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Before the Public Utilities Commission of the State of California

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Before the Public Utilities Commission of the State of California BEFORE THE PUBLIC UTILITIES COMMISSION OF THE FILED STATE OF CALIFORNIA 09/09/20 04:59 PM Order Instituting Rulemaking to Consider Rulemaking 17-07-007 Streamlining Interconnection of Distributed (Filed July 13, 2017) Energy Resources and Improvements to Rule 21. COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON PROPOSED DECISION ADOPTING RECOMMENDATIONS FROM WORKING GROUPS TWO, THREE, AND SUBGROUP AINSLEY CARRENO Attorney for: SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1358 Facsimile: (626) 302-1935 E-mail: [email protected] Dated: September 9, 2020 1 / 32 TABLE OF CONTENTS I. INTRODUCTION .......................................................................................1 II. DISCUSSION ..............................................................................................2 A. Several WG2 and WG3 Proposals Represent a Significant Departure from Current Practices and Merit Additional Implementation Time or Coordination ............................................2 1. SCE Recommends that the Final Decision Order Additional Stakeholder Coordination and a Tier 3 Advice Letter to Implement Proposal A-B 3 and Issue Nine ..........................2 2. Time Should Be Provided for Implementation of Proposal 8m Option B .........................................................................4 3. Time Should Be Provided for Stakeholder Consultation Prior to Advice Letter Submission Regarding the Lightning Review Process in Issue 11 Proposal B1 .............................5 B. Issue 12 Timeline Requirements Should Be Clarified or Modified 6 1. Proposal 12a and 12b Timelines Require Clarification .......6 2. Time Should Be Provided to Implement Timeline Reporting for Projects Other Than Rule 21 Non-Export .....9 3. Flexibility Should Be Provided in Satisfaction of the Net Generation Output Meter Timeline Set Forth in Proposal 12d........................................................................................9 C. Utilities Should Not Be Required to Provide Data on the “Accuracy” of the Integration Capacity Analysis in Connection with the Resolution of Issue 9 ........................................................10 D. Additional Commission Action Is Required Before the Vehicle-to- Grid Alternating Current Working Group Should Commence ......11 E. Clarifications or Corrections Are Required to the Proposed Decision .........................................................................................12 1. Proposal 8k Should Not Be Applied to Utilities That Do Not Use PG&E’s Transmission Overvoltage and Transmission Anti-Islanding Tests ....................................12 2 / 32 2. The Reference to Certification in OP 41 Requires Clarification .......................................................................13 3. The Adoption of Proposal 23i Should Identify What Qualifies as a “Pilot” and Should Confirm Other Rule 21 Requirements Still Apply ...................................................13 4. OP 47 Should Be Updated to Reflect Current Commission Efforts ................................................................................14 5. The Reference to “UL 1547 SA” in OP 40 Should Be Corrected ............................................................................14 6. SCE’s Treatment of the Cost-of-Ownership Charge Is Stated Incorrectly ...............................................................14 III. CONCLUSION ..........................................................................................15 APPENDIX A: Southern California Edison Company’s Proposed Modifications to the Proposed Decision 3 / 32 COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON PROPOSED DECISION ADOPTING RECOMMENDATIONS FROM WORKING GROUPS TWO, THREE, AND SUBGROUP TABLE OF AUTHORITIES CPUC Rules of Practice and Procedure Rule 14.3 ......................................................................................................................................... 1 CPUC Resolutions Resolution E-5000 ........................................................................................................................ 14 CPUC Rulemaking R.19.09.009 ..................................................................................................................................... 