SUBJECT: Southern California Edison Company's Proposed Microgrid Demonstration Project with the United States

Transcription

1 STATE OF CALIFORNIA Edmund G. Brown Jr., Governor PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA June 20, 2017 Advice Letter 3510-E Russell G. Worden Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, CA SUBJECT: Southern California Edison Company's Proposed Microgrid Demonstration Project with the United States Dear Mr. Worden: Advice Letter 3510-E is effective as of June 15, 2017, per Resolution E-4840 Ordering Paragraphs. Sincerely, Edward Randolph Director, Energy Division

2 Russell G. Worden Managing Director, State Regulatory Operations November 16, 2016 ADVICE 3510-E (U 338-E) PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION SUBJECT: Southern California Edison Company s Proposed Microgrid Demonstration Project with the United States Department of Defense Southern California Edison Company ( SCE ) hereby submits for filing the following changes to its tariffs. The revised tariff sheets are listed on Attachment A and are attached hereto. SCE seeks authority from the California Public Utilities Commission ( Commission or CPUC ) to develop and implement a microgrid demonstration project ( Microgrid or Project ) with the United States Department of Defense ( DOD ) at the United States Army National Training Center, Fort Irwin, California ( Fort Irwin or Base ). The Microgrid s installation will be pursuant to a standard Added Facilities Agreement ( AFA ) and is assumed to be permanent. The Microgrid will be evaluated for a period of five (5) years after installation in order to gain knowledge regarding the design, installation, operation, control and management of microgrid systems. SCE s List of Contracts and Deviations tariff is being revised herein as further described below. I. OVERVIEW AND PURPOSE Pursuant to General Order ( G.O. ) 96-B, General Rule Section 8.2.3, SCE shall collaborate with the DOD to develop and implement the Project to support Fort Irwin s energy resilience and renewable energy goals. A. SCE Rule 2, Subsection H Deviation G.O. 96-B, General Rule Section provides, in relevant part, that SCE may provide service (other than resale service) to a government agency for free, or at reduced rates and charges, or under terms and conditions otherwise deviating from its tariffs then in effect. The utility may begin such service without prior Commission approval, but the utility shall P.O. Box Rush Street Rosemead, California (626) Fax (626)

3 ADVICE 3510-E (U 338-E) November 16, 2016 promptly submit an advice letter to the appropriate Industry Division to notify the Commission of the utility s provision of such service and of the rates, charges, terms and conditions under which the service is provided. As explained in Section I.D. below, the equipment SCE intends to install in support of the Project will be at the customer s expense and is comprised of behind-the-meter added facilities as described in, and typically installed under, SCE s Rule 2, Subsection H ( Rule 2.H. ). Notably, the Microgrid s scope of work proposed here does not include any generation. The Microgrid Project proposes to use existing AFA forms and does not entail the establishment of a new rate or fee schedule. However, in an abundance of caution, SCE notes there are two relatively unique aspects of this Project that arguably qualify as a deviation from the standard Rule 2.H. tariff currently in effect. First, the equipment to be installed in support of the Project as added facilities under Rule 2.H. is not unique or novel. As proposed and consistent with Rule 2.H., the Project consists of equipment normally installed by SCE in the development of its electrical transmission and distribution systems and facilities or equipment related to SCE's provision of service to a customer or a customer's receipt or utilization of SCE's electrical energy. However, the term microgrid is not specifically referenced within Rule 2.H. and thus, while the Project s equipment is a typical added facilities offering, its function as part of a microgrid is arguably not. Also novel is the extent of SCE s proposed control of the generation supporting the Microgrid. While Rule 2.H.1. already provides that Added Facilities may include load control devices and meters, here SCE proposes to operate and control the equipment to vary a generator s output for load following, frequency and voltage characteristics when in island mode. 1 SCE proposes to publicly report on its learnings over a five-year period. As such, accompanying the Project, SCE proposes a study program ( Study Program ) in order for SCE and the DOD to gain knowledge regarding the design, installation, operation, control and management of microgrid systems. 1 Island mode or Islanding refers to [a] condition on Distribution Provider s Distribution System [SCE in this case] in which one or more Generating Facilities delivers power to Customers using a portion of Distribution Provider s Distribution System that is electrically isolated from the remainder of the Distribution Provider s Distribution System. See SCE Rule 21 at Sheet 17. As applied with respect to the Microgrid Project here, island mode refers to the operating condition when Distributed Energy Resources (DERs) and interconnected loads act as a single controllable entity without connection to SCE s grid. SCE s control of the generation supporting the Microgrid is described in Section I.D., below.

4 ADVICE 3510-E (U 338-E) November 16, 2016 Thus, SCE seeks the CPUC s approval to expand its normal functions under Rule 2.H. to support SCE s construction of the Microgrid, as well as to control various aspects of the generation connected to the Microgrid when in island mode. 2 B. Fort Irwin Fort Irwin is an Army base located 32 miles east of Barstow in northern San Bernardino County, California. A map of Fort Irwin and the conceptual single line diagram of the proposed Microgrid is included as Attachment B. The Base is entirely located on federal land, under the jurisdiction of the DOD and United States Army. Fort Irwin is within SCE s service territory. The power consumed by Fort Irwin is measured by a single meter. The bill for this meter is paid by Fort Irwin. The Fort Irwin distribution system is owned by SCE via a 2003 Privatization Agreement between SCE and the United States of America. SCE has executed multiple AFAs supporting Fort Irwin. This Advice Letter does not seek to modify any terms of these existing AFAs, but may modify certain equipment covered by existing AFAs in support of the Project s construction. Pursuant to SCE s Rule 2.H. and the terms and conditions of the currently effective AFAs, Fort Irwin pays monthly added facilities charges, and within these fees a portion covers the operation and maintenance of the distribution system. Outages are a significant concern for the Base. Fort Irwin has experienced three major outages exceeding twenty (20) hours over the last five years. Outages from inadvertent man-made damages (e.g., cars striking poles, etc.), natural phenomena (e.g., lightning strikes, flooding, etc.), as well as potential impacts from a major catastrophe and/or terrorist act potentially threaten Fort Irwin s energy resilience and mission-critical activities. 2 Any additional costs to exercise such control are expected to be de minimis and thus captured by the operations and maintenance fees already authorized that Fort Irwin will be responsible for under the AFA associated with the Project.

5 ADVICE 3510-E (U 338-E) November 16, 2016 C. The DOD s Energy Resilience and Renewable Energy Goals The DOD has an established objective to enhance resilience at its bases. 3 Specifically, the DOD s Office of the Assistant Secretary of Defense, Energy, Installations, and Environment is leading energy resilience initiatives to help ensure that the DOD has the ability to prepare for and recover from energy disruptions that impact mission assurance on military installations. 4 The DOD believes energy resilience encourages the necessary planning and capabilities to ensure available, reliable, and quality power to continuously accomplish DOD missions and as such, the DOD continues to pursue a number of initiatives to enhance the energy resilience of its military installations. 5 To further these initiatives, the DOD engages in partnerships with various stakeholders, including other federal agencies as well as the private sector. 6 DOD sees its collaboration with local utility providers, such as SCE, as critical to enhance resilience and rapidly restore the commercial electric grid in the event of an outage or failure requiring substantial down time for repairs. 7 In addition to reducing facility energy demand, the DOD seeks to increase the supply of renewable and other forms of distributed (onsite) energy installations. 8 In so doing, 3 See Office of the Assistant Secretary of Defense for Energy, Installations, and Environment Installation Energy (IE), Energy Resilience Initiatives website, available at Castillo, Ariel S., Ph.D., Energy Exchange, Federal Sustainability for the Next Decade, DOD Energy Resilience, Energy Resilience Policy (Aug. 9, 2016), available at %20Energy%20Resilience%20Policy%20Track%202.pdf ; Hammack, Katherine, Assistant Secretary of the Army, Achieving resiliency through energy security and sustainability, U.S. Army Online Publication, Installations, Energy and Environment (Oct. 2, 2015), available at Castillo, Ariel S., Ph.D., Energy Exchange, Federal Sustainability for the Next Decade, DOD Energy Resilience Initiatives, Operational Resilience and Recovery (Sept. 10, 2015), available at %20Castillo%20DOD%20Energy%20Resilience%20Overview_Aug% pdf; see also American Council on Renewable Energy (ACORE), Renewable Energy for Military Installations: 2014 Industry Review (Feb. 2014), available at 4 See Office of the Assistant Secretary of Defense for Energy, Installations, and Environment Installation Energy (IE), Energy Resilience Initiatives website, available at 5 See id. 6 See id. 7 See id. (engaging with stakeholders) 8 See Office of the Assistant Secretary of Defense for Energy, Installations, and Environment Installation Energy (IE), Renewable Energy website, available at

6 ADVICE 3510-E (U 338-E) November 16, 2016 the DOD actively considers not only the cost-effectiveness of renewable and distributed energy solutions, but also the energy resilience benefits [those energy solutions] could provide to [DOD] installations. 9 In August 2016, the DOD made various recommendations to enhance energy resilience and encourage cost-effective solutions that improve mission readiness, including the planning of large and small scale microgrids and so-called smart grids. 10 SCE s proposed construction of the Microgrid at Fort Irwin has been endorsed by the DOD and Fort Irwin Command as serving the DOD s energy resilience objectives discussed above. (A copy of a letter of support for the Microgrid from the Fort Irwin Command is appended hereto as Attachment C). D. The Proposed Microgrid Demonstration Project The Project s technical design will support the DOD s energy resilience and renewable energy objectives referenced above. The Project is estimated to be constructed and placed in service in the 4th quarter of Components of the proposed Microgrid infrastructure include: Switching equipment and field devices to enable transitioning to and from island mode ; Communications infrastructure including remote terminal units and cabling for the transmission of monitoring and control signals; Protection devices to avoid damage to the distribution system feeders, conduit, poles, vaults, panels, etc. that will distribute electricity to Base facilities; Protection equipment including relays, circuit breakers and fuses; and Controllers, associated devices and software to monitor and regulate the operation of the Microgrid and supporting generation when in island mode. A simplified, conceptual single-line diagram of the proposed Project is appended hereto as part of Attachment B. This diagram is subject to change pending future design discussions between SCE and Fort Irwin. All of the Microgrid infrastructure components listed in the bullets above will be installed on the customer s side of the meter under the provisions of Rule 2.H. (Added Facilities). 11 By this Advice Letter and as described in Section I.A. above, SCE seeks 9 See id. 10 See Castillo, Ariel S., Ph.D., Energy Exchange, Federal Sustainability for the Next Decade, DOD Energy Resilience, Planning Microgrids and Smart Grids (Aug. 9, 2016), available at %20Energy%20Resilience%20Policy%20Track%202.pdf. 11 SCE Tariff Rule 2, Section H ( Added Facilities ) states, in relevant part, that [w]here an applicant requests and SCE agrees to install facilities which are in addition to, or in substitution for the standard facilities SCE would normally install, the costs thereof shall be borne by the applicant. Such costs shall include continuing ownership costs as may be applicable. Unless otherwise provided by SCE's filed tariff schedules, these added facilities

7 ADVICE 3510-E (U 338-E) November 16, 2016 authority to deviate from SCE s traditional scope of work pursued under Rule 2.H. in order to construct the Microgrid and control its supporting generation when in island mode. In support of this Project, SCE intends to use Added Facilities to monitor and control the variations of the generators outputs. SCE s load control devices typically disconnect customers generation during system abnormalities or for maintenance. Here however, in order to (among other things) protect SCE s distribution system assets, SCE requires more sophisticated controls than would normally be employed. For example, control of the generation will include varying generator output for load following, frequency and voltage characteristics. The Microgrid will serve Fort Irwin s critical load needs including its headquarters, training facilities, communications and data recording operations, and health and safety facilities. SCE s distribution infrastructure is also installed on the customer s side of the meter. SCE owns and operates these distribution facilities via the 2003 Privatization Agreement executed between SCE and the United States of America. 12 The Microgrid will connect to SCE s existing distribution system currently serving Fort Irwin. This Project proposes to support the electrical needs of the Base during grid outages lasting up to thirty (30) days. With respect to generation, the Microgrid is anticipated to be powered by various existing DERs provided by Fort Irwin or other third-party generator/developers. 13 (special facilities) will be installed, owned and maintained or allocated by SCE solely as an accommodation to the applicant Added Facilities may include, but are not limited to, all types of equipment normally installed by SCE in the development of its electrical transmission and distribution systems and facilities or equipment related to SCE's provision of service to a customer or a customer's receipt or utilization of SCE's electrical energy. Added Facilities also include the differential costs for equipment for electrical transmission and distribution systems designed by SCE which, in SCE's sole opinion, is in excess of equipment required for SCE's standard serving system. Added Facilities may include poles, lines, structures, fixtures, transformers, service connections, load control devices and meters. See SCE Rule 2 at Sheets See SCE Advice Letter 3100-E, Deviation to SCE's Added Facilities Agreement - Applicant Financed (Form ) for Fort Irwin (Oct. 9, 2014), available at: 13 SCE notes that in direct support of the 2014 Energy Storage Mandate, SCE s Energy Storage Integration Program ( ESIP ) intends to install approximately 10 energy storage units or batteries throughout SCE s service territory. See Southern California Edison Company (U 338-E), 2018 General Rate Case, SCE-02 T&D-Vol. 11 Grid Technology (Sept., 1, 2016), available at y=2018%20grc&start=26&count=25. SCE anticipates that Fort Irwin will host one of these batteries, with an expected capacity of 5 MWh. SCE anticipates that the Fort Irwin ESIP

8 ADVICE 3510-E (U 338-E) November 16, 2016 Additional, emissions-compliant fossil fuel generation may be required when on-site renewable generation is unavailable or insufficient to power critical loads during Microgrid islanding. The development and construction of such generation is outside the scope of the Project for which this Advice Letter seeks approval. In general, however, the Microgrid s operating scheme will prioritize the use of renewable generation, consistent with the DOD energy resilience and renewable energy goals and policies. E. Roles and Responsibilities While construction and control of the Microgrid infrastructure outlined above will be SCE s responsibility, the development of any additional generation supporting the energy and protection input (fault duty) requirements is the responsibility of the DOD and Fort Irwin. In addition to the anticipated installation of a five (5) MWh battery as part of SCE s ESIP, 14 all on-site generation supporting the Microgrid is anticipated to be installed, owned and maintained by either Fort Irwin or other third-party pursuant to the applicable interconnection tariffs and agreements (e.g., SCE Rule 21). SCE is not proposing to own any on-site generation required for the operation of the Microgrid. A new AFA will be executed between SCE and Fort Irwin in support of the Microgrid s construction. SCE will control the Microgrid during island mode in order to help ensure the Microgrid s safe and reliable operation, as well as to support the integrity of SCE s existing distribution infrastructure. Consistent with Rule 2.H., SCE will not be liable for any loss, damage, or injury arising from SCE s installation, operation, maintenance, or control of the Microgrid. 15 The Microgrid is expected to be engaged on an as-needed basis. Routine testing of the Microgrid is anticipated on a schedule which will be determined collaboratively between Fort Irwin and SCE. Appropriate communications protocols will be established between Fort Irwin and SCE to allow SCE to effectively manage and control the operation of the Microgrid once engaged. SCE will comply with all applicable environmental regulations in support of the Project s construction and operation. It is anticipated that any approvals and supporting environmental documentation in support of the Microgrid Project will be the responsibility of the DOD, which acts as its own lead agency for purposes of complying with the National Environmental Policy Act ( NEPA ). The requirements of the California Environmental Quality Act ( CEQA ) are not applicable to SCE s Microgrid Project given that all work will occur on lands within the jurisdiction of the Federal Government. Installation of the Microgrid components do not require a Certificate of Public Convenience and Necessity ( CPCN ) or Permit to Construct ( PTC ) under Commission G.O. 131-D. Any permitting and/or subsequent environmental documentation for any generation needed in support of the Microgrid are anticipated to storage device will be installed in 2018 and will interconnect with the Microgrid. SCE will be responsible for the installation and maintenance of this battery. 14 See id. 15 SCE Tariff Rule 2.H.3 (describing limitation of SCE liability for added facilities).

9 ADVICE 3510-E (U 338-E) November 16, 2016 be the responsibility of the DOD, Fort Irwin and/or the developers of such generation, as may be appropriate. II. SCE S STUDY PROGRAM The Microgrid s installation and operation offers an important opportunity for SCE to gain knowledge about the design, installation, operation, control and management of microgrid systems. Through this Advice Letter filing, SCE proposes to initiate the Study Program for the Microgrid, and in particular SCE s installation, maintenance, and islanded control of same. SCE s Study Program has many objectives, including: Gaining knowledge about the design, installation, operation, control and management of microgrid systems; Studying the role of the utility, if any, in the provision of microgrid services, including installation as added facilities, control, and when such services are appropriate; Determining the time, effort and costs involved in facilitating the proper maintenance and control of microgrids; Gauging the extent to which microgrids may facilitate the energy resilience and renewable energy goals of the DOD; Gauging the extent to which microgrids may be replicated and scalable (possibly with modifications) to develop potential energy resilience and renewable energy solutions for other DOD facilities and/or other retail customers; Improving knowledge regarding the scope and mix of energy resources required to support the microgrid, including the extent to which on-site renewable generation may reliably support load requirements; Studying the interaction between energy storage 16 and microgrid systems if possible, and developing best practices for the implementation and operation of such systems; Demonstrating the technical viability of microgrid technology; and, Exploring the role that added facilities installed under Rule 2.H. may play in enabling the modern electricity grid. DOD-specific study objectives include gauging the extent to which microgrids may facilitate the energy resilience and renewable energy goals of the DOD, and specifically: Whether microgrid technologies are capable of serving all mission-critical loads in the event of a loss of grid power; Gauging the extent to which the DOD may reduce electric consumption through deploying the microgrid systems; Gauging the extent to which microgrid systems may manifest cost savings; and Gauging the extent that renewable generation can support microgrids during islanding. 16 See footnote 13, supra (referencing SCE s proposed installation of a 5 MWh battery via the ESIP).

10 ADVICE 3510-E (U 338-E) November 16, 2016 Such knowledge will enable SCE to advance its grid modernization efforts in order to better support customer choice regarding emerging technologies and the manner in which such technologies interact with the grid. Such knowledge will also allow SCE and the DOD to critically evaluate the effect microgrids may have in advancing DOD objectives concerning energy resilience and renewable energy. SCE is amenable to working collaboratively with the DOD (including its contractors) to prepare a report on its findings after one, three and five years of operating the Microgrid. III. RATEMAKING TREATMENT; IMPACT OF DEMONSTRATION PROJECT ON NON-PARTICIPATING CUSTOMERS The Microgrid infrastructure will be installed as Added Facilities under Rule 2.H. As described in Section I.A. above, while the SCE equipment supporting this Project fits within the added facilities governed by Rule 2.H., the collective function of this equipment as a microgrid and control of the generation is relatively unique and warrants SCE s request for authority pursuant to this Advice Letter. Under the terms of Rule 2.H., the costs for the installation, operation, and maintenance of the Microgrid infrastructure will be the responsibility of the DOD. As mentioned above, SCE will also control the Microgrid s operation when Fort Irwin is in island mode. SCE currently anticipates that Fort Irwin will operate in island mode approximately thirty-five (35) hours per year (approximately 0.4 % of the time). 17 SCE does not anticipate employing additional resources in support of this control function. As such, SCE expects any control operation costs to be de minimis. These, as well as other operations and maintenance costs will be paid by the DOD/Fort Irwin directly as part of SCE s routine billing for electricity service as additional Added Facilities line items on the customer s bill pursuant to the terms of the AFA. As part of the Study Program, SCE intends to observe the incremental time, effort and costs (if any) involved in facilitating the proper maintenance and control of the Microgrid. Given the as yet unknown costs of SCE s control of the Microgrid and the expectation that they would be de minimis for this Project, SCE is not proposing to impose a separate charge to DOD/Fort Irwin for this activity. Rather, SCE anticipates that any such operation and maintenance costs associated with SCE s control of the Microgrid will be negligible and covered within the added facilities charges imposed pursuant to the anticipated AFA for the Microgrid Project. Depending on the findings of SCE s Study Program, SCE reserves the right to seek additional cost recovery from the DOD/Fort Irwin associated with the Microgrid s control This estimate is based on the time Fort Irwin actually experienced outages over the past five years. Notably, such an estimate does not include routine outages engaged for testing purposes, so the effective number of outage hours at the Base may exceed 35. Given the uncertain nature of predicting future outages, this number may under- or over-predict the number of hours and/or frequency with which the Microgrid will be engaged. 18 SCE s customers will also presumably benefit from SCE s learnings regarding the potential integration of microgrids in SCE s utility infrastructure, as well as any energy resilience benefits they may bring.

