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Rule 21 Working Group Two Workshop November 7, 2018
Rule 21 Working
Group Two
Workshop
November 7, 2018
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Safety and Emergency Information
In the event of an emergency evacuation, please cross McAllister Street, and gather in the Opera House courtyard down Van Ness, across from City Hall.
Additional Information
Wi-Fi Access
• Login: guest
• Password: cpuc103118
Restrooms
• Through the courtyard, right into the lobby, and to the left through double-doors
• Through the courtyard, left into the auditorium, and to the right
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Agenda Overview
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Time Topic Presenter
10:00-10:10 Welcome and
Introductions
Judge Hymes
10:10-10:30 Issue 6 SDG&E/Stem overview
Q&A and discussion led by Judge Hymes
10:30-12:30 Issue 8 SCE/IREC/Clean Coalition overview
Q&A and discussion led by Judge Hymes
12:30-1:30 Lunch
1:30-2:30 Issue 9 PG&E/CALSSA overview
Q&A and discussion led by Judge Hymes
2:30-3:05 Issue 10 CALSSA/PG&E overview
Q&A and discussion led by Judge Hymes
3:05-3:15 Break
3:15-3:50 Issue 11 Stem/SCE overview
Q&A and discussion led by Judge Hymes
3:50-4:00 Wrap Up/Next
Steps
Judge Hymes
Issue 6
Issue 6 OverviewIssue 6 covers the contractual relationship between the utility and Rule 21 aggregatorsThe proposal included:
• Rule 21 Aggregator Agreement
• Rule 21 Participating Generating Facility – Aggregation Agreement
Aggregator
Gateway
Smart
InvertersAggregator specific
interface
EMS
(Site Controller)
Generating
Facility made up
of multiple
Smart Inverters
using EMS
ICU
(Site Controller)
Generating
Facility made up
of multiple
Smart Inverters
using ICU
Utility
IT
Communication
Network
Utility
Business
Aggregator
Business
Rule 21
Aggregator
Agreement
Communication
Network
Rule 21 Participating
Generating Facility-
Aggregation Agreement
Rule 21 Aggregator
– DER Agreement
Out of Scope
Scope of Issue 6
The Working Group focused on the following scoped items:
• Rule 21 Aggregator Definition:
“An entity that provides the communication capability functions required in Section Hh on behalf of one or more Generating
Facilities that utilize inverter-based technologies. An Aggregator is intended to perform a role that would otherwise be
performed by individual Generating Facilities. The Aggregator shall act as a conduit, sending commands from the Distribution
Provider to a Generating Facility and sending information from a Generating Facility to Distribution Provider.”
• Rule 21 Aggregator Role:
Rule 21 Aggregator to fulfill a Generating Facilities Rule 21 Section Hh requirements which covers “Smart Inverter Generating
Facility Design and Operating Requirements.”
• Section Hh.5 Communication Requirements
• Section Hh.6 Scheduling Capability Requirements
• Section Hh.7 Monitoring and Telemetry Requirements
• Section Hh.8 Control Through Communication Capabilities
• Rule 21 Agreement Articles
The draft agreement is recognized as incomplete but can serve as a basis for continued development as Rule 21 / Smart
Inverter requirements evolve. The agreement has the following articles:
• The Agreement’s applicability
• Responsibilities of the Supplier (DER Aggregator), including communications functions, cybersecurity and privacy
procedures, and dual participation restrictions
• Rights for testing and approval
• Terms and conditions
• Insurance requirements
• Confidentiality provisions
• And notice requirements
Issue 6 Overview
Rule 21 Aggregator is Software not Hardware
TCP / IP
VPN
Server OS
2030.5 LibraryProprietary
Protocol
Application Code
Firewall
IP
Gateway
IOU
Datacenter
Cloud Services Datacenter Aggregator Maintained
Software
Mini-OS
TCP/IP
VPN
Proprietary
Protocol
EMS Code
On-Site EMS
Secure Link
ModBus
To Inverter
• Aggregator provides “service”, not equipment
• References to “equipment” replaced by “service” or “function”
• Removed provisions regarding inspection of equipment or software, e.g. “Right of Access”
• Participating Generator Facilities
• Sign a separate agreement with utility
• Listed in Appendix attached to Aggregator agreement – can be changed without legal
execution each time
• Operations and Maintenance
• Communicating outages
Issue 6 Sub-group – resolved some concerns
Definition of Aggregator • Rule 21 describes Aggregator as “conduit” but Function 8 and draft agreement sounds more like executor;
affects liability among other things
• Scope and limitations of Aggregator (which pieces of communications link)
• Tesla: clarity of what agreement covers and the distinction between capabilities vs. actual use
• Distinguish from “Supplier” as the contractual entity.
• Dual participation restrictions
End-to-End testing• SDG&E proposes that, to be an eligible Aggregator, the Aggregator must first be able to demonstrate, to
SDG&E’s reasonable satisfaction that the functionality can be achieved
• End to End test procedures have not been defined; unclear when required
Processes and Structure• Forms, required information, and deposits/fees are to be developed to formalize the process of reviewing
an aggregator and executing the Rule 21 aggregator agreements
• Tesla: agreement should not be structured with evolving set of obligations or capabilities.
• Unbounded, unilateral changes to cybersecurity and privacy requirements
• SBUA: Business Continuity Plans
• SBUA: Liability insurance
• Provisions for how certification and approval of Aggregator is handled as software is changed
Is signing of Aggregator agreement required for Feb 22 deadline?
Open Issues
Questions
Issue 8
Introduction
• Introduction (Clean Coalition)
• Issue 8 has 23 main proposals, some with sub-proposals
• Grouped into 4 level of complexity
• Level 1 – Full consensus (Clean Coalition)
• Level 2 – Near consensus (Clean Coalition)
• Level 3 – Non consensus – Divergent Views (SCE)
• Level 4 – Non consensus – Significant Divergent Views (IREC)
• Q & A
Level 1 - Consensus Proposals
8.a – Remove existing Fast Track Eligibility Limit
Concept: Informed by the ICA, this will allow an applicant the option to select Fast Track as their preferred
study track for a project of any size.
8.f1 – Adopt additional Initial Review Screen F1
Concept: Add Screen F1 to the Initial Review to screen whether the generating system’s short circuit
contribution exceeds 1.2 per unit.
Modification #1 for 8.f, 8.g, 8.h, 8.j – Apply these screens only to projects larger then 30KV
Concept: Raise the existing exemption for Screens F, G, H, and J from the current threshold of 11kVA to 30 kVA
(raising above 30 kVA did not have consensus)
8.q – Modify screen P
Concept: Update Screen P to account for new smart inverter capabilities.
8.r – Option to combine Initial Review and Supplemental Review
Concept: Customer option to combine the Initial Review and Supplemental Review processes when both are
likely needed, thereby increasing the efficiency of the overall process.
Level 2 - Near Consensus
(Low opposition or supported with qualifications)
8.b- Initial Review process to include verification and explanation of updated ICA to customer.
Concept: The IOUs will modify their Initial Review processes to incorporate an additional run of the specific
node/feeder ICA where updated ICA values may be required, because monthly ICA values can become of date.
If needed, the update will be completed within the Initial Review timeframe. The IOUs will implement this
proposal as part of their review under Screen M. Different approaches to implementing this proposal are
suggested by different IOUs.
8.c – Track when ICA values are updated outside of the required monthly updates
Concept: The IOUs will track when the ICA is updated leading to Interconnection Requests failing Initial Review.
(see 8.b)
Level 2 - Near Consensus
(Low opposition or supported with qualifications)
Modification #2 for 8.f, 8.g, 8.h, 8.j – Provide earlier indication where screen F and G failure is likely
Concept: To provide an early indication of whether a project is likely to face challenges related to Screens F &
G.
The Working Group determined that ICA does not provide a complete indication whether a project will
pass or fail these Screens, and that it may be practical though other means, but did not agree on the best
way to address this.
