This entry covers CLECA’s filings in CPUC proceeding A.24-11-007, on PG&E’s proposed Electric Rule 30 for transmission-level retail electric service. The excerpts below are drawn from CLECA’s Limited Opening Brief, Reply Brief, and Comments Contesting a Portion of the Partial Settlement Agreement.
Rule 30’s risk provisions were built for speculative data center load
CLECA argues that Rule 30’s heightened requirements were designed for large, speculative data center requests and should be applied only to that load.
If adopted, PG&E's proposed Rule 30 risk mitigation provisions, which were designed to target large, speculative data center loads, should be narrowly applied to target such large, speculative data center loads rather than being broadly applied to Decarbonizing and EITE Existing Customers that do not possess the same risk characteristics.
PG&E has failed to meet its burden to justify its proposed application of Rule 30's heightened risk-mitigation provisions to all transmission-level customers.
Existing decarbonizing and EITE customers do not present the same risks
CLECA contends that existing customers adding load to decarbonize or expand operations lack the risk profile the rule was meant to address, and that California policy encourages their growth.
These customers do not present risks of speculative load growth or early departure sufficient to justify Rule 30's enhanced minimum demand charges (MDCs), extended contacted terms, or early contract termination fees.
California has a vested policy interest in Decarbonizing and EITE Existing Customers load increases … to decarbonize manufacturing processes, including through electrification, adding electric vehicle charging.
The revised minimum demand charge is punitive to existing customers
CLECA objects that PG&E’s revised 75 percent minimum demand charge penalizes normal industrial operations rather than mitigating speculative-load risk.
PG&E's revised 75% MDC from year 1, based on a binding load ramp, is especially punitive to and counterproductive for existing industrial and manufacturing (Decarbonizing and EITE Existing) customers.
Applying a 75 percent minimum demand charge to those normal operating conditions would penalize existing customers for ordinary business and safety-related fluctuations, not protect ratepayers from speculative load risk.
Existing exceptional-case procedures should remain available
CLECA asks that decarbonizing and EITE existing customers keep the option to interconnect under longstanding procedures instead of accepting data center-driven obligations.
Decarbonizing and EITE Existing Customers should be allowed to continue seeking incremental transmission-level service under existing exceptional case filing and negotiated agreement procedures.
But if the Commission declines to exempt these customers from Rule 30's heightened provisions, it should, at minimum, preserve their ability to proceed under existing procedures rather than requiring them to accept data center-driven obligations that PG&E has not justified applying to them.
Confidential customer data cannot be disclosed without a legal basis
In its settlement comments, CLECA argues that the partial settlement would release protected customer-specific data in violation of Public Utilities Code section 8380.
Public Utilities Code section 8380 and the Commission's implementing decisions restrict disclosure of such customer-specific energy data absent customer consent, express legal … authorization, or aggregation sufficient to prevent re-identification.
It would authorize disclosure of protected customer-specific information without customer consent, without aggregation or anonymization, and without any identified legal basis for Sierra Club's access.
CLECA’s objection to the settlement is narrow
CLECA supports appropriately tailored information-sharing and opposes only the provisions granting Sierra Club access to confidential interconnection data.
CLECA does not oppose the Partial Settlement as a whole, and recognizes that appropriately tailored reporting and information-sharing requirements can advance legitimate objectives within the scope of this proceeding.
The Joint Motion does not demonstrate that providing Sierra Club with ongoing access to sensitive, customer-specific interconnection information advances either of those purposes; indeed, it cannot, as Sierra Club is not a load-serving entity.
Read the filings
The excerpts above are drawn from CLECA’s filings in this proceeding. Read the complete documents: