Issue 8 Proposal[remaining to do list:

- Finalize policy and cost considerations section- Revise flow chart and integrate- Receive/place final counterproposals- Clean up Roger’s figure 1- Rewrite summary- Cost/benefit- 8.n explanation- Final SCE and CALSSA input on 8q- Timelines

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Table of ContentsProposal Summary.......................................................................................................................................... 4

Issue 8: How should the Commission incorporate the results of the Integration Capacity Analysis into Rule 21 to inform interconnection siting decisions, streamline the Fast Track process for projects that are proposed below the integration capacity at a particular point on the system, and facilitate interconnection process automation?. .4

Summary of Revised Flow Chart...................................................................................................................................................6

Background........................................................................................................................................................ 8ICA and Interconnection Overview..............................................................................................................................................8

Threshold Considerations.......................................................................................................................... 10Policy Considerations......................................................................................................................................................................10Cost Considerations..........................................................................................................................................................................11Implementation Dependencies....................................................................................................................................................11Proposed ICA Validation Study....................................................................................................................................................11

Proposal Summaries.................................................................................................................................... 12Proposal 8.a: Remove Existing Fast Track Eligibility Limit.............................................................................................12Proposal 8.b: Modification of Initial Review Process to Include Verification and Explanation of Updated ICA............................................................................................................................................................................................................ 12Proposal 8.c: IOUs will keep track of when ICA values are updated outside of the required monthly update to inform future ICA discussions.................................................................................................................................14Proposal 8.d: Modification of Projects if ICA Values are Out-of-Date To Stay Under ICA Limit and Maintain Queue Position................................................................................................................................................................14SCE suggests it would, as a part of its initial review response, indicate whether a customer passed or failed initial review, including technical information delineated in Proposal 8.b. If the customer desires to make modifications to its interconnection request, the customer can do so by utilizing the approved Material Modification procedures. PG&E and SDG&E generally agree with SCE, but conclude the proposal adds complexity without providing substantial value......................................................................................................14Proposal 8.f: Apply Screen F to Projects Larger than 30 kVa; Provide Earliest Available Indication where Screen F Failure is Likely................................................................................................................................................................14Proposal 8.g: Apply Screen G to Projects Larger than 30 kW; Provide Earliest Available Indication where Screen G Failure is Likely...............................................................................................................................................................16Proposal 8.h: Screen H should be modified to note that Screen H does not apply to Generating Facilities with a Gross Rating of 30 kVA or less.......................................................................................................................................17Proposal 8.i: Non-export projects must be evaluated for all screens.........................................................................17Proposal 8.j: Apply Screen J to Projects Larger than 30 kW...........................................................................................18Proposal 8.k: Screen L should be modified to include the transmission overvoltage and transmission anti-islanding test..............................................................................................................................................................................18Proposal 8.m: Screen M should be modified to reflect ICA.............................................................................................20Proposal 8.n: The Commission should adopt additional Initial Review Screen F1..............................................23Proposal 8.o: The Commission should adopt additional Supplemental Review Screen M2. The IOUs are required to develop <API? Translator?>.................................................................................................................................23Proposal 8.p: Changing Supplemental Review Screens....................................................................................................24Proposal 8.q: Screen P should be modified… .......................................................................................................................24Proposal 8.r: The Interconnection Application should have an option to combine Initial Review and Supplemental Review, with applicants pre-paying for Supplemental Review.......................................................24

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Proposal 8.s: Rule 21 tariff should adopt new timelines that reflect additional efficiencies driven through the incorporation of ICA, <better enforce timelines>, and reduce interconnection fees..................................25Proposal 8.t: Queue management...............................................................................................................................................25Proposal 8.u: IOU Validation Exercise......................................................................................................................................26Proposal 8.v: non-ICA related automation of Rule 21 Screens......................................................................................26

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Proposal Summary

Issue 8: How should the Commission incorporate the results of the Integration Capacity Analysis into Rule 21 to inform interconnection siting decisions, streamline the Fast Track process for projects that are proposed below the integration capacity at a particular point on the system, and facilitate interconnection process automation?

The following proposals were developed by various stakeholders as part of the Working Group process to address Issue 8.

Proposals to modify the Rule 21 process and integrate the results of ICA include:

o Proposal 8.a: Remove Existing Fast Track Eligibility Limito Consensus: yes? o Non-consensus (supported by/opposed by)

o Proposal 8.b: Modification of Initial Review Process to Include Evaluation of Updated ICAo Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.c: IOUs to track updated ICA values to inform future ICA discussions with regards to frequency of updates

o Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.d: Modification of Projects if ICA Values are “Stale” To Stay Under ICA Limit and Maintain Queue Position

o Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.e: Identification of ICA results shared during Initial Review Results Meetingo Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.f: Screen F should be modified to note that Screen F does not apply to Generating Facilities with a Gross Rating of 30 kVA or less; Known Results> of Screen F may be shared on <maps>

o Consensus: ?? to change/?? on sharing information on map vs. pre-app, how it’s implemented

o Non-consensus (supported by/opposed by)o Proposal 8.g: Screen G should be modified to note that Screen G does not apply to Generating

Facilities with a Gross Rating of 30 kVA or less; <Known Results> of Screen G may be shared on <maps>

o Consensus: ?? to change/?? on sharing information on map vs. pre-app, how it’s implemented

o Non-consensus (supported by/opposed by)

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o Proposal 8.h: Screen H should be modified to note that Screen H does not apply to Generating Facilities with a Gross Rating of 30 kVA or less

o Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.i: Non-export projects which pass Screen I should still be reviewed under Screen Mo Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.j: Screen J should be modified to ask, “Is the generating facility ≤ 30 kVA?”o Consensus: yes o Non-consensus (supported by/opposed by)

o Proposal 8.k: Screen L should be modified to include the transmission overvoltage and transmission anti-islanding test.

o Proposal 8.l: Some indicators of where projects are likely to fail Screen L should be flagged on the <ICA map> in advance, where known transmission deficiencies have already been identified.