8.l- Provide earliest available indication where screen L failure is likely
Concept: The IOUs will post an indication of potential Screen L results on ICA maps, related to transmission
dependency, stability, overvoltage and anti-islanding.
8.n – Update to Screen N methodology
Concept: Update Screen N to allow the evaluation of thermal overload, steady state voltage deviation, and
protection reduction-of-reach when the Interconnection Request fails Initial Review due to exceeding the ICA
values or Screen F1. This evaluation will also account for the default Volt-Var settings for inverter-based
Generating Facilities.
Level 3 - Non Consensus – Divergent Views
Proposal 8.d – Modification of projects if ICA values are out-of-date to stay under ICA limits and maintain queue position
Concept: Applicant who apply based on information on the ICA map should have the ability to make
modifications (such to reduce to be under the ICA value) if the ICA value has been updated such that it fails
the Initial Review.
Supporting Arguments:
• Fairness to customers that use published information without knowing that such information is
outdated
Opposing Arguments:
• The proposal adds complexity to a Fast Track process that is intended to be “Fast” especially
when multiple requests are received within a month where some project will have to be delay
pending decision on earlier queued projects
• Currently there is no data to support this level of increase complexity because especially given
that customers have to make a decision within 10 days
• Proposal only transfers the issue to other projects which may have also used the same data in
their requests
• Proposal transfer the cause-causation principle that is currently in the rules
• Proposal complicates the monthly ICA update that is required
Level 3 - Non Consensus – Divergent Views
Proposal 8.m – Screen M should be modified to reflect ICA
Concept: Utilize the ICA values which have been generated using
power-flow simulations to determine the limits on thermal,
voltage, PQ, protection and safety. These values will be updated
in a monthly basis as required by DRP decision on track 1 (14-
08-013) and can be used to expedite the interconnection
process for projects which are under the calculated ICA values
Option A
a Use 90% of the lowest value in the ICA-SG 576 profile
Using Nameplate
b Use 100% of the lowest value in the ICA-OF 576 profile
c Use 90% of any hour value on the ICA-SG 576 profile
Typical PV-Output Profile
d Use 100% of the lowest value in the ICA-OF 576 profile
Option B
Typical PV-Output Profile
d Use 100% value of any hour in the ICA-OF 576 profile
Option A or B
Implementation Variation #1 – Remove buffer for
protection ICA value for “a” and “c”
Implementation Variation #2 – Apply the buffers as part of
the ICA development to all the use of values without need
to adjust in the interconnection process
Level 3 - Non Consensus – Divergent Views
Proposal 8.m – Screen M should be modified to reflect ICA
Difference: 8.m (d) – use 100% at any hour vs 100% of the lowest value on the ICA-OF profile
Supporting Arguments:
• Usage of the 100% of the lowest ICA-OF value creates a enormous buffer for typical PV profiles
• The IOUs have agreed to evaluate proposals against that hourly and seasonal data for ICA-SG but are
proposing not to use hourly and seasonal data for ICA-OF
• 100% of the lowest value is much more conservative than 90% of hourly values.
• The ICA is a tool that is being invested in by the IOUs and it should be used as much as possible to derive
maximum efficiency for Rule 21
Opposing Arguments:
• While ICA looked at normal operations (ICA-SG) and Operational flexibility (ICA-OF) that accounts for switching
between circuits, ICA-OF did not account for internal circuit switching which if ignored can lead to safety and
reliability issues . An example of this configuration change is shown on the figure in pg. 71
Proposal 8.i: Consider Applicability of Screen I for Non-exporting Projects Above 30kVA - Non-consensus
Option A: Relocate Screen I to the Rule 21 technical framework overview so that non-exporting projects above 30 kVA are reviewed under
all Screens. Supported by PG&E, SCE, SDG&E, TURN.
• A DER penetration increases, 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.
• An adequate level of technical evaluation is needed for non-export projects, including reviewing thermal, voltage, and protection.
• Option A could result in new costs for interconnecting non-export projects. Option A would observe the existing cost responsibility
rules in Rule 21 Section E.4.
