Details for: PGE AL 5449-E.pdf

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Erik Jacobson
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3585

December 20, 2018

Advice 5449-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

Proposal for the Rule 21Technical Requirements for Smart Inverter
Working Group Phase 2 Functions 4 and 7 Pursuant to Resolution E4898 Ordering Paragraph 8

The purpose of this advice letter is to discuss a proposal concerning the Rule 21
technical requirements for Smart Inverter Working Group (SIWG) Phase 2 Functions 4
and 7 and a report on consensus and non-consensus issues in accordance with
Resolution E-4898, ordering paragraph 8. 1
On September 22, 2011, the Commission2 initiated Rulemaking (R.) 11-09-011 to
review and revise Rule 21 governing the interconnection of generation and storage
facilities to the investor-owned utilities (IOUs)3 electric distribution systems.
In early 2013, the SIWG was formed by parties of R.11-09-011 to develop proposals to
take advantage of the new, rapidly advancing technical capabilities of inverters.4 In
March 2016, the SIWG completed its first set of recommendations for the Phase 3
advanced functions.5

Resolution E-4898. Approval, with Modifications, of Request for Modifications to Electric Rule
21 Tariff to Incorporate Smart Inverter Phase 3 Advanced Functions in Compliance with
Decision 16-06-052.
California Public Utilities Commission or CPUC.
The IOUs consist of Pacific Gas and Electric Company (PG&E), Southern California Edison
Company (SCE), and San Diego Gas & Electric Company (SDG&E).
Inverters convert DC generation to AC to allow for interconnection with the IOUs’ electric grid.
SIWG Phase 3 DER Functions: Recommendations to the CPUC for Rule 21, Phase 3
Function Key Requirements, and Additional Discussion Issues, Issued March 31, 2017. The
SIWG’s Phase 1 and Phase 2 recommendations were incorporated into Rule 21 in April 2015
and April 2017.