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.m: Screen M should be modified to reflect ICAWOF (w or w/o buffer?)o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.n: The Commission should adopt additional Initial Review Screen F1o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.o: The Commission should adopt additional Supplemental Review Screen M2. The IOUs are required to develop <API? Use of 3rd party? Integrated into map, app, or pre-app?>

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.p: The IOUs made language changes to Supplemental Review Screens language to reflect evaluation of operational flexibility considerations

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.q: Screen P should be modified to reflect <consideration of x/r ratio> before requiring upgrades

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.r: The Interconnection Application should have an option to combine Initial Review and Supplemental Review, with applicants pre-paying for Supplemental Review

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.s: Rule 21 tariff should adopt new timelines that reflect additional efficiencies driven through the incorporation of ICA, <better enforce timelines>, and reduce interconnection fees

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.t: <Queue management>

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o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.u: <IOU validation exercise>o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.v: <non-ICA related automation of Rule 21 Screens>o Consensus: ? o Non-consensus (supported by/opposed by)

Summary of Revised Flow Chart

[add narrative relating this to proposals]

As a key objective of Issue 8 is to understand how the Rule 21 process will be streamlined, the WG identified that proposals to modify the tariff should clearly highlight:

- Steps to be eliminated- Steps to be streamlined- Steps to be added- Who takes each step

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- What data is used - How the action is executed

This section presents a summary of the proposals only. The “Working Group Proposals” section further describes the proposals and the positions for and against each. Please review the Appendix for complete Issue Proposals by supporting WG members and identification of the steps mentioned above.

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Background

The Integration Capacity Analysis (ICA) is a tool, developed under the Distribution Resources Plan (R.14-08-013) proceeding. California Public Utilities Commission (CPUC) Decision D. 17-09-026 adopted the use of ICA for online maps, interconnection streamlining, and distribution planning, and authorized implementation of ICA across the utilities’ system-wide territories. This Decision reiterated that one of the key purposes of the DRP is to dramatically streamline the interconnection process, and that ICA results can help customers design DER systems by providing accurate information about the amount of DER capacity that can be interconnected at specific locations without significant distribution system upgrades or study process.1

ICA and Interconnection OverviewICA is a tool that provides information on the distribution system conditions capabilities that helps inform interconnection applicants on proposed project sizing. This information is based on analyses of grid conditions tied to accounting for thermal limitations of distribution components, power quality/voltage, protection, safety, and operational flexibility requirements. The Distribution Resource Plan Working Group report described its expectations for using the ICA to support interconnection as follows2:

Developers should be able to submit a Rule 21 Fast Track application for DER interconnection up to the identified ICA value at the proposed point of interconnection, based on ICA figures shown on the map, changes in queued DER since the last map update and the underlying data, and be able to pass those screens representing criteria the ICA has evaluated….

The ICA values identified at a point of interconnection are expected to replace and/or supplement the size limitations in the Fast Track eligibility criteria and will be able to address and/or improve the technical screens in the Rule 21 Fast Track process which are part of the ICA methodology…With few exceptions, interconnection customers should be able to use the ICA value at their point of interconnection to know whether a proposed project will pass these screens in the Fast Track process. In the near-term, there will be additional screens that still need to be evaluated due to data not currently analyzed in the ICA.

Decision D. 17-09-026 further specified how ICA should be implemented and the specifics of the methodology that should be used but identified Rule 21 as the proceeding to decide how ICA can be incorporated into the Rule 21 tariff. The R. 17-07-007 Scoping Memo identified three Phases of the proceeding and scoped issues to be addressed by various working groups. Working Group Two is tasked with discussing ICA and Streamlining Interconnection Issues.

1 D.17-09-026, p. 272 ICA Working Group Final Report, p. 8-9 (https://drpwg.org/wp-content/uploads/2016/07/ICA-WG-Final-Report.pdf)

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Threshold ConsiderationsThe Working Group spent much of its effort identifying and developing consensus proposals, and exploring issues where consensus may exist. In identifying changes to the R21 tariff, members of the WG also identified where there are “threshold considerations” to adopting the recommended changes. These threshold considerations include 1) policy issues, 2) cost considerations, and 3) implementation dependencies.

Policy Considerations The Working Group identified several policy issues for consideration when discussing proposed changes to the Rule 21 tariff. Given the current phase (Phase 1) of this proceeding is not scoped to address ratemaking and cost considerations, the WG has agreed to summarize the discussion on the related policy issues to date in this WG report for the Commission’s subsequent consideration in Phase 2 (“Ratesetting Issues Requiring Coordination with 14-08-013”). For some proposed modifications, the WG has presented different proposals on how to proceed in the interim until after the Commission resolves related policy questions. This report identifies those proposals.

Responsibility for grid upgrades when load changesRule 21 currently holds interconnecting generators responsible for grid upgrades which are necessary to accommodate the interconnecting generator (see Rule 21 Section E.4). In the event load changes (increase or decrease) subsequent to that interconnection, triggering the need for additional grid upgrades, the utility would plan for necessary upgrades, seek approval of those costs from the Commission through a general rate case during the utilities filing period, and, if approved, collect the costs of the upgrade from all customers. In the past, DER penetration has been relatively low, so load decreases have not triggered the need for upgrades and load increases were handled through overarching grid planning as a normal course of business. This dynamic has been aided by Screen M, which allows interconnection requests to pass simplified interconnection if the aggregate generation is less than 50% of the minimum load on the feeder. The WG asked, under a new R21 framework using ICA in which DER penetration edges upward, what may be the effect of changing load? And how should these changes be evaluated under Rule 21?

The WG discussed scenarios in which the existing approach to cost recovery for grid upgrades may warrant further consideration. Scenarios discussed include both situations involving Rule 21 and one scenario that impacts the proposals made herein related to interconnection processes and cost responsibilities for non-export projects. Specifically, as DER penetration continues to increase, the amount of load being served by DER rises and the margin for error in load forecasting decreases as circuits get closer to “full capacity”. Put differently, the more load served by DER, the more sensitive grid operators become to unexpected changes in load, and the smaller the margin of available generating capacity becomes on a circuit. Further, the WG discussed that responsibility for costs when load disappears has not yet been an issue the IOUs have experienced but expect to happen on a more frequent basis going forward, given higher rates of adoption of load-modifying DERs (e.g., storage). So the high DER penetration scenarios, which are the express purpose of the ICA and current revisit of Rule 21, introduce new sensitivity to changes in load and, by extension, cost allocation for grid upgrades which may be necessary to serve customers reliably.

At present there are no regulations on who should pay for grid upgrades in such scenarios. The Commission may wish to considerhis issue and whether a policy is warranted.

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Interconnection processes and cost responsibilities for non-export projects to pay for both interconnection studies and grid upgrades

Related to the previously identified concernThe WG discussed that, with a reduced margin of available capacity, non-exporting generating facilities could have a material impact on power flow, potentially triggering system upgrades. The WG asked, under a new R21 framework using ICA, what happens when non-exporting systems reduce the minimum load on the feeder? Does this change how they should be evaluated under Rule 21 to interconnect onto the grid?