11 ADVICE 3510-E (U 338-E) November 16, 2016 Except as noted above, this Advice Letter will not increase any rate or charge to nonparticipating customers, nor will it cause the withdrawal of service. IV. PROPOSED SCHEDULE A preliminary schedule of activities for the Demonstration Project and Study Program are presented below: Regulatory Approval 11/ /2017 Final Design 03/ /2018 Site & Environmental Permitting 04/ /2018 Procure Equipment 01/ /2018 Microgrid Construction and Commissioning 10/ /2019 Microgrid Operational 10/ /2019 Study Program 01/ /2025 V. PROPOSED TARIFF CHANGES SCE s List of Contracts and Deviations is updated to reflect the Rule 2.H. deviation discussed above for Fort Irwin. The revised tariff sheets are listed within Attachment A hereto. VI. MISCELLANEOUS A. Tier Designation Pursuant to GO 96-B, Energy Industry Rule 5.3(8), this Advice Letter is submitted with a Tier 3 designation. B. Effective Date Pursuant to GO 96-B, General Rule 8.2.3, this advice filing is effective pending disposition. 19 C. Cost No cost information is required for this advice filing. 19 See G.O. 96-B, General Rule Section ( At all times, a utility other than a telephone corporation may provide service (other than resale service) to a government agency for free, or at reduced rates and charges, or under terms and conditions otherwise deviating from its tariffs then in effect. The utility may begin such service without prior Commission approval, but the utility shall promptly submit an advice letter to the appropriate Industry Division to notify the Commission of the utility s provision of such service and of the rates, charges, terms and conditions under which the service is provided. Although the advice letter may be effective pending disposition under General Rule 7.5.3, the Commission may determine, in an appropriate proceeding, the reasonableness of such service. ).

12 ADVICE 3510-E (U 338-E) November 16, 2016 D. Safety The Microgrid s installation will be pursuant to a standard AFA. The Microgrid is expected to be constructed, operated, and maintained consistent with the AFA s terms and in a manner at least as safe as other added facilities installed pursuant to Rule 2.H. Consistent with Rule 2.H., SCE will not be liable for any loss, damage, or injury arising from SCE s installation, operation, maintenance, or control of the Microgrid. The Microgrid s installation may have ancillary safety benefits for Fort Irwin residents and staff in that it is expected to improve the reliable provision of electricity to Fort Irwin, including the Base s headquarters, training, and health and safety facilities. E. Notice Anyone wishing to protest this advice filing may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice filing. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this Advice Letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Telephone: (626) Facsimile: (626) AdviceTariffManager@sce.com Michael R. Hoover Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415) Karyn.Gansecki@sce.com

