On Monday, RCRC submitted comments to the California Public Utilities Commission (CPUC) as part of the new Self-Generation Incentive Program (SGIP) proceeding.

Earlier this year, the CPUC voted to set aside 63% of SGIP ratepayer funds for community and individual energy resiliency projects to mitigate the impacts of PSPS events. The SGIP program is funded by ratepayers from the three largest investor owned utilities and provides incentives for customers to install energy storage devices. The program has devoted $600 million through 2024 to an equity resiliency budget, which will nearly completely subsidize the cost to install energy storage systems for critical facilities and certain residential customers in in Tier 2 or Tier 3 High Fire Threat Districts or that have experienced two or more PSPS events. Residential customers may qualify if they: 1) are eligible for the equity budget; 2) have participated in the Multifamily Affordable Solar Housing or Single Family Affordable Solar Homes Programs; 3) are on a medical baseline rate program or have reported a serious medical condition to their utility; or, 4) rely on electric well pumps for water supplies.

Due to an unexpected volume of funding applications from individuals who rely on electric groundwater well pumps, the CPUC requested stakeholder comments on whether they should adopt an income cap for groundwater well applicants and those that have reported a serious medical condition to their utility. RCRC provided feedback supporting eligibility for those customers and urging the CPUC to carefully craft any changes in order to avoid making the program overly restrictive.

In light of significant wireline communications provider push back to increasing the resiliency of their systems that serve communities with little or no wireless coverage, RCRC also suggested that the CPUC expand SGIP eligibility to help any residents who live in wireline-dependent communities. Wireline providers argued that they should not be required to upgrade their infrastructure in high fire risk areas to maintain service during a power outage because few residents have their own energy sources that are necessary to power residential communications equipment. As the industry shifted from copper based telephone lines to newer technology, the infrastructure has become far more dependent on utility- (or customer-) provided electricity. Expanding SGIP eligibility to customers living in areas dependent on wireline communications systems will allow those residents to tap into significant subsidies to install energy storage systems so that they can mitigate the impacts of PSPS events and maintain access to emergency communications networks.