Under the existing Rule 21 Fast Track process, non-export projects which pass the Fast Track Screens A-H will also pass Screen I, bypassing Screen M which is meant to determine when aggregate generation is approaching or exceeding minimum load on a feeder. As detailed in Proposal 8.i, IOUs propose to eliminate the Screen I exemption for non-exporting systems, so that non-export projects are screened to determine whether further study is required to identify if system upgrades are required, similar to any other Rule 21 interconnection request. Similarly, those WG members identified that if needed, non-export projects should be required to pay for system impact studies.

This likely includes additional cost implications for non-export projects to pay the fees for Supplemental Review and increase the time to review and approve a non-export project.

Cost Considerations The WG discussed whether and how to consider the costs of implementing proposals suggested here. This question arises in several proposals. First, the question of cost comes up in Proposals 8.f, 8.g., and 8l, in which some utilities are considering presenting information related to the likelihood of interconnecting generators to pass Screens F, G, and L. Second, the question of cost comes up in Proposal 8.v, concerning non-ICA related automation of Rule 21 screens. Implementation of these proposals may result in new costs to IOUs.

The WG agreed to include a high-level sense of whether these proposals result in costs and the reasonableness of such costs, but to defer detailed consideration of costs to the Ratemaking portion of this Proceeding.

Implementation Dependencies New tools and processes will be needed to achieve use of ICA values in the interconnection process, to achieve Proposals 8.a – 8.t. Those include:

1. Tool or process to efficiently reference the ICA values 2. Tool or process to efficiently update the ICA value3. Tools to reference external information (such as PV watts), including processing operational profiles[4.] Tools to process customer provided DER - typical operation profiles4.[5.] Processes related to new interconnection process flow (applications, forms)

Proposed ICA Validation StudyGiven the complexity of ICA and that ICA production is new, the IOUs are conducting quality control and assurance efforts to ensure the results of that analysis can be used in the ways proposed herein. The Working Group has significant discussion of these efforts and agreed they are worthwhile.

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Proposal SummariesProposal 8.a: Remove Existing Fast Track Eligibility Limit ProposalThe Commission should remove the existing Fast Track Eligibility Limit.

StatusConsensus

DiscussionFast Track evaluation allows for rapid review of certain projects to determine whether they require further Detailed Study. Fast Track is comprised of an Initial Review and, if required, a Supplemental Review. Because a project’s size has been a primary indicator of whether it is likely to be approved for interconnection under Fast Track, eligibility for Fast Track review currently is dependent on the project’s size. PG&E and SCE currently use a 3 MW size limit to determine Fast Track eligibility, while SDG&E uses a 1.5 MW size limit.

The ICA provides an estimation about what size project can likely be interconnected on a specific circuit without likely requiring distribution upgrades, replacing the need for the 3 MW or 1.5 MW limits currently used to determine Fast Track Eligibility. Indeed, it is possible that in some locations the ICA may indicate capacity for projects larger than these limits. In addition, in some cases projects which are proposed above the ICA limit may be able to be interconnected without study after Supplemental Review is conducted if minor upgrades or system changes are possible to address the limitation. Thus, this proposal will allow applicants to select Fast Track as their preferred study track.

All WG members supported the elimination of Fast Track Eligibility Limits. Two caveats to this proposal were emphasized by the WG. First, ICA is informational only and projects may be required to go to Supplemental or Detailed studies and projects may trigger upgrades to allow interconnection. Elimination of the Fast Track eligibility limit does not increase an interconnecting generator’s chances of passing through initial or supplemental review if the project is sized above the ICA with or without Operational Flexibility. Applicants are therefore encouraged to reference the ICA. Second, net-energy metering (NEM) projects under 30kW are currently processed as Fast Track projects. The WG recommends this practice continue, regardless of the ICA.

Proposal 8.b: Modification of Initial Review Process to Include Verification and Explanation of Updated ICA ProposalThe IOUs will modify their Initial Review processes for specific interconnection requests where an updated ICA value may be required, to to incorporate an additional run of specific node/feeder ICA where an updated ICA value may be required. IOUs will provide interconnecting generator an explanation of the update.

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StatusNon-consensus

DiscussionPer implementation requirements from D. 17-09-026, the ICA is currently updated on a monthly basis on circuits where significant system changes have occurred and those monthly updates are reflected in the ICA maps and public data portals. The WG noted that this frequency of updates means that sometimes interconnection requests could be sized based upon a ICA value which is not up-to-date; that is, the ICA value reflected on the public data portal and online map may not reflect changes which have occurred in the grid (such as circuit reconfigurations, load changes, equipment changes, etc.) or changes in the interconnection queue (such as new interconnection applications and/or withdrawals).

SCE proposes to use the Initial Review process to determine if the ICA values at the proposed Point of Interconnection (POI) need to be updated. If it is determined that the ICA value at the POI needs to be updated, SCE will use the ICA tool on the specific electrical node or will run the ICA on all the electrical nodes in the circuit, depending on future ICA tool capabilities. SCE believes that the Initial Review process may reveal the need for an updated ICA value when the Interconnection Request-to-ICA ratio at the requested POI is greater than 50% for any hour. SCE will not perform additional analyses of interconnection requests with less than 30kW nameplate capacity.

This proposal can be implemented without changes to the existing timelines for Initial Review.

PG&E and SDG&E generally agree with SCE’s approach, but proposes that verification of the ICA through the Initial Review Process may also be accomplished through simple calculations without rerunning the ICA.

In addition to these questions of how ICA values would be verified, the WG discussed what steps the IOUs should take to share the results of their analysis with the interconnecting generator. Most WG participants agree an explanation of the following is warranted:

- Grid condition changes- Interconnection queue changes- New results of ICA rerun or alternative calculation

In the event disclosing ICA results fails any confidentiality provision, IOUs will provide information in aggregation or at a level of granularity that would allow IOUs to continue to comply with 15/15 confidentiality rules

Finally, SCE agreed to consider future implementation of system for “flagging” if the ICA value likely needs an update. If possible, SCE would attempt this during Q1 2019.

Most Working Goup members support this proposal. GPI opposes this proposal as it asserts this proposal would add a new step to interconnection and may make interconnection review more complicated.

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Proposal 8.c: IOUs will keep track of when ICA values are updated outside of the required monthly update to inform future ICA discussionsProposalThe IOUs will track when the ICA is updated for interconnection requests and identify when the posted ICA deviates from the actual ICA.