Option B: Do not relocate Screen I, continue to allow non-exporting projects of all sizes to skip Screens K, L and M. This is status quo, with
the expectation that the issue will be reviewed in Phase 2 of this proceeding or through some other docket as appropriate. Supported by
CALSSA, IREC, GPI, Clean Coalition, Stem, Public Advocates Office.
• Customers change their demand for many different reasons, subjecting non-exporting projects to screens as a result of departing load
would discriminate between projects depending on how they reduce their load and would suggest that customers have an obligation
to “guarantee” their load.
• Utilities are still able to review the technical impacts of departing load from non-export projects in the same way they do for projects
using energy efficiency, reducing operations, or going out of business.
• Utilities have indicated that to-date this situation has never arisen - Screen I should stay the same until the Commission considers cost
allocation issue in later phase or in other forum.
Level 4 - Non- Consensus Proposals – Significant Differences
Rule 21 Flow Chart Contrast to Demonstrate Screen I placement
Screen I
Screen I
Proposal 8.s: Reduce Interconnection Application Fee for Non-NEM Systems – Non-consensus
Currently an $800 application fee applies to non-NEM systems of any size, NEM projects below 1 MW pay a fee based on
actual utility costs (currently less than $200).
Both Option A & B are opposed by PG&E, SCE, SDG&E, TURN
Option A: Change the application fee for non-NEM systems smaller than 1 MW to match the application fee for NEM
systems. Supported by CALSSA and GPI.
• Pro: Because for non-NEM systems smaller than 1 MW require roughly the same amount of work to process as NEM
systems, they should pay application fees at the new NEM level rather than the full $800.
• Con: For NEM projects, the overall average cost is based on thousands of residential NEM systems that average about 8
kW. For these projects, Screens F, G, H, and E are not evaluated. Non-export storage projects up to 1 MW require an
evaluation of those screens and potentially an evaluation of loading profiles, thus they are not comparable.
Option B: Review actual costs and determine whether a $300 fee is appropriate for significant application categories.
Supported by Clean Coalition and IREC.
• Pro: The fee collected should reflect actual average costs, and these costs should be determined. Projects up to 1 MW
may have greater average costs than small NEM, but it should be calculated.
Level 4 - Non- Consensus Proposals – Significant Differences
Proposal 8.k: Modify Screen L to Include the Transmission Overvoltage & Transmission Anti-islanding Test – Non-consensus
• Option A: Screen L should be modified to include a transmission overvoltage and transmission anti-islanding test
proposed by PG&E.
• Option B: Screen L should be modified to include only a transmission overvoltage test.
• Option C: Screen L should be modified to temporarily allow application of anti-islanding tests, as defined in writing by
utility guidance documents, until the questions raised in Issue 18 can be addressed more thoroughly.
Summary of Positions:
• PG&E currently conducts anti-islanding screening in Supplemental Review for projects that fail 15% of Peak Load Screen
(M), with modifications to Screen M to use ICA, projects may pass without going through the anti-islanding screening.
They propose to now apply the anti-islanding screening as part of Screen L through a reference to their currently
published guidance. Guidance would evaluate when the ratio of machine-based synchronous generation to inverter-
based generation is over 40% and aggregate generation is greater than 50% of min load. SCE and SDG&E do not
currently screen for anti-islanding but would like to retain the option to and would publish a guidance document if so.
• CALSSA believes research does not support adoption of a screen – note the substantial costs of DTT.
• IREC believes anti-islanding screening in Screen L should be temporary until Issue 18 is resolved.
All parties appear to support addition of Transmission Overvoltage Test: when a transmission breaker opens on a substation
that has an ungrounded high side and aggregate generation is greater than 50% of min load.
Level 4 - Non- Consensus Proposals – Significant Differences
Proposal 8.t: Queue Management – Non-consensus
Opposed by PG&E, SCE, SDG&E, GPI, TURN
Option A: Require justification for extending Commercial Operation Date; tighten deadlines; and allow small projects to interconnect if they
do not impact larger projects that are in front of them in the queue. Supported by CALSSA, IREC, Clean Coalition (qualified).
