On May 3, 2001, San Diego Gas & Electric Company (SDG&E) filed and served an emergency petition for modification of Decision (D.) 01-04-006. SDG&E seeks authorization to implement a Rolling Blackout Reduction Program (RBRP) through proposed tariff Schedule RBRP. According to SDG&E, the RBRP will permit SDG&E to deploy customer-owned emergency backup generators (BUGs) during a Stage 3 event declared by the California Independent System Operator (CAISO). SDG&E says this will bring additional generation on-line, and reduce the need for rolling blackouts.
On May 17, 2001, comments were submitted by Premier Utility (PU) Consultants Inc. PU Consultants recommends denial of the petition, but generally seeks Commission endorsement of a CAISO program designed to operate BUGs.1 On May 18, 2001, responses were filed and served by Pacific Gas & Electric Company (PG&E), the CAISO, and the University of California and California State University (UC/CSU). PG&E opposes the petition. CAISO states it generally does not oppose the use of BUGs, but expresses concern with SDG&E's proposal. UC/CSU generally support the proposal. Finally, letters dated May 18, 2001 were received from the Air Pollution Control District (APCD) of San Diego County, and the California Air Resources Board (ARB). The San Diego APCD expresses conditional support, while the ARB recommends denial of the petition.
On May 21, 2001, SDG&E filed and served reply comments in further support of the RBRP.2 SDG&E asks that the Commission balance concerns with the proposed program against the potential of serious public harm if rolling blackouts become a reality.
1 PU Consultants Inc. is an information only participant in this proceeding. As SDG&E points out, however, the CAISO program endorsed by PU Consultants does not exist, and has no prospect of coming onto existence in the near future. (SDG&E Reply Comments, pages 20-21.) 2 An errata was filed and served on May 22, 2001.