PACIFIC GAS AND ELECTRIC COMPANY
Electric Rule 30 – Transmission-Level Interconnections
Application 24-11-007
Data Response
PG&E Data Request No.: JointCCAs_001-Q007
PG&E File Name: ElectricRule30-Transmission-LevelInterconnections_DR_JointCCAs_001-Q007 Request Date: January 23, 2025
Requester DR No.: 001
Requesting Party: JointCCAs
Requester: Scott Blaising
Date Sent: January 29, 2025
PG&E Witness(es): Ben Moffat – Engineering, Planning and Strategy QUESTION 007
In D.22-11-009, the Commission clarified that PG&E’s substation microgrid solutions “does not impact a customer’s choice of, or experience with, their [CCA].” (D.22-11-009 at 62.)
a. As related to issues in this proceeding, is PG&E amenable to providing advance notice to customers (at the earliest stages of the proposed Rule 30 process) that, among other things, identifies the CCA for the customer’s service location, describes the role that CCAs play in providing electric generation service to customers in their respective service areas, provides contact information (supplied by the CCA) for the CCA, and clearly states that the customer’s application for and election of transmission delivery service does not impact the customer’s rights with respect to electric generation service provided by the CCA? i. If not, please explain why PG&E is not amenable.
ii. If so, please identify where in the proposed Rule 30 stages PG&E would propose adding customer notification about these CCA-related matters.
ANSWER 007
PG&E is willing to work with the Joint CCAs to develop a procedure by which, during the Electric Rule 30 process, PG&E explains to an applicant that interconnection under Electric Rule 30 does not “impact a customer’s choice of, or experience with” a CCA or other energy provider such as a Direct Access provider. PG&E is willing to work with the Joint CCAs on the appropriate information to be provided by PG&E to potential transmission level customers during the Electric Rule 30 application process.
Attachment C-6
ElectricRule30-Transmission-LevelInterconnections_DR_JointCCAs_001-Q007
PACIFIC GAS AND ELECTRIC COMPANY
Electric Rule 30 – Transmission-Level Interconnections
Application 24-11-007
Data Response
Request Date: March 28, 2025
Requesting Party: Joint CCAs
Requester: Scott Blaising
Date Sent: April 10, 2025
QUESTION 001
Please provide a description of and associated timelines for expected activities under proposed Rule 30 (including, but not necessarily limited to, activity related to the submittal of an application, preliminary study, design review, engineering, interconnection agreement, procurement, construction and energization). The preceding examples are intended to be general descriptions of certain activity, and PG&E should not feel limited by these descriptions; PG&E may use whatever terminology it believes is most appropriate so long as PG&E’s response describes expected activities and provides associated timelines for these activities. As much as reasonably possible, the Joint CCAs request that PG&E describe activities in a sequential manner.
ANSWER 001
PG&E's large load interconnection process includes a number of phases: application, preliminary engineering study, design, preconstruction, construction, and closeout.
These phases can be described as the following:
Application Phase: The customer submits a service energization request and a study deposit.
Preliminary Engineering Phase: PG&E defines the initial scope of analysis and performs studies to determine service options and initial costs.
Design Phase: PG&E and the customer agree on the scope of work, creating a project design and refining the project cost.
Preconstruction Phase: This phase confirms dependencies between the customer and PG&E, including obtaining necessary permits and easements.
Construction Phase: PG&E schedules and completes all construction activities, including traffic control and scheduling outages.
Closeout Phase: All inspections are completed, and the site is energized, allowing the customer to start receiving service.
JointCCAs_003-Q001
Tyrone Hillman - Engineering, Planning and Strategy
Attachment C-7
ElectricRule30-Transmission-LevelInterconnections_DR_JointCCAs_003-Q001.pdf
While this process is generally sequential, certain components, such as design and preconstruction, can occur concurrently. The associated timelines are not solely under PG&E's control and depend on customer decisions, agency permit timelines, and land negotiations. As noted in our Application, until 2023, PG&E had a limited number of customers requesting retail electric service at transmission-level voltages. Infrequent requests for transmission-level interconnections were addressed through exceptional case filings. However, starting in 2023, the number of customers requesting transmission-level service began to significantly increase.
As we continue to refine our load interconnection processes, we lack the granularity to provide specific timelines for each phase. Nevertheless, the Preliminary Engineering Phase is planned to take 200 calendar days. Additionally, many projects require upstream capacity upgrades, which often involve more complex work. The CPUC has recently adopted the following maximum statewide timelines1 for upstream capacity projects, based on the lowest average among the three investor-owned utilities:
New or upgraded circuit: 684 calendar days
Substation upgrade: 1,021 calendar days
New substation: 3,242 calendar days.
1 D.24-09-020 at 47.
ElectricRule30-Transmission-LevelInterconnections_DR_JointCCAs_003-Q001.pdf JointCCAs_003-Q001
Tyrone Hillman - Engineering, Planning and Strategy
Attachment C-8