• For a variety of market and procurement program reasons, developers of wholesale, FOM projects often apply for IC before they have a
PPA, secure financing, environmental permits, and other hurdles. This can result in projects holding the reserved grid capacity for as long
as it takes to find a buyer or line up other elements. This can cause delays for later-queued projects. The implementation of the ICA
may exacerbate this situation.
• Proposal is to implement various requirements to deter queue sitting including requiring justification for extending CODs, tightening
deadlines, and allowing small projects to connect if they do not impact larger queued-ahead projects.
Option B: Modified Option A with alternative approach to extending Commercial Operation Date to continue to allow for negotiation of
deadline. Supported by GPI, Tesla
IOUs Oppose both Options:
• PG&E believes some aspects may be beneficial but needs more discussion to ensure proposals and timelines work.
• SCE notes any recommendations relying on changes to the WDAT are misplaced and proposes various other changes to timelines and
opposes allowing smaller projects to connect ahead of earlier queued projects.
Level 4 - Non- Consensus Proposals – Significant Differences
Proposal 8.v: Additional Automation and Streamlining Opportunities – Non-consensus
Supported by GPI, Clean Coalition, Stem Opposed by PG&E, SCE, SDG&E, TURN
Proposal is for the Commission to consider the Interconnection Automation and Streamlining Opportunities report
(attached as Appendix A) and provide guidance on further action within this proceeding regarding:
1) how future Working Group schedules can include 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 precedent, the
DER Action Plan, and the merits of including automation goals in the DER Action Plan or a separate automation
roadmap.
Opposition:
• TURN opposes the inclusion of the report from Smarter Grid Solutions. TURN’s perspective is that the proposal needed
to be supported by a high-level cost estimate of automation opportunities. Does not want this to be viewed as a
Roadmap.
• IOUs appreciate consideration of automation but believe development and implementation of such IT tools will require
time and cost, also disagree with the ease of implementing many of the specific steps.
Level 4 - Non- Consensus Proposals – Significant Differences
Questions
Issue 9
Issue 9 Overview
Issue 9 OverviewWorking Group Proposal
IOU Counter Proposal
Questions
Issue 10
Issue 10 Overview
Issue 10 has 8 proposals (2 consensus and 6 non-consensus)
Proposal Description Status
1 Assign a project manager for interconnection requests greater than 100KW Non-consensus
2 Use of a single Project Identification Number Consensus
3 For a project studied under Rules 2, 15 and 16, the customer shall be informed of the start date
of that study
Consensus
4 Engineering advance or the facility costs process within 5 BD of IA Non-consensus
5 Schedule a mitigation work scoping meeting process Non-consensus
6 Design and cost estimation must be completed within 60 business days Non-consensus
7 Construction of interconnection completed within 60 business days Non-consensus
8 The utility shall send a detailed reconciliation of the costs of interconnection facilities and
distribution upgrades, with refund of any amount paid in excess of actual costs, within 6 months
of project completion
Non-consensus
Questions
Issue 11
Introduction
• Introduction (Stem)
• Proposal A & B1 (SCE)
• Proposal B2 & B3 “Vision” (Stem)
• Proposal C (Stem)
• Q & A
OIR Issue 11 -IntroductionIssue 11 Question:
Should the Commission adopt a notification-based approach in lieu of an interconnection application for non-exporting storage systems that have a negligible impact on the distribution system? If so, what should the approach entail?
Issue 11 Objective: Expedite interconnection applications for non-export storage systems
Proposal broken into a “short Term” and “Long Term”
Short Term:• Proposal A - Formally implement the process improvements that were tested in the non-exporting
energy storage pilots in the standard Fast Track process for all storage applications which fit the pilot criteria
• Proposal B1 –Implement the Lightning Review Phase I as described in the Issue 11 report
Long Term:• Proposal B2 – Undertake a study and design of Lightning Review for projects larger than 30KVA
• Proposal B3 – Perform pre-studies similar to ICA allow the application of lightning review to be location specific
• Proposal C – Re-scope issue 25 to perform research and report what circumstances, configurations, lessons, and changes would be needed to be adopted in Rule 21 to effectuate a notification-based approach
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Proposals - A Proposal “A” - Concept:
Direct each utility to formally implement all successful process improvements that were tested in the non-exporting energy storage pilots (Rule 21 Section N.) in the standard Fast Track process flow that fit pilot criteria.