StatusNon-consensus

DiscussionSome WG participants suggested that the IOUs should track deviations from the posted ICA values which surface during the implementation of Proposal 8.b to inform future discussions of ICA refinement.

SCE expressed a willingness to consider tracking ICA updates for those projects that require Supplemental Review. PG&E and SDG&E oppose this proposal at this time, finding it better related to long-term ICA refinements within the DRP proceeding.

Proposal 8.d: Modification of Projects if ICA Values are Out-of-Date To Stay Under ICA Limit and Maintain Queue Position ProposalApplicants who apply based on posted ICA should have an opportunity to make modifications to their application should the ICA value change by the time their application is reviewed.

StatusNon-consensus

DiscussionThe WG discussed that projects which apply to be studied under Fast Track and apply based on the posted ICA value may have an opportunity to modify their application request, should the ICA value have changed at the time their application is evaluated in the queue.

SCE suggests it would, as a part of its initial review response, indicate whether a customer passed or failed initial review, including technical information delineated in Proposal 8.b. If the customer desires to make modifications to its interconnection request, the customer can do so by utilizing the approved Material Modification procedures. PG&E and SDG&E generally agree with SCE, but conclude the proposal adds complexity without providing substantial value.

CALSSA offers a counterproposal (8.dx) in Appendix X. Stakeholders supporting CALSSA’s 8.dx include: x, y, and z.

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Proposal 8.f: Screen F should be modified to note that Screen F does not apply to Generating Facilities with a Gross Rating of Apply Screen F only to Projects Larger than 30 kVa; Provide Earliest Available Indication where Screen F Failure is LikelyProposalApply Screen F to Projects Larger than 30 k Va ; Provide Earliest Available Indication where Screen F Failure is Likely

StatusModification #1: consensusnon-consensus

Modification #2: consensusnon-consensus

DiscussionModification 1:

The existing Rule 21 tariff language for Screen F includes the following language:

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 11 kVA or less.

The WG/someSome WG members agreed that this should be expanded to 30 kW to allow standard NEM and other small projects to easily pass the Screen and maintain the goal of streamlining the interconnection process for small projects.

This tariff language is changed to

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 30 kVA or less.

All WG stakeholders agree the increase from 11 kVa to 30kVa is an improvement. Some WG members are concerned the threshold could be larger than 30kVa. The IOUs emphasize the 30kVa is an acceptable number, but not derived from technical analysis. Stakeholders request additional analysis and reasoning behind the 30kVa threshold. Resolving this difference was beyond the bandwidth of the WG.

Modification 2:

Screen F (“Is the Short Circuit Current Contribution Ratio within acceptable limits?”) identifies whether a project may have an impact on the system’s short circuit duty, fault detection sensitivity, relay coordination, or fuse-saving schemes. While the ICA Working Group report had indicated that the ICA could provide results for this screen, the WG identified that all elements of the tests conducted under Screen F are not evaluated within ICA, which identifies reduction of reach of reach, but does not study coordination. Further, Screen F requires the IOUs to study impacts in aggregate with other generating facilities on the circuit. However, IOUs typically know where Screen F is likely to fail based on existing system conditions at each 3-phase electrical node, when short circuit flow models are run. Identifying where projects are “likely to fail Screen F” upfront for projects over 500 kw for developers will facilitate streamlining of the interconnection process by allowing developers to make informed development choices. In order to determine if a project fails Screen F it is necessary to run short circuit flow models. In sum, the ICA does not provide a an indication whether a project is likely to required Supplemental Review or Detailed Study.

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In the place of the ICA, IOUs considered whether/how they may provide an early indication whether a project is likely to face challenges related to Screen F. SCE is evaluating the feasibility to display locations where projects would likely fail Screen F. If and when this capability and information is available, SCE would display this information along with the ICA values in the interconnection maps PG&E proposes that screen F results can provided in the Pre-Application report given that our CYME DG Screening tool has the capability to analyze Screen F quickly. Information can be provided as an additional screen in the pre-application once the DG Screening Tool is modified to add this new feature. SDG&E indicates it does not have the capability to provide additional information before its Initial Review results.

Finally, some stakeholders have reservations about this proposal, noting that a “pass/fail” flag for Screen F may have limited value, given that successfully passing Screen F is a function of the project’s size. This concern is greater for customer-sited projects, relative to projects in front of the meter. Given these observations, the benefits of the proposal may not outweigh the costs. Other stakeholders emphasize that the value of the proposal depends on what exact information the IOU provides and what the information means, both questions which remain unanswered.

Proposal 8.g: Apply Screen G to Projects Larger than 30 kW; Provide Earliest Available Indication where Screen G Failure is Likely

ProposalApply Screen G to Projects Larger than 30 kVa; Provide Earliest Available Indication where Screen G Failure is Likely

StatusModification #1: consensus

Modification #2: consensus

DiscussionModification 1:

The existing Rule 21 tariff language for Screen F includes the following language:

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 11 kVA or less.

The WG/some WG members agreed that this should be expanded to 30 kVA, to allow standard NEM and other small projects to easily pass the Screen and maintain the goal of streamlining the interconnection process for small projects.

This tariff language is changed to

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 30 kVA or less.

Modification 2:

Screen G (“Is the Short Circuit Interrupting Capability Exceeded?”) identifies and studies whether a generating facility, in aggregate with other generating facilities on the distribution circuit, cause disturbances to protective devices and equipment, risking overstressing the equipment. This Screen

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allows the IOUs to evaluate how a generation project on the distribution system affects interrupting devices on the entire system, including at the distribution substation level, sub-transmission substation level (where applicable), and at the transmission level.

The ICA Working Group Report had indicated that this screen would be addressed by Screen G, but IOUs determined later that this was not the case since Screen G requires the IOUs to study impacts in aggregate with other generating facilities on the circuit. The information required to determine failure of Screen G may be from cluster studies, Rule 21 interconnection studies, and other internal studies. Identifying where these substations may be located and flagging them as “likely to fail Screen G” upfront will facilitate streamlining of the interconnection process. However, this information is not easily obtainable and may not be available until a study (such as cluster study or Rule 21 study) is complete for the relevant circuit or substation.

In the place of the ICA, IOUs considered whether/how they may provide an early indication whether a project is likely to face challenges related to Screen G. SCE is evaluating the feasibility to display locations where projects would likely fail Screen G. Screen G requires the IOUs to study impacts in aggregate with other generating facilities on the circuit. However, IOUs typically know which substations are likely to fail Screen G due to studies the utilities run, including cluster studies, Rule 21 interconnection studies, and other internal studiee. Identifying where these substations may be located and flagging them as “likely to fail Screen G” upfront for projects over 500 kw for developers will facilitate streamlining of the interconnection process.

