Reply Comments on Track 3 Scoping Memo

SDG&E:

• Agrees with PG&E and others- compensation mechanism of microgrids should not be addressed through standby charges.
• Standby changes reflect long-term planning; resiliency is a need that is immediate and sporadic in nature.
• No one has provided evidence or logic supporting waiver of standby charges.
• SB 1339 states “reduce” barriers to microgrids- not “eliminate.”

SCE:

• Standby charges are rooted in cost causation principles and are designed to recoup the customer’s fair share of utility costs.
• Under no circumstances should the Commission waive standby charges, however small they may be for some customers.

CalAdvocates:

• A standby charge waiver is not appropriate tool to compensate avoided capacity provided by non-renewable resources.
• D. 01-07-027 provides path for standby waivers for non-renewable resources based on “physical assurance” AND the customer agreeing to drop their load proportionally when needed.

Microgrid Resources Coalition:

• Notion of cost-shifting is being wielded to avoid review of whether current charges are poorly justified.
• Allow standby charge waivers - the charge is outdated and not in line with causation.