the established community planning group, community advisory board, homeowners’ association, or other relevant stakeholders, in addition to local municipal leaders. SDG&E works with
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Public Utilities Commission 9 February 17, 2021 these stakeholders to incorporate their feedback, resolve their concerns, and maintain good relationships as possible and appropriate. d) Incorporate relevant elements of a community-based collaborative planning framework as suggested by the Energy Division Staff Proposal (i.e., as the National Institute of Standards and Technology Community Resilience Planning Guide or its Resilient Communities Toolkit) The Decision references the National Institute of Standards and Technology Community Resilience Planning Guide for Buildings and Infrastructure Systems (“NIST Guide”) for the utilities to follow. The NIST Guide provides a six-step process to help all communities improve their resilience by setting priorities and allocating resources to manage risks: 1. 2. 3. 4. 5. Form a collaborative planning team Understand the situation Determine goals and objectives Plan development Plan preparation, review, and approval SDG&E appreciates this sound approach to collaboration with local governments, as it resonates with SDG&E’s long-standing business practices. When it comes to local and tribal government resiliency projects, SDG&E’s dedicated staffing assemble ad hoc teams specific to each project and the internal technical experts to address all facets of the project. For the semi-annual workshops, SDG&E will leverage this approach depending on the level of interest, engagement, and each agency’s specific needs. Each jurisdiction has varying needs, priorities, and interests, and SDG&E will need to monitor participation and tailor this six-step process to meet the goals identified in each workshop. e) Based on best practices such as San Diego Gas & Electric Company’s community engagement As discussed above, SDG&E already participates in multiple venues and meetings throughout the year to collaborate with community and government leaders. The County OES is a member of the WSCAC and will co-chair the PSPSWG. These ongoing meetings address the broad range of wildfire and PSPS emergency planning and operations and are one appropriate venue to discuss collaborative planning about enhancing grid resilience within local and tribal government areas. SDG&E will continue to leverage these existing meetings to provide resiliency information and solicit best practices to help refine relevant protocols. SDG&E will also create new semi-annual workshops geared toward government staff, associated agencies and their consultants. These workshops will focus on resiliency planning and be more technical or granular in nature than SDG&E’s existing working groups and advisory councils, providing additional information on grid operations, utility
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Public Utilities Commission 10 February 17, 2021 infrastructure, and the nature of weather events alongside SDG&E’s PSPS mitigation initiatives. SDG&E proposes to hold two workshops a year, to coincide with the timing of two of the four PSPS Working Group meetings that SDG&E will hold. Given the all-hands-on-deck focus in the months leading up and during wildfire season, SDG&E proposes to hold these events in December and June annually. Given the unique composition of SDG&E’s service territory, with most of SDG&E’s jurisdictions having never experienced a PSPS event, SDG&E believes it would be most efficient to break the focus of the two workshops into two components: 1) the electric system, and 2) fire science, climate adaptation, and PSPS Jurisdictions less interested in the fire science/PSPS portions of the workshop do not have to attend both. In both workshops, SDG&E will cover the resiliency tools, reliability reporting and hold collaborative planning breakout sessions. Attendees of the resiliency workshops will be invited and have the opportunity to attend the preceding utility working group meetings. Additionally, SDG&E educates its jurisdictional partners throughout the year on PSPS, as well as planned projects in their area. This education will continue to occur outside of the workshops. While these semi-annual workshops will comply with the plain language of the decision, SDG&E intends for the workshops to be meaningful and tailored to incorporate local and tribal government’s resiliency needs. SDG&E expects that the first workshop will be an introduction or orientation for its local governments. SDG&E has undertaken many critical investment activities where the impacted local governments and communities are very familiar with the status of SDG&E’s project development. However, there will be additional local governments who are not located in high fire threat districts or impacted by PSPS events. For this reason, the collaborative planning session will be a critical agenda item. After SDG&E presents a wealth of content, responding to questions throughout the presentation, a significant amount of time will be devoted to a guided dialogue in which SDG&E will seek specific input from local and tribal governments to facilitate a meaningful conversation about resiliency needs and planning. This will inform what additional ad hoc meetings will be needed with specific governments or tribes, where stakeholders need to be introduced and connected to one another for specific information or support, and how to refine SDG&E’s content and approach for subsequent semi-annual workshops. At each subsequent workshop, SDG&E will provide status updates of projects and issues discussed at previous meetings so that each workshop builds on the previous workshop.