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Advice 5449-E -2- December 20, 2018 The SIWG Phase 3 advanced functions recommendations identified eight smart inverter functions to improve the performance of the electric grid. Relevant to this Advice Letter are the two Phase 3 functions: Function 4. Set Active Power Mode: This function establishes the active power that a DER or a system of DERs can produce or use; and Function 7. Dynamic Reactive Support: This function is similar to the Volt-Var Function from Phase 1. However, instead of modifying reactive power in response to the steady-state voltage level, this function responds to the rate of change in voltage. Please note that voltage disturbances such as flicker are sub-second event and their correction may require sub-second time frame response to be effective. At this time, most of the current inverter response rates are slower than this time frame. So they may not be capable of providing this function effectively at this time. Hence, additional standard development, product design, and testing for this function may be required. On June 23, 2016, the Commission’s Decision (D.) 16-06-052 directed the IOUs to submit revisions to Rule 21 setting forth any agreed-upon technical requirements, testing and certification processes, and effective dates for the Phase 3 functions in Tier 3 advice letters no later than six months from the effective date of D.16-06-052. In the absence of consensus, the Commission directed the IOUs to file a work plan and an outline of next steps for tariff development. On December 20, 2016, the IOUs jointly submitted AL 4983-E that provided a work plan and an outline of next steps for tariff development including a status update on the activities outlined in the work plan by March 30, 2017. On August 18, 2017, pursuant to D.16-06-052, PG&E submitted its AL-5129-E6 proposing Rule 21 tariff revisions that set forth agreed-upon technical requirements, testing and certification processes, and effective dates for the smart inverter Phase 3 advanced functions. In addition, the Advice Letters proposed revisions to the smart inverters Phase 2 communications in the Rule 21 tariffs and mandatory activation for two of the eight Phase 3 advanced functions. 6 AL 5129-E “Modifications to PG&E’s Electric Rule 21 Tariff and Interconnection Agreements and Forms to Incorporate Smart Inverter Phase 3 Modifications”
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Advice 5449-E -3- December 20, 2018 An October 25, 2017 workshop clarified that Functions 4 and 7 are “Optional Upon Mutual Agreement between Utility and Applicant” but only the function capabilities are required. E-4898 also concluded, “the capability for Functions 4 and 7 is required for all new inverter-based Rule 21 interconnections…7.” On April 26, 2018, the Commission adopted Resolution E-4898 which, in part: i) approved the tariff revisions for Function 4 and Function 7 as proposed in AL 5129E; ii) adopted a “capability” effective date for Functions 4 and 7 to be 12 months after approval of a nationally recognized standard that includes these functions; iii) directed each IOU to work with the Smart Inverter Working Group (SIWG) to clarify Function 4 and 7 technical requirements; and iv) required that the IOUs to, pursuant to Ordering Paragraph 8, “…each file a Tier 2 Advice Letter proposing revisions to Electric Rule 21 Tariff setting forth additional technical requirements for Function 4 and Function 7 and a report on consensus and non-consensus, no later than eight months from the effective date of this Resolution,” with the additional instructions that “The IOUs shall make supplemental compliance Advice Letter filings to conform their Rule 21 tariffs to the agreed-upon effective dates approved in this Resolution in Table 28.” For Functions 4 and 7 that is 12 months after approval of a nationally recognized standard that includes these functions. During the October 11, 2018, SIWG meeting, the IOUs presented potential use-cases and potential technical specifications to meet the use-case for each of the functions. Below is an outline of the discussed use-cases for Functions 4 and 7: i) Function 4 use-cases could include: (a) Real-time support to the local customer or local distribution grid; (b) Market support; (c) System support. ii) Function 7 use-cases could include: (a) Minimizing flicker caused by intermittent DER operations or load fluctuations; (b) Transmission system support. No participating SIWG members voiced negative comments towards the IOUs’ description of these use cases and the related technical specification. SIWG members on the workshop call appeared to all understand that the IOUs’ use-cases and technical specifications will eventually need to be discussed as part of an update to IEEE915472018 standards and that final technical specification for Functions 4 and 7 would be determined based on the IEEE1547 standard development processes. These 7 E-4898 Page 38 E-4898 Page 39 9 Institute of Electrical and Electronics Engineers 8
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Advice 5449-E -4- December 20, 2018 processes will include IEEE1547 working group technical discussions, voting on the standard revisions, and ultimately the IEEE issuing approval. Regarding the technical standards, the IOUs opined that while the possibility exists that an entity other than IEEE may develop a national standard, nevertheless the IEEE will likely incorporate a national standard for these functions in the next update to the IEEE 1547-2018 standard. However, an IEEE Project Authorization Request (PAR) to update IEEE1547-2018 has not yet commenced, and thus the technical standards for Functions 4 and 7 may not be ready for another 2 years. Proposal Based on the October 11, 2018, SIWG meeting, PG&E working along with the other IOUs propose: A. Regarding Function 4 and 7: Reflecting a consensus among the SIWG members that it will likely take several years for a national standard to be developed and approved for Functions 4 and 7, PG&E recommends that no revisions or updates to Rule 21 Tariff be made at this time, as doing so may cause unnecessary confusion within the DER market place. PG&E will continue to monitor, support or participate in IEEE1547 updates and will update their respective California Rule 21 Tariffs as applicable to reflect the development of a national standard. B. Summary Report: Regarding a report summarizing the degree of consensus achieved regarding the clarity or proposed revised technical requirements of Functions 4 and 7, this advice letter serves to report that the working group did not conceptually disagree on the use-cases, and the associated technical requirements. The SIWG members in attendance agreed that such use-cases and technical specification would be discussed and finalized as part of a national standard development. Protests Anyone wishing to protest this filing may do so by letter sent via U.S. mail, facsimile or E-mail, no later than January 9, 2019, which is 20 days after the date of this filing. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102 Facsimile: (415) 703-2200 E-mail:
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Advice 5449-E -5- December 20, 2018 Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date PG&E requests that this Tier 2 advice letter become effective on regular notice, January 19, 2019, which is 30 calendar days after the date of submittal Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service lists for R.11-09-011 and R.17-07-007. Address changes to the General Order 96-B service list should be directed to PG&E at email address For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter filings can also be accessed electronically at:
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Advice 5449-E -6- /S/ Erik Jacobson Director, Regulatory Relations cc: Service List R.11-09-011 and R.17-07-007 December 20, 2018
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39E) Utility type: ELC GAS PLC ✔ HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Yvonne Yang Phone #: (415)973-2094 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 5449-E Subject of AL: Proposal for the Rule 21Technical Requirements for Smart Inverter Working Group Phase 2 Functions 4 and 7 Pursuant to Resolution E-4898 Ordering Paragraph 8 Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual ✔ One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Resolution E-4898 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: Yes Yes ✔ No ✔ No 1/19/19 No. of tariff sheets: N/A Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: Service affected and changes proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. Braun Blaising Smith Wynne P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Casner, Steve Cenergy Power Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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