Comments on Track 3 Scoping Memo

Climate Center & Vote Solar:

• The Commission should consider 3 types of microgrids when considering standby charges:

              1.  Single-customer;

              2.  Multi-customer as a single island mode when grid is down;

              3.  Multi-customer operating on 24/7 basis (this may be a case when a microgrid might be subject to a standby charge).

• The benefits of a microgrid for all customers will outweigh costs.
• Cost of unserved load during recent Texas outage was $6,000/ MWh.
• PSPS policies provide free WF insurance to IOUs and shift costs.

SDG&E:

• CPUC must separate a customer’s fair-share of the utility’s cost of service to customers from value that a microgrid provides to the grid. comprising the microgrid may already be receiving through NEM.
• There is no policy rationale for exempting microgrid customers from standby charges.
• Any benefits provided by a microgrid to the public should be compensated directly through monetized value streams; not indirectly through waivers of charges.

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