Wholesale DG Working Group,

Attached is a filing made today by SCE, SDG&E and PG&E in the SEIA rulemaking proceeding at FERC regarding small generator interconnection reforms. The 3 IOUs attempt to distinguish the proposal in the SEIA Petition from the recently agreed to California Rule 21 settlement. There are significant differences between the SEIA and California settlement proposals. However, the 3 IOUs see inconsistency where there is none, going so far as to ignore the following statement in SEIA’s previously filed answer which is as follows:

Any reference to the 100% of minimum daytime load supplemental screen in this answer should be read to include the California settlement penetration test as well as the power quality & voltage fluctuation, safety and reliability screens. The 100% daytime load screen combined with these additional screens is at the heart of the SEIA proposal, provided the process is well defined and transparent from the solar developer perspective. Moreover, as stated repeatedly in the Petition, SEIA is not proposing to eliminate the 15% screen

Regardless of this clarification, the 3 IOUs insist inaccurately that SEIA’s daytime load screen is different from the California settlement and that SEIA is trying to eliminate the 15% screen.

I may seek to further clarify, although what the IOUs are doing is quite transparent and FERC staff will likely see through it.

Have a great weekend.

Dan