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Public Utilities Commission 11 February 17, 2021 Local governments have a variety of forums to affect change, depending on their specific needs and requests. Throughout the year, SDG&E works directly with its public safety partners (e.g., local cities, counties, tribal governments, water and telecom providers and emergency response partners) to educate them on Public Safety Power Shutoffs and collaborate on how to minimize the impact to the region. SDG&E also engages its community partners, such as fire safety councils, planning groups, chambers of commerce and Community Emergency Response Teams, and provides these organizations with education on PSPS events. SDG&E recognizes that each jurisdiction, utility, and emergency response partner has diverse needs and different perspectives, but all have the common goal of increasing resiliency and minimizing the impacts of shutoff events. Therefore, SDG&E deploys an educational approach that is collaborative and varied. For example, SDG&E holds PSPS briefings individually with local elected officials and government staff and holds tabletop exercises for water and telecom utilities. As described below, SDG&E has already established various advisory councils to receive input and feedback, and to provide support regarding wildfire-related matters, including PSPS. The working groups and advisory councils below represent external stakeholders that are experts in their region and field and provide invaluable input to SDG&E. • Community Advisory Council (“CAC”): In 1998, SDG&E established its CAC comprised of 20 members to receive input and feedback and provide support on various issues, including wildfire matters. The CAC provides for a direct and candid exchange of ideas and perspectives among SDG&E’s senior leadership and a diverse cross-section of community leaders representing academic, business, labor, faith-based, non-profit, environmental, law enforcement and safety, local government, and other civic interests in the San Diego region. The CAC meets quarterly to provide recommendations on a broad spectrum of SDG&E and state regulatory issues, such as clean transportation, customer programs, rates, natural gas pipeline safety, infrastructure projects, and wildfire safety. • Wildfire Safety Community Advisory Council (“WSCAC”): In 2019, SDG&E formed its WSCAC comprised of a specialized group of diverse and independent community leaders from public safety, tribal government, business, nonprofit, and academic organizations in the San Diego region. The members of the WSCAC possess extensive experience in public safety, wildfire management, communitybased services, and applied technology. The WSCAC provides constructive input, feedback, suggestions, and support to SDG&E senior management and the Safety Committee of SDG&E's Board of Directors on how SDG&E can continue to help protect the region from wildfires. The WSCAC meets at least semi-annually. • County of San Diego Office of Emergency Services Access and Functional Needs (“AFN”) Working Group: Locally, SDG&E is a member of the County OES AFN Working Group, which is comprised of over 40 members including local CBOs and cities. The purpose of the AFN Working Group is to ensure emergency planning
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Public Utilities Commission 12 February 17, 2021 efforts in San Diego County reflect the unique needs of all communities within the county. This group works to identify the needs of individuals with disabilities and other access and functional needs before, during and after disaster strikes. The group takes steps to ensure that needs and resources are integrated into emergency management systems. SDG&E worked closely with County OES and the AFN Working Group in advance of the 2019 PSPS events to help amplify SDG&E’s de-energization notification messaging to residents whom these organizations support. • Public Safety Power Shutoff Working Group (“PSPSWG”): In 2020, SDG&E worked closely with County OES to help the AFN population prepare for emergencies, establishing two separate AFN-specific working groups in the same territory would be a draw on all organizations’ resources that work with the AFN population. SDG&E has formed a sub-committee to the County OES AFN Working Group to exclusively address utility-related issues, including community resource centers, communication strategies, information-sharing and supporting AFN populations. SDG&E plans to utilize this subgroup input to continue to inform its strategy for the AFN population and PSPS events as a whole, while ensuring there is a formal environment, within which lessons learned between the impacted communities and the utility can be shared. The PSPSWG provides a forum for community leaders, some of whom serve the AFN community to provide constructive input and feedback on SDG&E’s and the region’s efforts to meet community needs. SDG&E plans to incorporate this feedback to refine certain PSPS protocols. The PSPSWG will meet at least quarterly. However, SDG&E will be convening smaller ad hoc meetings of AFN population subgroups as needed. 4) SDG&E’s Coordination with Other Proceedings, General Orders, and Requirements a) Public Safety Power Shutoff working group meetings, as required by Rulemaking 18-12-005 and any subsequent requirements arising from that proceeding b) Disaster response plan requirements pursuant to General Order 166 c) Annual reliability reporting obligations pursuant to Decision 16-01-008 and Public Utilities Code Section 2774.1 d) Land use consultation requirements as laid out in GO 131-D, Section XIV. SDG&E intends to conduct the semi-annual workshops ordered in the Decision such that they occur on the same day as PSPS working group meetings. The goal is to consolidate these meetings to benefit participating local governments and tribes. Many of these stakeholders have the same staff participating in both forums; however, many other local governments and tribes, especially those larger in size and resources, have different staff involved given the different focus. For instance, emergency services and community development staff participating in a PSPS working group meeting may not have the