PG&E proposes that screen G results can provided in the Pre-Application report given that our CYME DG Screening tool has the capability to analyze Screen G quickly. Information can be provided as an additional screen in the pre-application once the DG Screening Tool is modified to add this new feature. SDG&E indicates it does not have the capability to provide additional information before its Initial Review results

Finally, some stakeholders have reservations about this proposal, noting that a “pass/fail” flag for Screen G may have limited value, given that successfully passing Screen G is a function of the project’s size. This concern is greater for customer-sited projects, relative to projects in front of the meter. Given these observations, the benefits of the proposal may not outweigh the costs. Other stakeholders emphasize that the value of the proposal depends on what exact information the IOU provides and what the information means, both questions which remain unanswered. Finally, some stakeholders strongly support consolidating this information in the ICA maps to ease access.

Proposal 8.h: Screen H should be modified to note that Screen H does not apply to Generating Facilities with a Gross Rating of 30 kVA or lessProposal

StatusConsensus

DiscussionThe existing Rule 21 tariff language for Screen F includes the following language:

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Note: This Screen does not apply to Generating Facilities with a Gross Rating of 11 kVA or less.

The WG/some WG members agreed that this should be expanded to 30 kVA, to allow standard NEM and other small projects to skip the Screen and maintain the goal of streamlining the interconnection process for small projects. It is not anticipated that projects below 30 kVA would be likely to raise any safety or reliability concerns if they skipped this screen.

This tariff language is changed to

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 30 kVA or less.

Proposal 8.i: Non-export projects must be evaluated for all screens ProposalNon-export projects must be evaluated for all screens

Statusdependent on resolution of policy considerations (above). DiscussionScreen I (“Will power be exported across the PCC?”) essentially asks whether a project is export or non-export. Currently, if a project passes Screen I, it is allowed to bypass Initial Review Screens J, K, L, and M. Consequently, it also is not required to undergo Supplemental Review as long as it also passed Initial Review Screens A-H. The WG discussed whether non-export projects, which pass Screen I, should be required to be evaluated under Screen M, as non-export projects still have an impact on minimum loading conditions, which is tested under Screen Msubsequent screens.

The IOUs perspective is that, as levels of DER penetration are increasing in the distribution system, the level of ICA margin at various parts of the distribution system are diminishing to the point at which non-export projects which remove load from the system can potentially adversely affect the safety and reliability of the distribution grid by causing overvoltage conditions and possible overloads. In order to insure that all DERs are connected to the grid in a safe and reliable manner, an adequate level of technical evaluation needs to be performed. This includes evaluating how non-export projects may affect the ICA parameters, including thermal, voltage, and protection.

Tesla suggests a counterproposal 8.ix detailed in Appendix X. Stakeholders supporting Tesla’s counterproposal include X, Y, and Z.

The WG agrees this proposal cannot be resolved in isolation. It must be considered in the context of the “Policy Consideration” identified above.

Proposal 8.j: Apply Screen J to Projects Larger than 30 k Va ProposalApply Screen J to Projects Larger than 30 kW.

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StatusConsensus.DiscussionThe existing Screen J asks, “Is the gross rating of the generating facility ≤ 11 kVA?” If a project passes this screen it is then allowed to bypass Screens K through M. The WG agreed that this should be expanded to 30 kVA, to allow standard NEM and other small projects bypass Screens K through M and maintain the goal of streamlining the interconnection process for small projects. . It is not anticipated that projects below 30 kVA would be likely to raise any safety or reliability concerns if they skipped screens K through M.

Proposal 8.k: Screen L should be modified to include the transmission overvoltage and transmission anti-islanding test.ProposalScreen L should be modified to include the transmission overvoltage and transmission anti-islanding test. This proposal is PG&E (only).

StatusNon-consensus

DiscussionThe existing Screen L (Transmission Dependency and Transmission Stability Test) tests whether the interconnection request is made in an area where there are known or posted transient stability limitations, or the proposed generating facility has interdependencies known to the utility with earlier-queued transmission system interconnection requests. The ICA does not identify the results of Screen L, because the analysis is not conducted up to the transmission level. However, PG&E contendsWG discussed that there are some areas where utilities have identified known transmission deficiencies that will impact the application of ICA.

Currently, Screen M (“Is nameplate generation > 15% of peak load?”) tests for minimum loading conditions and identifies which projects should proceed to Supplemental Review. It was identified that some protection tests are currently identified within Screen M that should instead be evaluated under Screen L. These protection tests evaluate traditional anti-islanding (when the ratio of machine-based synchronous generation to inverter-based generation is over 40%) and transmission overvoltage (when a transmission breaker opens on a substation that has an ungrounded high side). This 50% min load screen was also identifying when projects should undergo more detailed protection tests which are currently performed in Supplemental Review such as traditional anti-islanding (when the ratio of machine-based synchronous generation to inverter-based generation is over 40% and 50% min load for aggregate generation) and transmission overvoltage (when a transmission breaker opens on a substation that has an ungrounded high side. The WG identified that these transmission protection screens are not incorporated into ICA therefore modifying Screen M with ICA meant that these screens need to be captured elsewhere. The WG proposed that these screens be identified in Screen L because L is also evaluating transmission. The benefit here is that this evaluation is conducted in Initial Review instead of Supplemental.

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PG&E proposes that the traditional anti-islanding test and the transmission overvoltage test should be evaluated in Screen L.

DER stakeholders contend that PG&E is misinterpreting the risk of anti-islanding failing to work. For Issue 8, these stakeholders oppose PG&E’s proposal not to use ICA values on circuits with machine-based synchronous generation.

It is noted that there is some overlap in this topic with Issue 18 (“should the Commission adopt changes to anti-islanding screen parameters to reflect research on islanding risks when using UL 1741-certified inverters in order to avoid unnecessary mitigations? IF yes, what should those changes entail?”). Working Group Four, tasked with Issue 18, is scoped to consider changes to the existing anti-islanding test while this Issue 8 proposal is moving this evaluation from Supplemental Review to Screen L in the Initial Review. Note however that detailed evaluation of Screen L failure requires detailed study vs. Supplemental Review.

Proposal 8.l. Provide Earliest Available Indication where Screen L Failure is Likely

ProposalWhere there are known transmission deficiencies likely to cause projects to fail Screen L, indicate as much through ICA maps (preferably) or an alternative means identified herein .

