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On Monday, October 21, 2019, the MRC submitted comments on the Preliminary Scoping Memo issued as a part of the California Public Utility Commission Order Instituting Rulemaking regarding Microgrids pursuant to Senate Bill 1339.

In the comments, the MRC applauds the Commission's efforts to eliminate microgrid barriers and encourage microgrid development through a stakeholder process. However, the MRC points out that the timetable for the proceeding is clearly inadequate in the wake of last year's devastating fires and this month's mismanaged blackouts. The MRC suggests that the Commission move forward to eliminate the most egregious barriers to microgrid deployment, including but not limited to: 

• Elimination of departing load charges.
• Reduction of standby charges to a simplified and clearly defensible minimum.
• Streamlining of microgrid interconnection.
• Reallocation of Small Generator Incentive Program ("SGIP") funding.