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Public Utilities Commission 13 February 17, 2021 expertise or assignment to topics related to resiliency planning, which may be instead assigned to engineering or planning staff. SDG&E combines the General Order (“GO”) 166 reporting requirement and the Assembly Bill 1650 requirements by annually presenting its planning efforts to the Regional Emergency Managers meeting with an expanded audience. SDG&E conducts two sessions annually, one for San Diego participants and one for Orange County participants. Typically, these are conducted in February. SDG&E will provide information from its Electric System Reliability Annual Report as part of the workshop agenda after the report becomes available, which is typically in July of each year. This review would be in addition to the annual townhall meeting held by SDG&E to share this report, as required by D.16-01-008. SDG&E supports collaborative workshops and regular forums for engaging with local and tribal governments and interested stakeholders regarding wildfire safety, de-energization, and resiliency planning. Currently, SDG&E conducts such collaboration. Pursuant to its obligations pursuant to GO 131-D, Section XIV, SDG&E conducts land use consultations, ranging from focused neighborhood meetings to meetings with local Community Planning Groups acting as advisory boards to the local government. SDG&E arranges ad hoc meetings with agencies to address their specific needs and questions. SDG&E will continue this formal and informal outreach to share information with local and tribal governments, meeting the goals and objectives of the Decision while also satisfying GO 131-D requirements. B) RESILIENCY PROJECT ENGAGEMENT GUIDE As discussed above, SDG&E has implemented a fast interconnection process for all its customers – whether an individual resident, a commercial business, a local government, or military base. Figure 1 above shows that SDG&E processed interconnection requests on average in less than four business days from the date of a complete interconnection application throughout 2019 for Rule 21 projects. SDG&E evaluated the requirement to create a resiliency project engagement guide for local and tribal governments, and, considering the success of SDG&E’s existing interconnection process, SDG&E proposes to leverage its existing Customer Generation website and make the guide available and applicable to all its customers. SDG&E plans to make updates to its resiliency project engagement guide and webpage to be consistent with Commission directives in this proceeding. Under current CPUC rules and regulations, IFOM microgrid configurations are largely prohibited. However, once the Commission does develop guidance around the deployment of third-partyowned or operated IFOM microgrids SDG&E will amend its webpage to reflect that new guidance. Such guidance will include disposition of the advice letters implementing the Microgrid Incentive Program in the Track 2 decision and any further Commission orders in Track 3 of this proceeding. Importantly, local government entities exploring the
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Public Utilities Commission 14 February 17, 2021 deployment of an IFOM microgrid will work with their SDG&E RPA Manager or Tribal Liaison and Account Executive, who will assemble the proper SDG&E staff to discuss the project and determine its feasibility. SDG&E will notify its local and tribal governments via email once it is launched and will present this guide at the semi-annual workshops. SDG&E will update the guide as needs arise. Whether and how to incorporate into the guide will depend on the type of feedback received. Sometimes SDG&E observes a significant number of customers asking for the same clarification or information; this causes SDG&E to recognize where information is unclear or merits additional detail to meet customer needs. Other times, customers may request changes to the guide that will conflict with the statutory or regulatory limitations, or perhaps would cause significant information technology improvements that are costly. SDG&E commits to reviewing stakeholder feedback, evaluating it, and responding in a timely matter. Furthermore, as SDG&E works with the IOUs, stakeholders, and Commission to implement the Track 2 decision, SDG&E will evaluate the best way to communicate information in updates to the guide. 1. Mockup showing how data will be presented SDG&E has developed a dedicated Customer Generation webpage,10 with a snapshot shown in Figure 2 below, that includes an overview of Generation Interconnections as well as links to the appropriate process for customers that will be interconnecting to SDG&E’s transmission or distribution system. This existing web page will be revised to present a list of various types of resiliency projects available to customers, including local and tribal governments. In addition, SDG&E will include a section for safety as well as a section to identify key elements for a successful interconnection. 10 See Overview of Generation, available at https://www.sdge.com/more-information/customergeneration.
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Public Utilities Commission 15 February 17, 2021 Figure 2. Generation Interconnection Overview Figures 3 and 4 display the detailed Electric Rule 21 Package that provides customers with a link to SDG&E’s Electric Rule 21 tariff and the complete listing of forms that comprise the application.11 The Rule 21 Package provides various Interconnection Agreement forms, data sheets, diagrams, as well as, Net Generation Output Meter Checklists for systems such as Photovoltaic, Advanced Energy, and Fuel Cell. Additionally, a customer can access information regarding Renewable Energy SelfGeneration Bill Credit Transfer, Emergency Standby Generators, contact information for 11 Electric Rule 21 Package, available at https://www.sdge.com/more-information/customergeneration/electric-rule-21#package.
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Public Utilities Commission 16 February 17, 2021 the Customer Generation team and the Rule 21 Ombudsman. This page also provides additional Rule 21 resources such as the unit cost guide, application user guide, distribution interconnection handbook and other links available to customers. Last, there is as a button available on this web page which directs customers to the “Apply for Rule 21 Behind the Meter” landing page. Here, customers may access the Distribution Interconnection Information System (“DIIS”) Guide to begin the application process as well as view a tutorial to learn how to register for SDG&E’s “My Partners” database where customers can manage their projects. Figure 3. Electric Tariff Rule 21
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Public Utilities Commission 17 February 17, 2021 Figure 4. Electric Rule 21 Package 2. Contents of the guides a. Types of resiliency projects SDG&E’s resiliency project engagement guide will include information for distributed generation planning for Rule 21, behind-the-meter projects. These projects can include: • • • • Non-Export Isolated Operations Momentary Parallel Operations Net Energy Metering (“NEM”) Solar Paired with Energy Storage b. Draft flowcharts for the above project types including project/interconnection milestones and timelines The Rule 21 behind-the-meter interconnection process is illustrated in Figure 5 below. The flow chart includes three options to obtain a successful interconnection with SDG&E, including process timelines and applicable fees.