StatusConsensus/non-consensus?

DiscussionThe WG discussed how identifying locations where certain pre-existing grid conditions exist would be useful for developers in understanding where they may fail Screen L. These conditions are:

● fused high side of substation transformer● existing direct transfer trip or hard wire tripping scheme ● synchronous generators present

Identifying where projects are “likely to fail” upfront will facilitate the transparency, predictability and streamlining of the interconnection process by allowing developers to make informed development choices. Thus, this proposal would provide more information for developers but is not an “actionable” number.

PG&E proposes to list this data with other feeder summarized data such as (feeder name, circuit voltage, customer counts, generation totals, etc.) PG&E proposes two fields to help identify locations that could be of concern for screen L:

Substation High Side Fuse: Y/N Substation DTT/Hard Wire Trip Installed: Y/N

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As part of a potential future enhancement to SCE maps, SCE is evaluating the feasibility of displaying locations where projects would likely fail Screen L. If and when this capability and information is available, SCE would display this information along with the ICA values in the interconnection maps.

SDG&E does not support this proposal.

Proposal 8.m: Screen M should be modified to reflect ICAProposalScreen M should be modified to reflect ICA

StatusConsensus/non-consensus?

DiscussionThere was much discussion in the working group about the different treatment of the ICA with Operational Flexibility (ICA-OF) and the ICA for static grid conditions (ICA-SG). Operational flexibility3 is evaluated through the “safety and reliability” criterion in the ICA. As explained in the ICA Working Group Report, unlike the other three criteria evaluated by the ICA (thermal, protection and voltage), the Group was not able to identify a method of measuring unreasonable limitations on operational flexibility that did not rely on a conservative proxy (or “heuristic”). The safety and reliability, or operational flexibility, criteria thus used a measurement of whether there would be any reverse power flow back to the substation low-side bus as a substitute for actually evaluating all the potential reconfigurations. What this results in is a screen that is relatively conservative (i.e. leaving much more operational flexibility than is necessary for safe and reliable operations in many cases). It is for this reason that the ICA Working Group asked for the creation of an ICA with operational flexibility and one without. Since the ICA is made up of four separate criteria, when the “safety” criteria is the most limiting factor at a particular point that will be shown as the ICAWOF, if one of the other criteria is the limiting factors then that will show as the ICA limit which will be used in Screen M.

Building on this understanding, the WG discussed whether a buffer was needed for ICA-OF or if was only necessary for ICA-SG. Stakeholders agree that a buffer to reserve some actual hosting capacity is reasonable to ensure against loading conditions changing soon after hosting capacity is used, but disagree on the size of the buffer and its applications. A larger buffer risks leaving too much hosting capacity unused; a smaller buffer risks interconnecting more generation than can be accommodated without impacts to safety, reliability or upgrades.

Currently, these risks are addressed by Screen M (“is the aggregate Generating Facility capacity on the line section less than 15% of line section peak load for all line sections bounded by automatic sectionalizing devices?”), which approximates whether the generation capacity is less than 50% of minimum load. ICA calculations are based on 100% of minimum load. It was identified that concerns about the creation of unintentional islands and the need for upgrades may be triggered when the aggregate generation on a line section exceeds the minimum load.

3 For a discussion of what operational flexibility means in this context please see page 25 of the ICA Working Group Report. [add link]

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IOU Proposal:

The IOUs suggest a hybrid approach, applying a a 20% buffer to the ICAWNOF and no buffer to ICAWOF. Under this proposal, when the ICAWNOF and ICAWOF are separated at each hour by more than 20%, (as depicted in Figure 1) the following would occur:

Operational flexibility would be evaluated with the ICAWOF. If Interconnection request is greater than ICAWOF, then IR would be sent to the SR for further evaluation

Safety and reliability (thermal, voltage, PQ and Protection) would be evaluated against the ICAWNOF with 20% buffer curve.

Figure 1

When the ICAWNOF and ICAWOF are NOT separated at each hour by more than 20% (Figure 2) then the following would occur

Operational Flexibility, Safety and reliability (thermal, voltage, PQ and Protection) would be evaluated against the ICA with 20% buffer curve.

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Figure 2

The IOUs propose that the Screen should be changed to:

The Interconnection request for uniform generation is less than 80% of the ICAWNOF ICA values or 100% of ICAWOF values. If screen fails, project is further evaluated under the supplemental review

Further, they propose if a project is interconnecting to an area of the system without ICA such as transmission-level, the project is evaluated against 15% peak load. If ICA is not available due to customer confidentiality, ICA will still be used, with certain details withheld consistent with the 15/15 rule for aggregating customer data.

If a project fails Screen M, it is sent to Supplemental Review to further study the project which may include evaluating the impact on the operational flexibility of the system, thermal, protection, and power quality, including studying probable switching configurations.

Counter Proposals

CALSSA proposes that the ICA values for certain constraints be devalued by ten percent to provide a buffer for potential future loss of load on the circuit segment. This may apply only to the thermal constraint.

Clean Coalition proposing basing the buffer on Total ICA value (including existing DER), not the remaining ICA value. On this basis a 10% margin may be appropriate.

GPI suggests a buffer of 90% or higher.

These proposals are detailed in Appendix X.

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Proposal 8.n: The Commission should adopt additional Initial Review Screen F1ProposalGenerating systems with 1.2 p.u. short circuit contribution can reference the ICA value for meeting the reduction of reach ICA protection screen. For generating facilities with short circuit current contribution greater than 1.2 p.u. SCE will use the protection ICA value at the point of interconnection in conjunction with the project specific p.u. short circuit contribution to determine if it passes Screen F.1

If the project screen fails Screen F.1 it must be evaluated under supplemental review for impacts to reduction in reach.

Screen F1 will be a part of the Initial Review process, reviewed concurrently with Screens A-H.

StatusConsensusDiscussionThe ICA assumed 1.2p.u short circuit duty contribution for inverter-based technology. [need further explanation here]

The ICA did not evaluate synchronous or induction generation facilities. Thus, an additional screen is proposed to evaluate whether a DER’s short circuit duty contribution is less than or equal to 1.2 p.u;. If it is, the DER passes Screen F1; if not, the application fails the Screen and may need to be evaluated under Supplemental Review for impacts to reduction of reach.

