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R1707007 Rule 21 Working Group Three Final Report

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R1707007 Rule 21 Working Group Three Final Report BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Streamlining Interconnection of Distributed Rulemaking 17-07-007 Energy Resources and Improvements to Rule 21. (Filed July 13, 2017) WORKING GROUP THREE FINAL REPORT JONATHAN J. NEWLANDER Attorney for SAN DIEGO GAS & ELECTRIC COMPANY 8330 Century Park Court, CP32D San Diego, CA 92123 Phone: (858) 654-1652 E-mail: [email protected] ON BEHALF OF ITSELF AND: KEITH T. SAMPSON ALEXA MULLARKY Attorney for: Attorney for PACIFIC GAS AND ELECTRIC SOUTHERN CALIFORNIA EDISON COMPANY COMPANY 77 Beale Street 2244 Walnut Grove Avenue San Francisco, California 94105 Post Office Box 800 Telephone: (415) 973-5443 Rosemead, California 91770 Facsimile: (415) 973-0516 Telephone: (626) 302-1577 E-mail: [email protected] E-mail: [email protected] June 14, 2019 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Streamlining Interconnection of Distributed Rulemaking 17-07-007 Energy Resources and Improvements to Rule 21. (Filed July 13, 2017) WORKING GROUP THREE FINAL REPORT Pursuant to the Scoping Memo of Assigned Commissioner and Administrative Law Judge, dated October 2, 2017, as modified by the Assigned Commissioner’s Amended Scoping Memo and Joint Administrative Law Judge Ruling, dated November 16, 2018, San Diego Gas & Electric Company (U 902-E), on behalf of itself and Pacific Gas and Electric Company (U 39-E) and Southern California Edison Company (U 338-E), hereby submits the Working Group Three Final Report. Respectfully submitted, /s/ Jonathan J. Newlander _______________________ Jonathan J. Newlander Attorney for SAN DIEGO GAS & ELECTRIC COMPANY 8330 Century Park Court, CP32D San Diego, CA 92123 Phone: 858-654-1652 E-mail: [email protected] On Behalf of San Diego Gas & Electric Company (U 902-E), Pacific Gas and Electric Company (U 39-E), and Southern California Edison Company (U 338-E) June 14, 2019 1 Working Group Three Final Report June 14, 2019 California Public Utilities Commission Interconnection Rulemaking (R.17-07-007) Table of Contents Working Group Three Background ................................................................................................. 3 Issue 12, Proposals 12-a to 12-j .................................................................................................... 10 Issue 15, Proposals 15-a to 15-b .................................................................................................. 24 Issue 16, Proposals 16-a to 16-d .................................................................................................. 27 Issue 20, Proposals 20-a to 20-c ................................................................................................... 33 Issue 22, Proposals 22-a to 22-b .................................................................................................. 40 Issue 23, Proposals 23-a to 23-i .................................................................................................... 61 Issue 24, Proposals 24-a to 24-c ................................................................................................... 99 Issues 27 and 28, Proposals 27-a to 27-c and Proposal 28-a ...................................................... 110 Issues A and B, Proposals A-B #1 to A-B #4 ................................................................................ 125 Issue D ........................................................................................................................................ 139 Annexes Annex A: Issue 16, Proposal Refinement by Proponents ............................................................. 32 Annex B: Issue 20, Potential Use Cases of Transfer from Rule 21 to WDAT ................................ 39 Annex C: Issue 22, Detailed Descriptions of Sub-Proposals ......................................................... 46 Annex D: Issue 22, Party Comments on Sub-Proposals ................................................................ 50 Annex E: Issue 23, Survey on V2G-AC (Mobile) Pilots .................................................................. 88 Annex F: Issue 27, Framework of Operational Categories for Smart Inverter Functions .......... 117 Annex G: Issue 27, Use Cases and Party Comments on Use Cases ............................................ 