Details for: Joint Reply to CESA and Tesla Responses to Advice 3966-E et al.pdf


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

April 8, 2019
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re:

Reply to CESA and Tesla’s Response to Joint Advice Letters 3966-E,
4073-G/5491-E, 5435, and 98, Proposed Modifications to the SelfGeneration Incentive Program Handbook related to Energy Storage
Equipment Specifications, Virtual On-site Inspections, and Other Program
Improvements and Handbook Clarifications

Dear Energy Division Tariff Unit:
Pursuant to General Rule 7.4.3 of the California Public Utilities Commission’s
(Commission or CPUC) General Order (GO) 96-B, Southern California Edison
Company (SCE) hereby submits this reply on behalf of the Self Generation Incentive
Program (SGIP) Program Administrator’s (PAs) to the response of California Energy
Storage Alliance (CESA) and Tesla, Inc.’s (Tesla) of SCE Advice 3966-E et al.,1
Proposed Modifications to the SGIP Handbook related to Energy Storage Equipment
Specifications, Virtual On-site Inspections, and Other Program Improvements and
Handbook Clarifications.
BACKGROUND
On March 11, 2019, the SGIP PA’s jointly submitted Advice Letter (AL) 3966-E2
proposing to modify and update the SGIP Handbook. In AL 3966-E, the PA’s proposed
the following amendments to the Handbook:
•
•
•
•
1

2

Make SGIP energy storage equipment available to the public;
Modify energy storage component specification requirement;
Allow virtual inspections for residential projects;
Remove requirement for copy of checks submitted with applications;

Joint Advice Letter submitted by SCE Advice 3966-E, Pacific Gas and Electric Company
(PG&E) Advice 4073-G/5491-E, Southern California Gas Company (SoCalGas) Advice
5435, and Center for Sustainable Energy (CSE) Advice 98.
SCE Advice 3966-E / PG&E Advice 4073-G/5491-E / SoCalGas 5435 / CSE 98, Proposed
Modifications to the Self-Generation Incentive Program Handbook Related to Energy
Storage Equipment Specifications, Virtual On-site Inspections, and Other Program
Improvements and Handbook Clarifications (SCE Advice Letter 3966-E, et al.), March 11,
2019.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

FAX (626) 302-6396





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Energy Division Tariff Unit Page 2 April 8, 2019 • • • • • • Streamline residential customer communications; Include project cost affidavit and breakdown in Incentive Claim Form; Remove requirement for third party authorization to receive customer information; Require final monitoring schematic for all projects; Extend the application fee refundable period for 3-step projects; and Correct the language for performance data provider (PDP) Audits. On April 1, 2019, CESA and Tesla submitted responses to AL 3966-E. CESA requested that the SGIP equipment list should leverage the California Energy Commission’s (CEC) storage equipment list and/or the PAs should shape the development of the CEC list to provide a single list that supports both the interconnection and program eligibility use cases.3 Tesla requested that the PA’s eliminate the requirement that participating storage systems submit a CEC inverter efficiency value in order to be eligible to receive SGIP incentives.4 The SGIP PA’s Reply to Response is included herein. DISCUSSION A. CESA’s Request to Leverage the CEC’s Storage Equipment List to Support Interconnection and Program Elibility Use Cases Could Stall Streamlining Effort While the SGIP PAs support the CEC’s development of a public battery storage equipment list that addresses performance, reliability, and safety standards; CESA’s request is misaligned with AL 3966-E. The proposed “SGIP Equipment List” detailed in AL 3966-E5 should not be interpreted as a finite list of SGIP “eligible” or “approved” equipment. Nor is it intended to replace current program protocols – such as NRTL certification – designed to verify safety and/or reliability in the manner proposed recently by Assembly Bill (AB) 877 (Gabriel, 2019), which recommends establishing minimum requirements and rating standards for battery storage systems. The proposed SGIP Equipment List is intended only to confirm specific SGIPevaluated metrics for a device’s energy capacity (kWh), rated energy values (kW), and discharge duration for calculating the correct incentive value for SGIP projects. Publicizing the SGIP Equipment List and incorporating these values into the SGIP application database will enable SGIP applicants to choose the 3 4 5 CESA Response, p. 1. Tesla Response, p. 1. SCE Advice 3966-E / PG&E Advice 4073-G/5491-E / SoCalGas 5435 / CSE 98, Proposed Modifications to the Self-Generation Incentive Program Handbook Related to Energy Storage Equipment Specifications, Virtual On-site Inspections, and Other Program Improvements and Handbook Clarifications (SCE Advice Letter 3966-E, et al.), March 11, 2019.
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Energy Division Tariff Unit Page 3 April 8, 2019 appropriate SGIP-specific sizing and related incentive values associated with their respective SGIP project while improving the accuracy and ease of the application process. In addition, the development and release of a CEC eligible storage equipment list may take considerable time and could stall aspects of SGIP’s application streamlining effort. Thus, the SGIP PAs request that the Commission approve their proposal to move forward with a publicized list of SGIP equipment and associated program-specific metrics as stated in AL 3966-E. The SGIP PAs look forward to the possibility of collaborating with the CEC towards the development of a battery storage equipment list for the benefit all California consumers and industry in the near future. B. TESLA’s Request to Eliminate Participating Storage System Requirement to Submit a CEC Inverter Efficiency Value to Receive SGIP Incentives is Out of Scope AL 3966-E proposes to allow manufacturers to authorize the release of certain information that may include CEC inverter efficiency data for the purposes of developing a publicly available SGIP Equipment List. AL 3966-E does not seek to modify the established SGIP incentive requirement that CEC inverter efficiency data be provided for energy storage systems. As such, Tesla’s request is out of scope with respect to the proposals in AL 3966-E. Moreover, to the extent Tesla seeks to modify or eliminate established SGIP requirements, such requests should include the appropriate alternative methodology and can be made through the SGIP Working Group via the Program Modification Request Process currently in place so that the request and assertions can be properly analyzed.6 Accordingly, the SGIP PAs request that the Commission approve the SGIP PA’s original proposal in AL 3966-E to create an SGIP Equipment List that may include the CEC inverter efficiency information for AC-based systems. 6 2017 SGIP Handbook Section 4.2.7, p. 40.
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Energy Division Tariff Unit Page 4 April 8, 2019 CONCLUSION The SGIP PA’s appreciate the opportunity to provide this Reply to CESA and Tesla’s Responses to AL 3966-E, and recommends the Commission approve the PA’s proposals as set forth herein and in AL 3966-E. Sincerely, /s/ Gary A. Stern Gary A, Stern, Ph.D. GAS:nh:cm cc: Edward Randolph, Director, CPUC Energy Division Franz Cheng, CPUC Energy Division Andy Schwartz, Tesla Inc. Alex Morris, CESA Erik Jacobson, PG&E Ray Ortiz, Sempra Utilities Sephra Ninow, CSE Service List for R.12-11-005
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