13 ADVICE 3510-E (U 338-E) November 16, 2016 There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B, R , R and A service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) For changes to all other service lists, please contact the Commission s Process Office at (415) or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by filing and keeping the advice filing at SCE s corporate headquarters. To view other SCE advice letters filed with the Commission, log on to SCE s web site at For questions, please contact Kathy G. Wong at (626) or by electronic mail at Kathy.Wong@sce.com. Southern California Edison Company RGW:kgw:cm Enclosures /s/ Russell G. Worden Russell G. Worden

14 CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/cpuc Utility No.: Southern California Edison Company (U 338-E) Utility type: Contact Person: Darrah Morgan ELC GAS Phone #: (626) PLC HEAT WATER Disposition Notice to: EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water (Date Filed/ Received Stamp by CPUC) Advice Letter (AL) #: 3510-E Tier Designation: 3 Subject of AL: Southern California Edison Company s Proposed Microgrid Demonstration Project with the United States Department of Defense Keywords (choose from CPUC listing): AL filing type: Monthly Quarterly Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information: Resolution Required? Yes No Requested effective date: 11/16/16 No. of tariff sheets: -3- Estimated system annual revenue effect: (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: Service affected and changes proposed 2 : List of Contracts and Deviations Pending advice letters that revise the same tariff sheets: N/A 2 Discuss in AL if more space is needed.

15 Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Telephone: (626) Facsimile: (626) Michael R. Hoover Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415)

16 Public Utilities Commission 3510-E Attachment A Cal. P.U.C. Sheet No. Title of Sheet Cancelling Cal. P.U.C. Sheet No. Revised E List of Contracts & Deviations Revised E Revised E Table of Contents Revised E Revised E Table of Contents Revised E 1

17 Southern California Edison Revised Cal. PUC Sheet No E Rosemead, California (U 338-E) Cancelling Revised Cal. PUC Sheet No E List of Contracts and Deviations Sheet 15 (Continued) Name and Location of Customer RULES - OTHERS (Continued) Type or Class of Service Execution and Expiration Dates Commission Authorization Number and Date Most Comparable Regular Tariff Schedule No. Contract Difference Standard Oil Western Operations, Inc., El Segundo General 11/01/75 Termination of service Res. E /10/76 Rule 12.E Parallel Operation Veterans Admn. Of the United States, Loma Linda General 11/05/76 Until terminated by either party with 12 months notice Res. E /01/77 Rule 12.E Momentary paralleling Veterans Admn. Of the United States, Wadsworth General 07/11/78 Ten yrs. from date service first rendered G.O. 96-A-X-B 03/06/81 Rule 12.E Momentary paralleling Kern River Cogeneration Co. Kern County near Bakersfield, California General 01/16/84 20 years or until terminated by either party, whichever comes first Res. E-1999, Advice 645-E 03/07/84 None Cogeneration facility located within PG&E service territory Rockwell International, Seal Beach California General 06/11/87 90 days notice Res. E-3093, Advice 784-E 05/25/88 Rule 12 & Sched. I-5 Momentary paralleling Xerox Corporation El Segundo, California General 09/17/87 90 days notice Res. E-3092, Advice 785-E 05/25/88 Rule 12 & Sched I-5 Momentary paralleling Claremont Colleges Claremont, California General 06/09/88 90 days notice Res. E-3109, Advice 802-E 10/14/88 Rule 12 & Sched I-3 Parallel generation Calif. State Univ. Channel Islands, Camarillo, California General 06/15/06 Dec. 31, 2011 Res. E-4482, Advice 2565-E 03/08/12 Rule 9 & Rule 16 Use of multiple meters DCOR, LLC Huntington Beach, California General ---- Until terminated Res. E-4238, Advice 2313-E 04/16/09 Rule 18 DCOR, LLC may submeter and bill Pacific Resources, LTD U.S. Department of Defense Fort Irwin, CA General 11/16/16 Until terminated G.O. 96-B Advice 3510-E Rule 2.H Use of Added Facilities in Microgrid to Control Generation during Islanded State (N) (N) (Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 3510-E Caroline Choi Date Filed Nov 16, 2016 Decision Senior Vice President Effective Jun 15, C11 Resolution E-4840