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Public Utilities Commission 18 February 17, 2021 Figure 5. Rule 21 Interconnection and Study Process c. Data required at each step in the process SDG&E’s resiliency project engagement guide will provide a list of required data for Rule 21, behind-the-meter projects, along with a description of each item and, if applicable, links to a webpage associated with that item. The required data include the following: • Completed and signed Letter of Authorization form12 • Completed and signed Generating Facility Interconnection Application13 • Electrical Single-Line Diagram Drawing • Site Exclusivity Documentation • Certificate of Insurance or Statement of Self-Insurance d. Engagement best practices SDG&E is in the process of establishing Engagement Best Practices that will be added to the main Generation Interconnection webpage, as well as the Resiliency Project SDG&E Form 185-1000 Authorization to Receive Customer Information or Act on a Customer’s Behalf, available at: www.sdge.com/sites/default/files/documents/Standard%20CISR%20form%20interactive.pdf. 13 SDG&E Form 142-05203 Generating Facility Interconnection Application, available at: regarchive.sdge.com/tm2/pdf/ELEC_ELEC-SF_142-05203.pdf 12
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Public Utilities Commission 19 February 17, 2021 Engagement Guide. Examples of these best practices include, but will not be limited to, the following list below: o Multiple options for an applicant to obtain information for an easy and smooth interconnection process.  Clear engagement guide and checklists available on SDG&E’s website  Semi-annual workshops for local and tribal governments  Designated point of contact available via email or phone o Multiple application options o Timely interconnection processing time o Effective and efficient communication 3. Plans for how the guides will be made available to the public SDG&E’s web page is currently available to customers, including local and tribal governments, interested in moving forward with resiliency projects. However, SDG&E will add a resiliency project engagement guide document to the main Customer Generation Interconnection webpage. 4. How the guides will be kept current with new modifications SDG&E will perform regular maintenance and include required modifications to the resiliency project engagement guide and associated webpages to keep up with ongoing updates to its systems, policies, and procedures. 5. Timeline for release of guides in compliance with this Decision The Resiliency Project Engagement Guide is expected to be available to the public in the fall of 2020. C) DEDICATED STAFFING FOR LOCAL AND TRIBAL GOVERNMENTS 1) Supporting Local and Tribal Governments with Dedicated, Individualized Expertise SDG&E’s service territory consists of two county governments (all of San Diego County and a portion of Orange County), 27 incorporated cities, and 18 federally recognized tribal nations. In both culture and practice, SDG&E has adopted a collaborative, relationshipdriven approach to local government engagement and has an existing skilled and expert dedicated team that supports local and tribal governments. Each local and tribal government within SDG&E’s distribution service area is assigned to a Manager in SDG&E’s Regional Public Affairs organization and an Account Executive in SDG&E’s Business Services organization, both of whom are dedicated points of contact available to answer any question the government has as it relates to SDG&E. RPA
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Public Utilities Commission 20 February 17, 2021 Managers, Tribal Liaisons, and Account Executives work together as a team along with support staff, which includes a dedicated Business Analyst and Project Coordinators within Business Services. This team provides comprehensive support to government customers, covering infrastructure projects, account inquiries, distributed energy resources, clean transportation, and other energy- and gas-related needs. This staffing acts as a liaison across the various departments and internal SDG&E activities to meet the specific needs of each local and tribal government. This core team has regional expertise for each local and tribal government. For example, each jurisdiction, such as the City of San Diego, has its own RPA manager, Account Executive, Business Analyst, Project Coordinator and municipal advisors.14 These assignments ensure that each entity has access to individualized expertise and the ease of direct phone and email contacts. The needs of local and tribal governments are met as quickly and easily as possible, providing more customized advice and guidance, grounded in familiarity with an individual jurisdiction. With this comprehensive staffing, SDG&E is able to work collaboratively and crossfunctionally to ensure the most comprehensive outreach and effective engagement throughout project lifecycles. SDG&E has dedicated staffing in place to meet the objectives of the Decision, as outlined below. a) Provide advice and guidance before proposal development begins and throughout the process Relationships and ongoing working partnerships are in place before a proposal development begins. SDG&E’s local and tribal governments know the direct phone number and email to at least two people – their dedicated RPA Manager or Tribal Liaison and Account Executive. These contacts routinely coordinate SDG&E’s internal resources from the appropriate departments to consolidate communications and ensure that all inquiries are met. SDG&E also proactively reaches out to these governments as new programs and offerings arise, to discuss opportunities of support for these governments. This Decision builds upon these already-open lines of communications, by adding more formal tools, semi-annual workshops, a resiliency project engagement guide and data portal. The Decision’s directives complement SDG&E’s existing personalized resources. The Decision’s new required tools provide additional transparency and forums where local and tribal governments can access information from SDG&E, ask SDG&E questions, and obtain SDG&E’s support in exploring microgrid opportunities. Prior to developing a proposal, a local government agency may reach out directly to their RPA Manager, Tribal Liaison, Account Executive, Municipal Infrastructure Advisor, or Project Coordinator. They will also have access to SDG&E’s resiliency project engagement guide and be invited to SDG&E’s semi-annual workshops proposed in this 14 For a complete listing of core dedicated team assignments, see Attachment A.
