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Mail # 70118 Part 3 : SB_GT&S_0444533.pdf

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Date:
Monday, 15 September 2014 15:50
Sender:
PG&E Tarif...:3/3
Recipient:
'EDTariffU...:3/3
Subject:
Joint Util...:3/3
Total file(s): 3

SB_GT&S_0444531.pdf
SB_GT&S_0444532.pdf
SB_GT&S_0444533.pdf
Content:

---------------------Page 1---------------------
PtwiUv &>; ,?m!
ElecUc Company*
Meredith Allen Pacific Gas and Electric Company
Senior Director 77 Beale St., Mail Code B10C
Regulatory Relations P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-7226
September 15, 2014
Energy Division Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Subject: Pacific Gas and Electric Company, Southern California Edison
Company, and San Diego Gas & Electric Company's Comments to
Draft Resolution E-4677 Approving the 21st Century Energy Systems
Research and Development Projects and Cooperative Agreement
(PG&E Advice 4402-E, SCE Advice 3030-E, and SDG&E Advice 2592-E
(Joint Utilities AL))
Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E), Southern California Edison Company
(SCE), and San Diego Gas & Electric Company (SDG&E), collectively known as the
Joint Utilities, respectfully submit its comments on Draft Resolution E-4677 (Draft
Resolution), which approves the proposed California Energy Systems for the 21st
Century (CES-21) projects, budgets, and cooperative research and development
agreement (CRADA), subject to a compliance filing incorporating modifications
identified in the Draft Resolution.
The cyber security and grid integration business cases presented in the Joint Utilities AL
sufficiently describe the proposed work to be completed. At the same time, in light of
the Office of Ratepayer Advocates' (ORA's) protest and the consensus meeting
convened by California Public Utilities Commission (Commission) Staff, the Joint
Utilities generally support the recommendations outlined in the Draft Resolution to
amend these business cases with additional project specific information.
The Joint Utilities request that the Commission clarify that the compliance filing required
by Ordering Paragraphs 2, 3, and 4 be filed within 5 business days of the approval of
the Resolution.
For the cyber security project, the Joint Utilities request that the Draft Resolution be
modified to specify that when a critical pathway is being contemplated to change or be
nullified, the Joint Utilities notify the Director of Energy Division, or the Director's
designee, via a letter and not an advice filing.
SB GT&S 0444533
---------------------Page 2---------------------
Joint Utilities' Comments on -2- September 15, 2014
Draft Resolution E-4677
In order to make the most efficient use of Commission Staff's time, the Joint Utilities
propose to provide a transportable "reading room" at the Commission's San Francisco
office. The Joint Utilities will make confidential documents concerning status updates of
the cyber security project available for designated Commission staff to read and
review.1
Lastly, the Joint Utilities request that Southern California Edison Company's advice
letter number referenced at the bottom of page 1 of the Draft Resolution be corrected
from "4040-E" to "3030-E" in the final resolution.
The Joint Utilities commend the Commission on a well-balanced Draft Resolution and
support the timely approval of Resolution E-4677.
Sincerely,
/S/
Meredith Allen
Senior Director, Regulatory Relations
cc: President Michael R. Peevey
Commissioner Michel P. Florio
Commissioner Carla J. Peterman
Commissioner Michael Picker
Commissioner Catherine J.K. Sandoval
Karen V. Clopton, Acting General Counsel
Timothy J. Sullivan, Acting Chief Administrative Law Judge
Edward Randolph, Director, Energy Division
Energy Division Tariff Unit
Damon Franz, Energy Division, CPUC
Maria Sotero, Energy Division, CPUC
Service Lists: A. 11-07-008 and R. 13-12-010
Chloe Lukins, ORA
Megan Caulson, SDG&E
Megan Scott-Kakures, SCE
Leslie E. Starck, SCE
1 Due to the confidential nature of cyber security documents, designated Commission staff will
not be allowed to remove documents from the reading room, nor will pictures be allowed.
SB GT&S 0444534

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