18 Southern California Edison Revised Cal. PUC Sheet No E Rosemead, California (U 338-E) Cancelling Revised Cal. PUC Sheet No E TABLE OF CONTENTS Sheet 1 Cal. P.U.C. Sheet No. TITLE PAGE E TABLE OF CONTENTS - RATE SCHEDULES E E TABLE OF CONTENTS - LIST OF CONTRACTS AND DEVIATIONS E TABLE OF CONTENTS - RULES E TABLE OF CONTENTS-INDEX OF COMMUNITIES, MAPS, BOUNDARY DESCRIPTIONS E TABLE OF CONTENTS - SAMPLE FORMS E E (T) (T) PRELIMINARY STATEMENT: A. Territory Served E B. Description of Service E C. Procedure to Obtain Service E D. Establishment of Credit and Deposits E E. General E F. Symbols E G. Gross Revenue Sharing Mechanism E E H. Baseline Service E I. Not In Use... -E J. Not In Use... -E K. Nuclear Decommissioning Adjustment Mechanism E L. Purchase Agreement Administrative Costs Balancing Account E M. Income Tax Component of Contributions E N. Memorandum Accounts E E E E E E E E O. California Alternate Rates for Energy (CARE) Adjustment Clause E E P. Optional Pricing Adjustment Clause (OPAC) E (Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 3510-E Caroline Choi Date Filed Nov 16, 2016 Decision Senior Vice President Effective Jun 15, H8 Resolution E-4840

19 Southern California Edison Revised Cal. PUC Sheet No E Rosemead, California (U 338-E) Cancelling Revised Cal. PUC Sheet No E TABLE OF CONTENTS Sheet 9 (Continued) RATE SCHEDULES (Continued) Schedule Cal. P.U.C. No. Title of Sheet Sheet No. OTHER (Continued) GTSR-CR-PDT Green Tariff Shared Renewables Community Renewables Project Development Tariff E E GTSR-GR Green Tariff Shared Renewables Green Rate E E GSN Envest SCE Equipment Service E ME Maritime Entities At The Port Of Long Beach E NEM E Net Energy Metering E E E NEM-V Virtual Net Energy Metering for Multi-Tenant and Multi-Meter Properties E E NMDL New Municipal Departing Load E E OBF On-Bill Financing Program E OBF-2 On-Bill Financing Program E OBMC Optional Binding Mandatory Curtailment E OBR On-Bill Repayment Pilot Program E E PC-TBS Procurement Charge Transitional Bundled Service E PCT Programmable Communicating Thermostat E PVS Experimental Photovoltaic Service E PVS-2 On-Grid Photovoltaic Service E RES-BCT Renewable Energy Self-Generation Bill Credit Transfer E E Re-MAT Renewable Market Adjusting Tariff E E RF-E Surcharge to Fund Public Utilities Commission Reimbursement Fee E S Standby 500 kw and Below E E SC Service Connection Charge E SLRP Scheduled Load Reduction Program E E SPSS Station Power Self-Supply E TMDL Transferred Municipal Departing Load E E UCLT Utility-Controlled Load Tests E V2G PILOT WATER WI-FI-1 WTR SCE Vehicle To Grid Experimental Pilot E Water Agency Tariff for Eligible Renewables E Schedule WI-FI Pilot Wireless Fidelity Rate E Wireless Technology Rate E LIST OF CONTRACTS AND DEVIATIONS LIST OF CONTRACTS AND DEVIATIONS E E E (T) (Continued) (To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 3510-E Caroline Choi Date Filed Nov 16, 2016 Decision Senior Vice President Effective Jun 15, H8 Resolution E-4840

20 ATTACHMENT B Map of Fort Irwin and a single line diagram of the proposed Microgrid

21 Legend NonMicrogrid Circuitry Microgrid Circuitry Substation 1 Renewable Generator 1 G Renewable Generator 2 G Substation 2 Critical Facility 1 Renewable Generator 3 Various Non-critical Facilities G New synchronous generation for microgrid support New energy storage for microgrid support Substation 3 ES G Various Critical Facilities

22 ATTACHMENT C Letter of support for the Microgrid from the Fort Irwin Command

23