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Public Utilities Commission 21 February 17, 2021 advice letter. Whether through direct outreach, review of published material, or workshop attendance, local and tribal governments will receive additional guidance on utility projects, reliability and PSPS events. b) Prioritize projects to ensure that resources are directed to the most urgent needs of public health, safety, and public interest In addition to the dedicated staffing that act as liaisons, local and tribal governments can enjoy the many improvements that SDG&E has undertaken over the past seven years to streamline the interconnection process. Such improvements include: • SDG&E developed and launched an application in July 2017 that ties directly into the Distribution Interconnection Information System (“DIIS”) interconnection portal so that the relevant authority having jurisdiction can release all generation types with one click – by phone, tablet, or desktop. • SDG&E supports a 24-hour response time. SDG&E Customer Generation’s business policy is to return all emails and phone calls within the same business day. Customers needing assistance may call a direct phone number or send an email to a dedicated email address. Calls and emails are monitored throughout the day within the Customer Generation group. • SDG&E has implemented single-line diagram (“SLD”) for Net Energy Metering – Successor Tariff (“NEM-ST”) customers with systems 30 kW or less that do not require a disconnect or a CT-rated panel. SDG&E has a high percentage of contractors that utilize this option. SDG&E has also implemented a Fast Track process for these same customers in which the contractor can upload a picture of the customer’s service panel, meter, and warning placard in lieu of a field inspection. Approximately 80% of the NEM-ST applications submitted to SDG&E use this feature. SDG&E is concurrently expanding its SLD templates to comply with the Decision, and these templates will also serve local and tribal government projects. • SDG&E accepts electronic signatures for all applications through its DIIS portal. For NEM-ST customers with systems that are 1 MW or less, as soon as the application is submitted, the customer receives a link via email to electronically accept the Interconnection Application and its Terms and Conditions. • SDG&E’s latest portal upgrade eliminates much of the manual data entry process. After the account and meter number is verified during Step 1 in the application process, the system automatically populates all existing onsite generation using SDG&E’s database to eliminate manual entry.
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Public Utilities Commission 22 February 17, 2021 As an added customer service and a tool to reduce delays in application processing, SDG&E has created a dedicated phone number and a dedicated email address so that customers can contact the Customer Generation team directly. SDG&E Customer Generation’s internal goal is to respond to all emails and phone calls during the same business day in which they are received. Figure 1. NEM and Rule 21 Project Approvals and Timelines in 2019 NEM Project Approvals and Timelines in 2019 Interconnection Type Residential Projects Residential Megawatts NonResidential Projects NonResidential Megawatts TOTAL Projects TOTAL Megawatts NEM Solar/Wind 30,485 172.45 443 37.90 28,437 210.35 NEM Paired with Storage 2,463 14.205 28 4.77 2,491 18.98 NEM TOTAL 32,948 186.655 471 42.67 30,928 229.33 Average Calendar Days to PTO 2.52 2.10 Rule 21 (Non-NEM) Project Approvals and Timelines in 2019 Interconnection Type Residential Megawatts NonResidential Megawatts TOTAL TOTAL Megawatts Fuel Cells 0 0 5 7.75 5 7.75 Standalone Batteries 20 0.34 20 6.71 40 7.05 Microgrid Systems 0 0 1 6.40 1 6.40 Rule 21 TOTAL 20 .335 26 20.86 46 21.2 Average Business Days to Authorized 2.65 3.44 As reflected in Figure 1, in 2019, SDG&E provided permission to operate (“PTO”) on average within less than (i) three calendar days of interconnection application submittal for NEM customers, and (ii) four business days for Rule 21, non-NEM projects after it received a completed application, which includes the electrical release from the local Authority Having Jurisdiction. This performance demonstrates that SDG&E is ready to meet the needs and timing requirements for all customers, including local and tribal governments.