5 4 / 32 SUBJECT INDEX OF RECOMMENDED CHANGES Pursuant to Rule 14.3(b) of the California Public Utilities Commission’s (“Commission”) Rules of Practice and Procedure, Southern California Edison Company (“SCE”) provides the following Subject Index of Recommended Changes in support of its Comments on the Proposed Decision Adopting Recommendations from Working Groups Two, Three, and Subgroup (“PD”). In brief, the Recommended Changes propose to: Modify the PD to direct (i) the Energy Division to convene a series of discussions with industry stakeholders within 60 calendar days after issuance of the Final Decision focused on implementing Proposal A-B 3 and Issue 9, as modified by the PD and (ii) the Utilities to submit an implementation plan in a Tier 3 Advice Letter to the Commission within 6 months of issuance of the Final Decision outlining recommendations (as applicable) regarding the standard review, certification requirements, and interconnection processes necessary for implementation of these proposals. Allow an implementation period for Proposal 8m Option B of (i) nine months from issuance of the Final Decision for non-fixed solar systems and non-solar technology, and (ii) nine months after the development of necessary tools for fixed solar systems. Allow for a 60-day stakeholder consultation period regarding implementation of the Lightning Review Process set forth in Issue 11 Proposal B1 prior to the 180- day period set forth in OP 21, and clarify that the process should “minimize” rather than “remove” the need for engineering technical review. Clarify or modify the timelines required to be reported in Proposals 12a and 12b to ensure accurate and consistent reporting and allow for a stakeholder call to discuss necessary clarifications to the dates to be tracked. Allow six months for implementation of the reporting requirements set forth in Proposals 12a and 12b as applied to projects other than Rule 21 non-export. Modify Proposal 12d to allow 40 business days total for Net Generation Output Meter design and construction (as opposed to 20 business days for design and 20 business days for construction). Modify the Advice Letter requirement in OP 15 to require that utilities report on the effectiveness of ICA values by providing data obtained from Proposals 8b and 8c rather than reporting on the “accuracy” of ICA values. Delay meetings of the Vehicle-to-Grid Alternating Current Subgroup (V2G AC 5 / 32 Subgroup) until the Commission issues additional guidance on the standards that should govern V2G AC interconnections and the certification process for V2G AC systems. Make several non-substantive clarifications and corrections to the PD, including: (i) clarifying that Proposal 8k does not apply to utilities that do not perform Pacific Gas and Electric Company’s transmission overvoltage and transmission anti-islanding tests; (ii) clarifying the reference to “certification” in OP 41; (iii) clarifying the requirements for pilot programs in Proposal 23i; (iv) updating OP 47 to reflect current Commission efforts; (v) correcting a standard reference in OP 40; and (vi) correcting a misrepresentation of SCE’s treatment of the Cost-of- Ownership charge. 6 / 32 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Rulemaking 17-07-007 Streamlining Interconnection of Distributed (Filed July 13, 2017) Energy Resources and Improvements to Rule 21. COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ON PROPOSED DECISION ADOPTING RECOMMENDATIONS FROM WORKING GROUPS TWO, THREE, AND SUBGROUP I. INTRODUCTION Pursuant to Rule 14.3 of the California Public Utilities Commission’s (the “Commission”) Rules of Practice and Procedure, Southern California Edison Company (“SCE”) respectfully submits these comments on the Proposed Decision entitled “Decision Adopting Recommendations from Working Groups Two, Three, and Subgroup,” which was issued on August 20, 2020 (the “PD”). SCE appreciates the Commission’s efforts to resolve the issues set forth in Working Group 2 (“WG2”) and Working Group 3 (“WG3”). SCE believes that many of the proposals adopted will help streamline interconnection, improve transparency, and incorporate Integration Capacity Analysis (“ICA”) data into Rule 21. In these comments, SCE recommends modest changes and clarifications to ensure successful implementation and to provide clarity to all stakeholders on the steps to be taken going forward. 1 7 / 32 II. DISCUSSION A. Several WG2 and WG3 Proposals Represent a Significant Departure from Current Practices and Merit Additional Implementation Time or Coordination WG2 and WG3 involved several complex issues. In particular, WG2 included several proposals seeking to incorporate the results of the ICA into Rule 21. The novelty and complexity of these issues led WG2 to request additional time to complete its work.1 While WG2 worked diligently to review all of the proposals and subproposals at issue in the time allotted, in many cases it did not have time to discuss details supporting proposal implementation. Accordingly, SCE’s comments below focus on the critical need to allow stakeholders time to develop proposal implementation
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