119 2 Working Group Three Background Procedural Background On July 13, 2017, the California Public Utilities Commission (“CPUC” or “Commission”) issued an Order Instituting Rulemaking to consider a variety of refinements to the interconnection of distributed energy resources under Electric Rule 21. On October 2, 2017, the Commission issued a scoping ruling for R.17-07-007 directing Pacific Gas and Electric (“PG&E”), Southern California Edison (“SCE”), and San Diego Gas and Electric (“SDG&E”), or the investor-owned utilities (“IOUs” or “utilities”), to convene eight working groups to develop proposals to address the issues.1 Working Group One submitted its final report on March 15, 2018. Working Group Two submitted its final report on October 31, 2018.2 An amended scoping memo on November 16, 2018 tasked the third working group, “Working Group Three,” to commence on December 1, 2018 and to develop and file a final report by June 14, 2019 for recommending proposals to address eleven issues. The amended scoping memo scheduled a workshop on Working Group Three proposals for June 21, 2019, scheduled an Administrative Law Judge (“ALJ”) ruling on the Working Group Three Report by July 19, 2019, established a due-date for comments on Working Group Three proposals by August 2, 2019, and established a due-date for reply comments by August 12, 2019.3 Working Group Scope Working Group Three developed proposals addressing eleven issues (12, 15, 16, 20, 22, 23, 24, 27, 28, A, and B) from the November 16, 2018 amended scoping memo: Issue 12. How can the Commission improve certainty around timelines for distribution upgrade planning, cost estimation, and construction? Should the Commission consider adopting enforcement measures with respect to these timelines? If so, what should those measures be? Issue 15. Should the Commission require itemized billing for distribution upgrades to enable customer comparison between estimated and billed costs and verification of the 1 R.17-07-007 Scoping Ruling, October 2, 2017 (http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M196/K476/196476255.pdf). 2 Interconnection Rulemaking 17-07-007, https://www.cpuc.ca.gov/General.aspx?id=6442455170, page updated January 2019 3 R.17-07-007 Amended Scoping Memo and Joint Ruling, November 16, 2018 (http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M241/K155/241155616.pdf) 3 accuracy of billed costs? Issue 16. Should the Commission encourage third party construction of upgrades to support more timely and cost-effective interconnection and, if so, how? Issue 20. How should the Commission coordinate Commission-jurisdictional and Federal Energy Regulatory Commission- jurisdictional interconnection rules for behind-the- meter distributed energy resources, including modification of queuing rules for Rule 21 and Wholesale Distribution Access Tariff (WDAT) projects seeking to interconnect at the same location, clarification of the rules for projects wanting to transfer between the Rule 21 and WDAT queues, and streamlining of the transfer process? Issue 22. Should the Commission require the Utilities to make improvements to their interconnection application portals? If yes, what should those improvements be? Issue 23. Should the Commission consider issues related to the interconnection of electric vehicles and related charging infrastructure and devices and, if so, how? Issue 24. Should the Commission modify the formula for calculating the Cost-of- Ownership charge and, if so, how? Issue 27. What should be the operational requirements of smart inverters? What rules and procedures should the Commission adopt for adjusting smart inverter functions via communication controls? Issue 28. How should the Commission coordinate with the Integrated Distributed Energy Resource proceeding to ensure operational requirements are aligned with any relevant valuation mechanisms? Issue A. What changes are needed to clarify the parameters for approval of system design to achieve non-export and limited export. Issue B. How should utilities treat generating capacity for behind the meter paired solar and storage systems that are not certified non-export? The November 16, 2018 amended scoping memo also included Issue D as part of Issue 12. Working Group Three discussed Issue D, and these discussions resulted in a statement in the final report that no proposal was necessary for Issue D: Issue D. When should the Commission consider results of an initial review or detailed study to be binding? Under what circumstances should the Commission allow the results to be changed? 4 Working Group Process Working Group Three met 18 times between November 28, 2018 and May 29, 2019 to develop proposals to address Issues 12, 15, 16, 20, 22, 23, 24, 27, 28, A, B, and D. Nine meetings were via teleconference and lasted 2 hours, and nine meetings were in-person meetings that lasted 4 hours. Most of the in-person meetings took place at the Commission’s San Francisco offices, and three meetings took place at other venues in San Francisco and Oakland. In addition, there were six joint meetings of Working Group Three and the Smart Inverter Working Group via
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