SDG&E Response to PRR 983 Interconnection Financial Security

SDG&E Response to PRR 983 – Interconnection Financial Security

Section 8

SDG&E is not in favor of adding invoicing to the Interconnection Financial Security (“IFS”) posting process.

Currently, approximately one month before the first and second IFS postings are due, the CAISO emails a summary to Interconnection Customers (“ICs”) detailing the requirement for the IFS. The summary contains information about the IFS for Participating TO’s Interconnection Facilities and Network Upgrades. The current format is acceptable for the first IFS.

SDG&E believes that it would beneficial to include additional information for the second IFS to provide clarity. SDG&E supportsthe addition of two lines for each of the IFS postings amount. One line would specify the amount the IC previously posted with the Participating TO and the second line would specify the additional amount due to meet the requirement for the second IFS.

SDG&E believes that similar information to what is proposed to be provided for the second posting could be provided for the third IFS posting specified in the GIA.

As a courtesy, SDG&E has provided invoices to ICs, based solely on the request of the IC. SDG&E would prefer to maintain this as a courtesy, rather than it being a requirement.

SDG&E believes the ICs have “sufficient time to provide the required security” since IFS is a topic during the Results Meetings and the amounts and due date for IFS are listed in the meeting minutes.

Section 8.5

SDG&E objects to the proposed language.

The estimates for the cost of the upgrades and time to construct the upgrades presented in the interconnection studies include appropriate governmental approvals, if applicable. Permitting and other Pre-Construction Activities are required before Construction Activities may commence. The IC must provide written authorization to proceed and post the third IFS BEFORE the Participating TO will pursue Pre-Construction Activities. If it is expected that obtaining governmental approvals will be a lengthy process, the GIA could specify a separate timeline and IFS posting for the Pre-Construction Activities and the Construction Activities. After written authorization to proceed and the third IFS posting is received, the IC should be meeting regularly with the Participating TO so there should be open lines of communication.