Proposal 8.o: The Commission should adopt additional Supplemental Review Screen M2. The IOUs are required to develop <API? Translator?> Proposal

StatusPending? DiscussionICA for uniform generation is agnostic of DER technology type. If a project fails Screen M, the WG agrees that applicants should have the option of providing an Typical Output Generation Profile, to be evaluated against the ICAWOF (w/ or w/out 80% buffer?). This evaluation determines that the 576 hour Typical Output Profile does not exceed 80% for each of the 576 hours evaluated in ICA. This allows the project to be reviewed using ICA within the Fast Track process under Supplemental Review, without going to Detailed Study.

To translate project-specific inputs into a Typical Output Profile, the WG recommends that...

Proposal 8.p: Changing Supplemental Review Screens Proposal

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Status?DiscussionLanguage of supplemental review screens should reflect that they are evaluating op-flex considerations

Proposal 8.q: Screen P should be modified ProposalAdd an item to the list of factors that may affect the nature and performance of an interconnection (G.2.c):

Advanced inverter functionality and settings

Add an example of an item that may be considered under this screen (G.2.c):

Will the proposed system cause any voltage impacts considering the settings of the Volt-Var function and the characteristics of the circuit segment?

StatusConsensus

Discussion

A project that exceeds ICA-OF (Screen M) will go to Supplemental Review for consideration of upgrades.

If it exceeds the voltage constraint but no others, utilities will need to assess whether it has any voltage impact.

If x/r ratio is high, Volt-Var will be highly functional and the project can be interconnected without upgrades.

Proposal 8.r: The Interconnection Application should have an option to combine Initial Review and Supplemental Review, with applicants pre-paying for Initial Review and Supplemental Review ProposalCustomer projects exceeding 1) 30kVA for exporting projects, or 2) 500 kW for NEM projects, or 3) the posted ICA value, will fail Initial Review under Screens, I, J, K, L and the modified Screen M. As such, any customer that believes that it is likely to fail IR, because it exceeds these amounts, will be provided an option to go through IR and SR as a combined study process, skipping the IR results meeting and thus saving significant time and IOU engineering hours

StatusPending; GPI proposed, others supported, IOUs taking back for consideration Consensus

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DiscussionWhile the ICA serves as a guide for projects to better understand whether they may pass Fast Track, there is the potential that projects over ICAWOF may still pass Fast Track after being evaluated under Supplemental Review for operational flexibility concerns or other ICA violations,, or after small modifications are made during the Fast Track process. The WG identified that some larger projects, and particularly exporting projects (as described above), have a high likelihood of failing Initial Review and proceeding to Supplemental Review. In addition, many projects can pass Supplemental Review after failing Initial Review, and thus still pass Fast Track.

Supporters of the proposal recommend adding an upfront option on the interconnection application to pre-pay for Supplemental Review, alongside paying for Initial Review. Applicants and the utility would benefit from additional time savings by opting to skip the Initial Results meeting. The applicant would still need to pay both fees for IR and SR and the project is still reviewed under both the IR and SR screens except for the IR screens made redundant by the SR (Screen M, for example, is made redundant by Screen N). Fees and timelines for this combined study process may be adjusted as efficiencies are realized as part of the Working Group’s future efforts.

In discussing this proposal, project developers were asked how often they take the option to review the Initial Review results report and schedule an Initial Review results meeting with the IOU engineers. A number of developers, including Sunworks, Sunpower, Tesla and CalCom Energy responded, giving a range anywhere from 0-50% of projects electing to take the Initial Review results meeting before heading to Supplemental Review.

Proposal 8.s: Rule 21 tariff should adopt new timelines that reflect additional efficiencies driven through the incorporation of ICA, <better enforce timelines>, and reduce interconnection fees. Proposal

StatusPending (CALSSA proposed, follow-up discussion needed) DiscussionIn reviewing IOUs’ typical Rule 21 timelines, it was identified that some processes may need better-defined timelines, and others may need shorter timelines, as using ICA is expected to streamline the process.

Supporters of the proposal recommend that <enter recommendations>

To account for the reduction in review time, supporters of the proposal also recommend that fees should be adjusted to <enter recommendations>

<Enforcement and additional reporting recommendations>

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Proposal 8.t: Queue managementProposalRequire identification of intended off-taker in the interconnection application; establish an expiration date for the interconnection agreement for non-NEM projects; tighten deadlines; require justification for extending Commercial Operation Date; allow small projects to interconnect if they do not impact larger projects that are in front of them in the queue

StatusNon-consensus

DiscussionCurrently, some DER developers apply for interconnection before they have a counterparty to buy the energy. This has been necessary because energy purchasers, such as Community Choice Aggregators or direct access customers, have requirements for participants in their solicitations to have an interconnection agreement. Those purchasers want to have confidence that a winning bidder will develop will be able to build the proposed project.

The downside of this is that developers that do not win the bid in their intended solicitation have a project with no buyer and are motivated to sit on the reserved grid capacity for as long as it takes to find another buyer. This comes at the expense of customers that want to invest in behind the meter DERs in locations where there is not enough existing capacity for their projects in addition to previously queued projects. Developers of behind-the-meter systems always have a counterparty because they are designing a system for installation on a customer’s property.

The current milestones in Rule 21 include the following.

Developer must have “site exclusivity” – own or lease the land or have an agreement for such – at the time of application.

Developer must pay a deposit for the interconnection study. There is no firm deadline for payment of this deposit. After ICA is made available there may be very large projects that go through Fast Track, which would greatly diminish the significance of this step.

After agreeing to pay upgrade costs, if any, the utility sends a draft interconnection agreement to the developer within 15 business days and the developer has 90 calendar days to negotiate changes and sign the agreement. The agreement includes schedules for work to be completed by the developer and the utility associated with the distribution upgrades and interconnection facilities.

Developer must make good faith efforts to meet the schedules in the interconnection agreement.

If a project fails Screen R, developer has 40 business days to indicate whether they intend to be included in a Distribution Group Study. If a study window closes during that time, the project will be studied approximately six months later in the next Distribution Group Study.

Applicant has 30 business days to agree to scope of study. Developer has 60 calendar days to post initial financial security for grid upgrades and

interconnection facilities.

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Developer can propose a Commercial Operation Date that is far in the future and can request extensions of that date. Utility is obligated to approve extensions as long as the developer has paid the required deposits.

The CALSSA Proposal includes the following changes to these milestones.

1-A. Require identification of intended off-taker in the interconnection application

Currently a developer does not need who will purchase or consume the energy produced by a proposed DER. We should not expect utilities to monitor the results of solicitations, but having information on the intended purpose of a proposed DER would inform later decisions of whether to grant deadline extensions. It would also discourage developers from proposing a system when there is no identified off-taker.