Supporting arguments:
• Permanently implement the Expedited Storage pilot that created streamlining interconnection opportunities for storage projects meeting Rule 21 Section N criteria.
Opposing argument:
• No opposing arguments to this proposal
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Proposals – B1
Proposal B1 - Concept:Implement the Lightning Review Phase I as described in the Issue 11 report for generating facilities under 30KVA in the steps described below:
• Application deemed complete – Uses equivalent NEM tools and process to expedite review of information, forms, documents
• Frontloading of the Generation Interconnection Agreement • Evaluation of technical review screen equivalent to NEM technical review• Inspection/Testing for Permission to Operate where on-site review would generally not be required
Supporting arguments:
• These projects can use the already utility expedited process that is used in the NEM program
• Provides short term solution to systems which don’t materially impact the grid
Opposing argument:
• Increasing the scope of the proceeding is not appropriate
• It is more cost effective to general program of expediting all interconnection given the low volume of this type of project
• Upgrading the standards portals can be expensive
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Proposals – B1 (Implementation Modification)
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Implementation Modification:
Non-IOU stakeholders propose that the Lightning Review process as part of Proposal B1 be expanded to include all
generating facilities with aggregate gross nameplate inverter rating under 30KVA regardless of whether those systems are
exporting or non-exporting.
Supporting arguments:
• For projects under 30KVA aggregate inverter rating, there is no difference between what is already done for
NEM as what would be done for exporting or non-exporting systems
• Provides the benefit of expedited process to all technologies not just non-exporting storage
Opposing argument:
• Jurisdictional issues must be addressed given that exporting non-NEM projects must be a QF
• Exporting systems are assigned a queued position which may create complexity in the process
• Not in scope in issue 11 with issue discussed in last working group meeting without opportunity to evaluate
Longer-term Vision (B2, B3 Proposals)
Vision: Lightning Review is ultimately an interconnection process streamlined as much as possible for the broadest range of non-exporting interconnection applications. This is based on providing information before application, minimizing paperwork round trips, and making steps automatable.
Proposal “B2” Objective:
Increasing the project size eligibility to a single number greater than 30kVA as the new standard that applies to most areas of the grid. Below 30 kVA still eligible anywhere on the grid.
• Increasing project size eligibility will allow for many more projects to be streamlined.
• Smallest first step expansion of eligibility based on ICA-like pre-study of the grid. (Current ICA doesn’t apply to non-exporting projects)
Utility Concern: Increasing size threshold will bring upon safety and reliability concerns and risk to utilities
Proposal “B3” Objective:
Utilities conduct ICA-like study to produce and publish location-specific eligibility numbers. This should significantly expand the number of projects eligible for Lightning Review from the B2 study.
Utility Concern: Creating an ICA-like pre-studied result process will be significant and cost impact needs to be evaluated.
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Proposal- CProposal C Objective:
In lieu of addressing Issue 25, the scope of Working Group 4 is amended to research and report what circumstances, configurations, lessons and changes would need to be adopted in Rule 21 to effectuate a notification-based approach.
Supporting Argument:
• Stakeholders would want Issue 25 amended because proposal “A” is addressing Issue 25 objective. Proposal “A” may permanently adopt the Expedited Storage Process Pilot in Rule 21 Section N.
Opposing Argument:
• Issue 25 can be removed from OIR
Issue 25 Refrence
“Should the Commission make any revisions to the expedited process for eligible non-exporting storage facilities in response to pilot program data collected by the Utilities between July 1, 2017 and June 30, 2018, in order to support tariff principles of technology neutrality and consistency across the Utilities?” (from the Scoping Memo of Assigned Commissioner and Administrative Law Judge, dated August 15, 2018.)
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Questions
