Details for: SCE Reply to CALSSA Protest to Advice 4033-E.pdf


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

August 1, 2019
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
SUBJECT:

Reply of Southern California Edison Company to the California
Solar & Storage Association’s Protest of Advice Letter 4033-E
Joint IOU Submittal Proposed Template for Process Option 2
Modifications Pursuant to Decision 19-03-013

Dear Energy Tariff Division Unit:
Pursuant to General Rule 7.4.3 of the California Public Utilities Commission
(Commission or CPUC)’s General Order (GO) 96-B, Southern California Edison
Company (SCE) hereby submits its reply to the California Solar & Storage Association
(CALSSA)’s protest (Protest) to the Joint Investor Owned Utilities (IOU)1 advice letter,
Advice 3401-E et. al., (the Joint AL).2
Background
On April 5, 2019, the Commission issued Decision 19-03-013 (the Decision), which
adopted proposals from the March 15, 2018 Working Group One Report (WG1 Report).
The Commission ordered the IOUs to use, as an interim solution for process option 2
from Ordering Paragraph (OP) 6, a standard form template to be sent to a dedicated
utility email address.3 To implement the standard form template interim solution, the
Commission ordered the IOUs to jointly submit a Tier 2 Advice Letter describing the
template within 90 days. 4 Consistent with the directives of the Decision, the Joint AL
was submitted on July 5, 2019. On July 25, 2019, CALSSA submitted its Protest to the
Joint AL. SCE hereby replies to the Protest.

1
2
3
4

The Joint IOUs are SCE, Pacific Gas and Electric Company (PG&E), and San Diego Gas &
Electric Company (SDG&E).
SDG&E submitted Advice 3401-E on behalf of PG&E (Advice 5583-E) and SCE (Advice
4033-E).
Decision, at OP 8.
Id.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





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Energy Division California Public Utilities Commission August 1, 2019 Page 2 Reply to CALSSA’s Protest A. The IOUs’ Proposed Template Section 1.B-6 Aligns with SCE’s Proposed Tariff Changes Concerning Equipment Replacement, Resolves a Minor Inconsistency in the Decision, and Should Be Approved As SCE previously explained in its Reply to CALSSA’s Protest of Advice Letter 4009-E,5 there is a minor inconsistency in the Decision that SCE sought to resolve in its proposed tariff changes, while still supporting the Commission’s goal of addressing “differences between projects at or above versus those below 100 kW.”6 Specifically, the Decision sets forth the conditions under which a customer may make a modification to its existing Generating Facility (referred to as a Type II Modification), and the corresponding action required by the customer. Where customers “replac[e] equipment that may increase the nameplate capacity of the system, but which employ inverter power controls that limit the real power output to the inverter listed size in the original agreement” (referred to as Use Case 3), the Decision adopted a hybrid approach.7 For projects at or below 100 kW, the customer must notify the utility, but need not wait for approval (referred to as Process Option 2). For projects greater than 100 kW, the customer is required to submit a new Interconnection Request (referred to as Process Option 4). For projects that request an increase of capacity within 110 percent of its original generating capacity and use control systems to limit the output to the original capacity, then like projects at or below 100 kW, the customer must notify the utility, but need not wait for approval. SCE reiterates that this hybrid scheme is in-conflict in one, unique circumstance: where a project requests an increase in capacity within 110 percent of its original generating capacity, and such an increase results in the project size being greater than 100 kW. On the one hand, because the increase in capacity is within 110 percent of its original capacity, then it should be allowed to proceed with notification only (Process Option 2); but on the other hand, because the project is now greater than 100 kW, it should be required to request a new Interconnection Request (Process Option 4). In Advice 4009-E, SCE therefore proposed that: 5 6 7 Reply of Southern California Edison Company to the California Solar & Storage Association’s Protest of Advice Letter 4009-E Implementing Decision 19-03-013. Decision, at Finding of Fact 37. Decision, at OP 6.
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Energy Division California Public Utilities Commission August 1, 2019 Page 3 • • • For all projects increasing capacity to at or below 100 kW, notification is required; For all projects increasing capacity to above 100 kW, a new Interconnection Request is required; and For projects of any size requesting to increase capacity within 110 percent of its original generating capacity and more than 100 kW, a new Interconnection request is required.8 The proposed template, submitted with the Joint AL, accurately reflects these proposed tariff revisions by directing projects increasing capacity above 100 kW to submit a new Interconnection Request.9 CALSSA argues, however, that Section 1.B-6 should be revised to indicate that the “110% rule’ applies to projects of any size.”10 This position conflicts with the Commission’s directive that “process option 4 shall be used for projects increasing capacity to at or greater than 100 kW.”11 Section 1.B-6 of the proposed template should therefore be approved in its current form. B. SCE Agrees to Revise Section 4.A of the Proposed Template to Address Energy Storage Devices Section 4.A of the proposed template asks a customer to verify that all major solar system components are on the verified equipment list maintained by the California Energy Commission (CEC). SCE agrees with CALSSA that clarification to Section 4.A is necessary since the CEC’s approved list is specific to solar PV inverters, and does not currently include energy storage devices (although discussions are underway to develop such a list). For energy storage devices, SCE proposes requiring customers to verify that the storage inverter is on the utility pre-approved non-solar list. SCE therefore intends to modify, through a supplemental advice letter, Section 4.A of the proposed template to add the following: 8 9 10 11 AL 4009-E at p. 6 and Attachment A (Tariff Sheets) Section Ee.1. Joint AL, Attachment A (Generating Facility Material Modification Notification Worksheet) Section 1.B-6. Protest, at p. 1. Decision, at OP 6.
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Energy Division California Public Utilities Commission August 1, 2019 Page 4 Conclusion SCE appreciates the opportunity to submit this reply to CALSSA’s Protest. Sincerely, /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:mb:cm cc: Edward Randolph, Director, CPUC Energy Division Franz Cheng, CPUC Energy Division Brad Heavner, CALSSA Service Lists of R.17-07-007 and R.11-09-011
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