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Public Utilities Commission 23 February 17, 2021 c) Assist local jurisdictions with consulting advice on the types of resiliency projects that can be expedited through the permitting and interconnection processes SDG&E will encourage local and tribal governments to attend the proposed semi-annual workshops to assist them with their resiliency projects. Additionally, SDG&E will continue to respond directly to all requests through their dedicated RPA Manager, Tribal Liaison, Account Executive, Project Coordinator, or Municipal Infrastructure Advisor. Many contractors and consultants working for these entities also successfully engage SDG&E’s Customer Generation group directly for interconnection issues. Through SDG&E’s semiannual workshops, local and tribal government staff will gain a high-level overview of what support and resources are available to them in their resiliency planning while also learning about SDG&E’s infrastructure projects relevant to them. These workshops also provide an extra opportunity for staff from the local and tribal governments to meet with and deepen relationships with their assigned SDG&E contacts. Stronger relationships will facilitate targeted or regular meetings for SDG&E to support local and tribal governments’ resiliency planning. Because SDG&E’s interconnection project is already fast, the best way for customers to expedite the process is to reach out to SDG&E as early as possible and at a regular cadence to ensure that SDG&E is able to support each stage in the project process. Customer Generation is always available, before and after an application is submitted, to answer technical questions that arise with regard to specific projects, including PreApplication Reports. The resources and processes described above will be responsive to any emergent infront-of-meter project types that local governments may wish to pursue. As governments communicate their resiliency planning needs and interests – whether in front of or behind the meter – SDG&E can be responsive with these resources and forums. The semiannual workshops are one new forum to address these needs, in addition to the relationships-based approach and fast Customer Generation response times. Each project is unique. For more complex projects, SDG&E typically coordinates focused meetings with local governments, including the appropriate internal SDG&E staff to support from all angles. d) Provide pre-project information about load points, customer connectivity, load profiles, and the relevant maps and infrastructure data to facilitate local jurisdiction planning Pre-project information is made available to Local Governments through SDG&E’s PreApplication Report.15 This report provides useful information including the capacity, available capacity, allocated capacity, and queued capacity of the substation/area bus or bank and of the circuit likely to serve the proposed site, limiting conductor rating from the 15 See, Rule 21 Pre-Application Report, available at: https://www.sdge.com/moreinformation/customer-generation/electric-rule-21.
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Public Utilities Commission 24 February 17, 2021 proposed Point of Interconnection to the distribution substation, and existing or known constraints such as, but not limited to, electrical dependencies at that location, short circuit interrupting capacity issues, power quality or stability issues on the circuit, capacity constraints, or secondary networks. SDG&E has a publicly available tool that local and tribal governments may access to view relevant maps and infrastructure data to facilitate their resiliency project planning, including integration capacity analysis and locational net benefit analysis. This map is an important first step in the planning process, access is free, and can save jurisdictions time and costs, as this precedes submission of an interconnection application. In addition, the dedicated account executives regularly assemble pre-project information, including load points, customer connectivity, profiles, and any other relevant data as a single point of contact. This core dedicated team exists today and is currently set up to successfully support local government resiliency planning. e) Staffing and training needs for preparing the team As outlined in this advice letter, SDG&E has existing staffing in place to effectively meet the needs of its local and tribal governments. 2) SDG&E’s operational plans for its dedicated staffing to engage local and tribal governments and facilitate application intake and processing Attachment A outlines SDG&E’s existing organizational structure and geographically assigned staffing for Regional Public Affairs Managers, Business Services Account Executives, Tribal Liaisons, and dedicated support staff. Each local and tribal government within SDG&E’s distribution service area is assigned to these staff as dedicated points of contact available to answer any question the government has as it relates to SDG&E. RPA Managers, Tribal Liaisons, and Account Executives work together as a team along with support staff, which includes dedicated Municipal Advisors and Project Coordinators. As a recent example of SDG&E’s existing core dedicated team successfully assisting local governments seeking resiliency support, on October 25, 2019, the California Office of Emergency Services issued a Public Safety Power Shutoff Resiliency Allocation for Tribes Request for Proposal to provide resiliency grants to California tribes impacted by PSPS events. One requirement of this grant was to explain the number of hours spent in PSPS as of October 25, 2019.16 This request for proposals (“RFP”) initially had a November 4, 2019, deadline. Despite the quick turnaround, SDG&E was able to utilize its existing core dedicated team to pull outage information for all impacted tribes and provide this information to the tribes for use in their RFP responses by November 4. This effort in turn enabled tribes to apply for resiliency grant funding. 16 See, Public Safety Power Shutoff (PSPS) Resiliency Allocation to Tribes RFP (October 25, 2019), available at: https://www.caloes.ca.gov/pages/GrantDetails.aspx?itemID=337&ItemTitle=2019-20.
