Details for: 3926-E (Part 1 of 1).pdf


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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

December 21, 2018
ADVICE 3926-E
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
Summary of Consensus and Clarity Provided to Rule 21
Technical Requirements for Functions 4 and 7 Pursuant to
Resolution E-4898

SUBJECT:

PURPOSE
The purpose of this advice letter is to clarify the technical requirements for Functions 4
and 7 and to report on the level of consensus achieved for the revised technical
requirements of Functions 4 and 7.1
BACKGROUND
The California Public Utilities Commission (Commission) initiated Rulemaking (R.)1109-011 (Rule 21 proceeding) on September 22, 2011 to review and, if necessary, revise
the rules and regulations governing the interconnection of generation and storage
resources to the electric distribution systems of Southern California Edison Company
(SCE), Pacific Gas and Electric Company (PG&E), and San Diego Gas & Electric
Company (SDG&E), collectively the investor-owned utilities (IOUs).
The Commission adopted Decision (D.)16-06-052 within the Rule 21 proceeding which
included, in part, Ordering Paragraph (OP) 9, which required the IOUs to submit a Tier 3
advice letter with proposed revisions to Rule 21 to set forth technical requirements and
effective dates for Phase 3 advance inverter functions.
SCE submitted Advice Letter (AL) 3647-E on August 18, 2017 which included, among
other things, proposed function requirement dates for Functions 4 and 7 as follows:

1

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.
http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M213/K658/213658887.PDF

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





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ADVICE 3926-E (U 338-E) -2- December 21, 2018 Function Requirement Date Function 4 – Set Active Power Mode (Section H.h.2.n) Optional Upon Mutual Agreement between Utility and Applicant Function 7 – Dynamic Reactive Support (H.h.2.o) Optional Upon Mutual Agreement between Utility and Applicant The Commission adopted Resolution E-4898 (Resolution) on April 26, 2018 which, among other things: (i) approved Rule 21 tariff revisions for Function 4 and Function 7 as proposed in AL 3647-E; (ii) adopted the effective date for Functions 4 and 7 to be the earlier of December 2019 or 12 months after approval of the IEEE 1547.1 standard revision; (iii) directed each IOU to work with the Smart Inverter Working Group (SIWG) to clarify Function 4 and 7 technical requirements; and (iv) per OP 8, directed each IOU to submit 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. DISCUSSION During the October 11, 2018 SIWG meeting, the IOUs presented potential use-cases and potential technical specification to meet the use-case for each of the functions. Below is an outline of the discussed use-cases: Function 4 use-cases could include: providing real-time support to the local customer or local distribution grid; providing market support; providing system support. Function 7 use-cases could include: minimizing flicker caused by intermittent Distributed Energy Resources (DER) operations or load fluctuations; transmission system support. No participating SIWG members voiced negative comments towards the IOUs’ description of these use cases and the related technical specification. All SIWG members on the call understood that the IOUs use-cases and technical specifications will eventually need to be discussed as part of an update to IEEE1547-2018 and final technical specification for Functions 4 and 7 would be determined based on IEEE1547 standard development process which includes: IEEE1547 working group technical discussion, ballot processes, and IEEE approval. Technical standards: The IOUs opined that while the possibility exists that an entity other than IEEE may develop a national standard, IEEE will likely incorporate a national standard for these functions in the next update to IEEE 547-2018. 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 until another 2-4 years.
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ADVICE 3926-E (U 338-E) -3- December 21, 2018 Summary Report: regarding the degree of consensus achieved for proposed revised technical requirements of Functions 4 and 7, SCE reports that the SIWG did not conceptually disagree on the use cases and related technical requirements and the SIWG members in attendance agreed that such use cases and technical specification would be discussed and finalized as part of the development of a national standard. PROPOSAL Reflecting a general consensus among the SIWG members that several years may pass before a national standard is developed and approved for Functions 4 and 7, SCE recommends that no revisions or updates to its Rule 21 Tariff be initiated at this time, as doing so may cause unnecessary confusion within the DER marketplace. SCE will continue to monitor, support or participate in IEEE1547 updates and will update its Rule 21 Tariff as applicable to reflect the development of a national standard. No cost information is required for this advice letter. This advice letter will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule. TIER DESIGNATION Pursuant to OP 8 of the Resolution, this advice letter is submitted with a Tier 2 designation EFFECTIVE DATE SCE requests that this Tier 2 advice letter become effective January 20, 2019, 30 calendar days following the date submitted. NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of:
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ADVICE 3926-E (U 338-E) -4- December 21, 2018 Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: AdviceTariffManager@sce.com Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: Karyn.Gansecki@sce.com There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and R.11-09-011 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters. For questions, please contact Mary J. Brown at (626) 302-8103 or by electronic mail at mary.brown@sce.com. Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:mb:cm Enclosures
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: Darrah.Morgan@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 3926-E Subject of AL: Summary of Consensus and Clarity Provided to Rule 21 Technical Requirements for Functions 4 and 7 Pursuant to Resolution E-4898 Keywords (choose from CPUC listing): Compliance, Rule 21 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: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: 1/20/19 No. of tariff sheets: -0- Estimated system annual revenue effect (%): Estimated system average rate effect (%): 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: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 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: EDTariffUnit@cpuc.ca.gov Name: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: advicetariffmanager@sce.com Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: karyn.gansecki@sce.com Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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