Reply Comments on Track 3 Scoping Memo

SDG&E:

• Commission should dismiss any further discussion of waivers- parties fail to show equity of exemption of standby charges.
• Resiliency & Microgrids WG should examine the value of resiliency.
• False for parties to assert POLR obligations are negated by PSPS.

SEIA/Vote Solar:

• Question of standby charges should focus on customers who are currently subject to standby charges.
• Commission should articulate cost causation for standby charges as distinct from departing load or other types of charges.
• Consider payment of standby charge to microgrid customers who have resources that can be made available to remove load from the grid in response to IOU signal and thereby reduce or avoid rotating outages.