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Public Utilities Commission 25 February 17, 2021 SDG&E also supports local governments seeking resiliency grant funding with endorsement letters, which local governments have used to successfully receive grant funding, and in the eyes of the granting agency is evidence of a collaborative relationship between the utility and the government. Through these collaborative relationships, SDG&E has worked with both municipal and tribal jurisdictions within SDG&E’s territory to provide information and support for microgrid development, which resulted in grant funding from the California Energy Commission and U.S. Department of Energy.17 SDG&E believes it can immediately implement the Decision’s goals for facilitating application intake and processing without additional operational plans. SDG&E has developed many improvements to automate and streamline the interconnection process as described above. However, SDG&E will continue to assess this team over time to determine if it needs to be augmented as government resiliency requests are made. If it does, SDG&E intends to request additional full-time employees to support this effort in future GRC cycles. SDG&E will discuss its plans for dedicated staffing and resources for the Customer Generation group that oversees the interconnection process in an upcoming advice letter, pursuant to OP 3 of the Decision. Through the upcoming resiliency workshops, governments will be provided with an open forum and SDG&E resources to be provided with information, at regular intervals, to ensure resiliency project needs are met. Continuing to have open two-way communication with local governments in addition to these workshops, ensures that developments are communicated. EFFECTIVE DATE SDG&E believes that this filing is subject to Energy Division disposition and should be classified as Tier 2 (effective after staff approval), pursuant to General Order 96-B and Ordering Paragraphs 7, 9, and 10 of D.20-06-017. SDG&E respectfully requests that this submittal be approved effective March 19, 2021, thirty days from 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 must be received by March 9, 2021, which is 20 days from the date submitted. 17 See, DOE Announces $16 Million for 14 Tribal Energy Infrastructure Deployment Projects (July 23, 2019), available at https://www.energy.gov/articles/doe-announces-16-million-14tribal-energy-infrastructure-deployment-projects. See also, https://www.energy.gov/indianenergy/san-pasqual-band-indians-2018-project, https://www.portofsandiego.org/press-releases/general-press-releases/port-san-diego-installsolar-powered-microgrid-5-million, https://microgridknowledge.com/microgrid-grants/, https://www.energy.gov/indianenergy/articles/energy-department-invest-more-5-million-tribalenergy-infrastructure,
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Public Utilities Commission 26 February 17, 2021 There is no restriction on who may submit a protest. The address for mailing or delivering a protest to the Commission is: CPUC Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Copies of the protest should also be sent via email to the attention of the Energy Division Tariff Unit (EDTariffUnit@cpuc.ca.gov). A copy of the protest should also be sent via email to the address shown below on the same date it is mailed or delivered to the Commission. Attn: Greg Anderson Regulatory Tariff Manager Email: ganderson@sdge.com & SDGETariffs@sdge.com NOTICE In accordance with General Rule 4 of GO 96-B, SDG&E is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, R.19-09-009, R.14-07002, and R.17-07-007 service lists, 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 SDGETariffs@sdge.com. ________________________________ 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 (U902) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Joff Morales Phone #: 858-650-4098 E-mail: JMorales@sdge.com E-mail Disposition Notice to: SDGETariffs@sdge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 3571-E-A Subject of AL: Supplemental - San Diego Gas & Electric Company's Plan to Conduct Semi-Annual Workshops, Develop a Project Engagement Guide, and Provide Dedicated Staffing for Local and Tribal Governments Pursuant to Decision 20-06-017 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 #: Decision 20-06-017 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: 3/19/21 No. of tariff sheets: N/A 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: 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: Greg Anderson Title: Utility Name: San Diego Gas & Electric Address: 8330 Century Park Court, CP32C City: San Diego Zip: 92123 State: California Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: GAnderson@sdge.com Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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cc: (w/enclosures) Public Utilities Commission CA. Public Avocates (CalPA) 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 Biofuels Energy, LLC K. Frisbie Braun & Blaising, P.C. S. Blaising D. Griffiths Buchalter K. Cameron M. Alcantar CA Dept. of General Services H. Nanjo California Energy Markets General California Farm Bureau Federation K. Mills California Wind Energy N. Rader Cameron-Daniel, P.C. General 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 NRG Energy D. Fellman Clean Power Research T. Schmid G. Novotny Pacific Gas & Electric Co. M. Lawson M. Huffman Tariff Unit Commercial Energy J. Martin regulatory@commercialenergy.net 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 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 Energy Regulatory Solutions Consultants L. Medina TerraVerde Renewable Partners LLC F. Lee Energy Strategies, Inc. K. Campbell TURN M. Hawiger 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 NLine Energy M. Swindle 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 Copies to AddisScott9@aol.com ckingaei@yahoo.com clower@earthlink.net hpayne3@gmail.com puainc@yahoo.com Service List R.19-09-009 R.14-07-002 R.17-07-007
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Attachment A Dedicated Staffing for Local and Tribal Governments