1-B. Establish an expiration date for the interconnection agreement for non-NEM projects

Currently, per D.13.d, if a NEM project smaller than 1 MW is not installed within one year of approval, the project is deemed withdrawn. This same bar should exist for non-NEM and large NEM systems. Because the ICA will enable large projects to go through Fast Track, the timelines for the various pieces of the detailed study process are no longer sufficient as protection against sluggish development. A one-year deadline should be created from Fast Track approval for all projects that receive Fast Track approval.

1-C. Tighten deadlines

Developers that want to go through the interconnection process quickly often do not use the full amounts of time allowed in the milestones listed above. Projects that are intentionally moving slowly should also respond more quickly. Ideas for trimming timelines include the following. [CALSSA would like to further review each of these, but offers them in this draft for reaction from stakeholders.]

Developers must pay detailed study deposit within ten business days. Timeline for negotiating an interconnection application should be reduced from 90 calendar

days to 60 calendar days. After failing Screen R, a developer has 20 business days to decide whether to enter the Group

Study process with extension for an additional 20 days. Agreement on the scope of the detailed study should be completed within 20 business days

rather than 30. Developer must post initial financial security within 45 calendar days rather than 60.

1-D. Require justification for extending Commercial Operation Date

A developer with an approved project but no power purchase agreement should not be allowed to extend the Commercial Operation Date without having made real progress in construction. If the developer is not able to quickly find another buyer after losing a bid, they should have to resubmit and lose queue position.

Rule 21 currently states the following (PGE F.3.e.iii) [emphasis added]:

Extensions of the Commercial Operation Date will be agreed upon in the executed Generator Interconnection Agreement. Reasonable Commercial Operation Dates will be discussed at the

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DGS Phase II Interconnection Study results meeting, or the DGS Phase I Interconnection Study results meeting if the DGS Phase II Interconnection Study results meeting is waived, in the case of the Distribution Group Study Process, the Interconnection Facilities Study results meeting, or the Interconnection System Impact Study results meeting if the Interconnection Facilities Study is waived in the case of the Independent Study Process. A request for an extension of the Commercial Operation Date after the Generator Interconnection Agreement is executed will be agreed to provided that, the Producer is still responsible for funding any Distribution Upgrades and Network Upgrades as specified in the Generator Interconnection Agreement and under the same payment schedule agreed upon in the Generator Interconnection Agreement. This provision has no impact on any power purchase agreement terms.

CALSSA proposes the following change: Commercial Operation Date must be set by mutual agreement considering intended

counterparty, reasonable construction time, and grid upgrades. Developer must demonstrate progress in construction and in securing a power purchase agreement when requesting an extension. Utility will grant extensions due to construction delays or circumstances outside of the control of the developer.

2. Allow small projects to interconnect if they do not impact larger projects that are in front of them in the queue

Large projects that take more than a year to study can hold up small projects that would not impact the results of the study of the larger project. If there is 1.5 MW of hosting capacity at a location and a 5 MW proposed project is undergoing detailed study to identify needed upgrades, a 1 MW project behind the larger project in the queue should be allowed to move forward if it would not impact the extent of the upgrades needed for the larger project.

Proposal 8. u : IOU Validation Exercise ProposalComplete ongoing Quality Assurance and Quality Control efforts, leading to full and final implementation of the ICA as ordered by the Commission, before implementation of the proposals made herein.

StatusPending DiscussionGiven the complexity of ICA and that ICA production is new, the IOUs propose to begin validating the ICA methodology and the ICA update process beginning XX, 2018. These activities will continue for YY months until the implementation date for Working Group 2’s ICA proposal as directed by the CPUC.continue to

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Proposal 8.v: non-ICA related automation of Rule 21 Interconnection Procedures ProposalThat the Commission review the Automation Status and Opportunities Report (attached as Appendix 1) and provide guidance on further action within this proceeding regarding:

1) how the Working Group can schedule additional discussion of the automation opportunities identified;

2) review of the likely costs and benefits of implementing automated data processes to reduce costs and streamline interconnection processes and schedules;

3) coordination of related IOU investments in line with the Commission’s Distribution Resources Plan (DRP) precedent, the DER Action Plan, and the merits of including automation goals in the DER Action Plan or a separate automation roadmap.

Status?Non-consensus

DiscussionIn discussing Issue 8, the WG identified that certain actions that facilitate automation are not necessarily related to integration of ICA, but are part of the WG 2 scope.

Green Power Institute and Clean Coalition led the development of recommendations and identification of automation and streamlining opportunities for the Rule 21 process. The intent of the draft “automation roadmap” included in Appendix A is to form the starting point for an actionable “roadmap” for adoption by the CPUC, after additional discussion in this proceeding.

GPI and Clean Coalition, with support from Smarter Grid Solutions as engineering consultants, took the lead in drafting the proposal and solicited input from stakeholders, including IOU and non-IOU WG members, to refine the understanding of opportunities and develop recommendations. GPI and Clean Coalition had several opportunities to present their research and recommendations to the larger Working Group, and circulated the Appendix A document for written comment a number of times during the course of Working Group 2.

A summary of the most promising opportunities identified by the GPI/Clean Coalition draft proposal and resulting discussions are as follows:

• Automating the application process and completeness review • Reduce review time from 1-40 business days (BDs) to as little as 1 day for projects that

don’t require corrections• Reduce turnaround time for corrections from 10 BDs for each round of corrections to 1-

2 days with automated interconnection portals• Issue 22 has already scoped potential revisions to the interconnection portals, and this

contributes to that work• Automating (at least partially) Initial Review

• Automating analysis of refined screens toward reducing time from 15-17 BDs to 1 day for eligible projects

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• Further evaluation of costs and benefits is required• Automating (at least partially) Supplemental Review

• Reduce time from 20-22 BDs or inclusion of the SR screens in IR (no additional time required for IR) for eligible projects

• Screens N and O have been automated as part of ICA, leaving the catchall Screen P for engineering review

• Combining Initial Review and Supplemental Review [included above as a separate item]• Only applies to projects that select this option, which will generally be large NEM (over

500 kW) and wholesale projects• Timelines and fees for the combined IR/SR to be determined as part of the working

group deliberations• Frontloading and automating the GIA drafting process

• Provide template GIA to customer after application deemed complete, in order to frontload customer review of GIA terms

• Automated population of template GIA with IR/SR results so that draft GIA can be generated in 1 day rather than 15 BDs

• Work to identify additional automation and streamlining items

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