Legislation making its way through the process (SB 1088, Dodd) is intended to address wildfire safety relative to the electric grid system. However, it contains elements that do not improve safety and seriously impede the ability of Community Choice agencies and others to implement Distributed Energy Resources (DERs). Find your state rep HERE and send them a brief letter. And whatever you send to your representative, send it to the bill author, Senator Bill Dodd as well: Senator.firstname.lastname@example.org
Here is what to say:
SB 1088 is overall a good, well-intentioned bill that will help with respect to our electrical grid and future wildfire episodes. However, the bill contains elements that do not improve safety and seriously impede the ability of Community Choice agencies and others to implement distributed energy resources such as community solar power, community battery storage and microgrids.
Therefore, I urge you to make the following amendments:
- Remove all of 2899.3 This section effectively prohibits most distributed energy resource (DER) projects occurring today. Such projects include community solar power, community battery storage and microgrids. Liability for DERs is already assigned in the DER contracts that providers have with investor-owned utilities today. There is no unassigned liability. However, to extend potentially unlimited system liability to small-scale local DER projects would serve to end the innovation in that sector and not recognize the investor-owned utility’s existing engineering limitations that serve to protect the system from local DER impacts.
- Modify Section 2899.2(b)(14) to read “Any other element pertaining to electric and gas safety, reliability, or resiliency deemed appropriate by the commission with the option for community choice aggregators to self-provide resources required for reliability as determined by the Commission, consistent with the community choice aggregator’s obligation to comply with resource adequacy requirements pursuant to Public Utilities Code Section 380.” This addition is critical because CCAs are investing in reliability resources today, so CCA customers would be paying twice for reliability services without this amendment. The addition will ensure that double-procurement of reliability resources does not occur in territories served by CCAs.
Thank you for your consideration.
Please refer any questions to woody [at] climateprotection.org