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Regional Public Affairs RPA Orange County & Cities • County of Orange (unincorporated) • City of Aliso Viejo • City of Dana Point • City of Laguna Beach • City of Laguna Hills • City of Laguna Niguel • City of Mission Viejo • City of Rancho Santa Margarita • City of San Clemente • City of San Juan Capistrano RPA Manager – Inland North & East County • City of El Cajon • City of La Mesa • City of Santee • City of Poway • City of Escondido • City of San Marcos RPA Manager – South Bay • City of Chula Vista • City of Imperial Beach • City of National City • City of Coronado • City of Lemon Grove • City of San Diego – District 8 RPA Manager – Coastal North County • City of Encinitas • City of Solana Beach • City of Del Mar • City of Oceanside • City of Carlsbad • City of Vista • Rancho Santa Fe RPA Manager – County & Unincorporated, Agencies • County of San Diego • Unincorporated San Diego, including Julian, Bonsall, Fallbrook, Valley Center, Borrego Springs, Ramona, Campo, Descanso, Lakeside, Spring Valley, Alpine, Mountain Empire, Bonita, Otay Valley Municipal Infrastructure Advisor I • Central San Diego • Coastal North County • South Bay Municipal Infrastructure Advisor II • Orange County & Cities • San Diego County & Unincorporated • Inland North & East County • Tribal Governments RPA Manager – Central San Diego • City of San Diego • Unified Port of San Diego • San Diego Association of Governments Tribal Relations & Land Services Tribal Liaison • Barona Band of Mission Indians • Campo Kumeyaay Nation • Capitan Grande Reservation • Ewiiaapaayp Band of Kumeyaay Indians • Inaja & Cosmit Band of Indians • Jamul Indian Village • Juaneno Band of Mission Indians • Kwaaymii • La Jolla Band of Mission Indians • La Posta Band of Mission Indians • • • • • • • • • • • Los Coyotes Band of Mission Indians Manzanita Band of the Kumeyaay Nation Mesa Grande Band of Mission Indians Pala Band of Mission Indians Pauma Band of Luiseno Indians Rincon Band of Luiseno Indians San Luis Rey Band of Mission Indians San Pasqual Band of Mission Indians Iipay Nation of Santa Ysabel Sycuan Band of Kumeyaay Nation Viejas Band of Kumeyaay Nation
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Business Services Account Executive, Project Coordinator & Business Analyst – Orange County & Cities and North Coast and Inland • Campo Fire Department • City of Aliso Viejo • City of Carlsbad • City of Dana Point • City of Del Mar • City of Encinitas • City of Escondido • City of Laguna Beach • City of Laguna Hills • City of Laguna Niguel • City of Mission Viejo • City of Oceanside • City of Poway • City of San Juan Capistrano • City of San Clemente • City of San Marcos • City of Solana Beach • City of Vista • County of Orange • Orange County Fire Authority Account Executive, Project Coordinator & Business Analyst – City of San Diego, National City, Imperial Beach, Chula Vista, Coronado, Lemon Grove, Eastern San Diego Balboa Park and County of San Diego • City of Chula Vista • City of Coronado • City of El Cajon • City of Imperial Beach • City of La Mesa • City of Lemon Grove • City of National City • City of San Diego • City of Santee • County of San Diego Account Executive, Project Coordinator & Business Analyst – Tribes, State, and Transportation • Barona Band of Mission Indians • Campo Band of Mission Indians • Capitan Grande Reservation • Ewiiaapaayp Band of Kumeyaay Indians • Inaja & Cosmit Band of Indians • Jamul Indian Village • Juaneno Band of Mission Indians • Kwaaymii • La Jolla Band of Mission Indians • La Posta Band of Mission Indians • Los Coyotes Band of Mission Indians • Manzanita Band of the Kumeyaay Nation • Mesa Grande Band of Mission Indians • Pala Band of Mission Indians • Pauma Band of Luiseno Indians • Rincon Band of Luiseno Indians • San Luis Rey Band of Mission Indians • San Pasqual Band of Mission Indians • Iipay Nation of Santa Ysabel • Sycuan Band of Kumeyaay Nation • State of California Departments • U.S. Department of Justice • U.S. Fish & Wildlife Service • Viejas Band of Kumeyaay Indians Account Executive, Project Coordinator & Business Analyst – K-12 Schools, Community Colleges, and Universities
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Attachment B Example Agendas
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Semi-Annual Collaborative Planning Workshop 1 December Agenda – The Electric System 1. Introduction 2. Resiliency Tools a. Overview of project engagement guide, data portal, and core dedicated staff to share contact information. 3. Electric Distribution and Transmission System a. Presentation on the two systems. b. Presentation on circuits, as well as explanation of sectionalizing devices c. Introduction/overview of the online map, so jurisdictions can better understand where existing capacity is on the distribution system. 4. Grid Hardening a. Introduction to various grid hardening solutions and how these solutions work together to determine where microgrids may be a better solution than other hardening efforts (covered conductor, installation of sectionalizing devices, undergrounding). b. Overview of planned projects across the region that harden the grid and increase reliability. 5. Reporting on reliability in areas of interest (based on jurisdictions in attendance) 6. Collaborative Planning Breakout session a. Opportunity for stakeholders to discuss concerns and areas of focus. b. Discussion on input from local and tribal governments. 7. Next Steps Semi-Annual Collaborative Planning Workshop 2 June Agenda – Fire Science, Climate Adaptation, and PSPS 1. Introduction 2. Resiliency Tools a. Overview of project engagement guide, data portal and core dedicated staff to share contact information. 3. Overview of Public Safety Power Shutoff events a. Discussion of past events b. Forecast of potential future events 4. Reporting on reliability in areas of interest (based on jurisdictions in attendance) 5. Discussion on grid hardening in PSPS prone areas 6. Collaborative Planning Breakout session a. Opportunity for stakeholders to discuss concerns and areas of focus. b. Discussion on input from local and tribal governments 7. Next Step
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