Details for: 4009-E-A (Part 1 of 1).pdf


Click on the image for full size preview

Document data

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

August 1, 2019
ADVICE 4009-E-A
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
SUBJECT:

Supplement to Advice 4009-E, Modifications to Electric Tariff
Rule 21 Pursuant to the Working Group One Decision
19-03-013 in Rulemaking 17-07-007

PURPOSE
Southern California Edison Company (SCE) hereby submits for approval by the
California Public Utilities Commission (Commission) this supplemental Advice Letter
(AL). As further discussed below, this advice letter makes changes to the Rule 21,
Generating Facility Interconnections, tariff sheets originally contained within Advice
4009-E, submitted on June 4, 2019. These changes are made in accordance with
General Order (GO) 96-B, General Rule 7.5.1, which authorizes utilities to make
additional changes to an advice letter through the submitting of a supplemental advice
letter.
This Advice Letter supplements Advice 4009-E in part. This advice letter addresses the
protest from CALSSA submitted on June 24, 20191 as well as editorial comments from
the Energy Division provided on July 1, 2019.
BACKGROUND
On June 4, 2019, SCE submitted AL 4009-E, which was protested by CALSSA on June
24, 2019. This supplemental Advice Letter addresses CALSSA’s protest by restoring
certain non-material modifications to Interconnection Facilities under the Cost Envelope
Option (CEO) provisions.
In explanation, customers that select the CEO should not be held to a different standard
than other customers in the Fast Track Process, and modifications to Generating

1

Protest of the California Solar & Storage Association to Southern California Edison
Company’s Advice Letter 4009-E Implementing D.19-03-013.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396





- Page 1 -

ADVICE 4009-E-A (U 338-E) -2- August 1, 2019 Facilities in pending Fast Track Interconnection Requests that have selected the CEO should continue to be limited to those in Table F.1. PROPOSED TARIFF CHANGES SCE proposes the following changes to Section F.7.f: Under the Fast Track Process, Type I mModifications to the Generating Facility are not permitted to be made to pending Interconnection Requests so long as the modification to the Generating Facility, related equipment, Point of Interconnection or other interconnection parameters that would not require a reevaluation of the Initial Review or Supplemental Review, and will be processed pursuant to Section F.2.f of this Rule. However, notwithstanding these restrictions, aAn Applicant may also identify and suggest minor changes to the Interconnection Facilities (e.g., minor adjustments to physical location of switchgear or other equipment, adjustments to routing of conductor from the Point of Common Coupling to the Point of Interconnection, etc.) upon or near completion of Applicant’s final design of its Interconnection Facilities. If If an Applicant identifies such changes, Applicant shall notify Distribution Provider of the requested changes and if, in the reasonable judgement of Distribution Provider, a re-evaluation of the costs under the Cost Envelope Option is required, Distribution Provider will provide Applicant within ten (10) Business Days of receipt of Applicant’s notice an estimate of the time required to reevaluate the costs under the Cost Envelope Option and the estimated cost of such re-evaluation... SCE proposes the following changes to Section G.3.a: If Distribution Provider determines that interdependencies exist and that they are reasonably anticipated to require or contribute to the need for Reliability Network Upgrades, then the Interconnection Request may be studied under the Transmission Cluster Study Process as set forth in Section F.3.d. Note 1Exemptions: All NEM and inverter-based Generating Facilitiess with nameplate capacity net export less than or equal to 500 kW1 MVA that may flow across the Point of Common Coupling will not be studied in the Transmission Cluster Study Process, but may be studied under the Independent Study Process. SCE proposes the following changes to Section H.3.d.ii: The replacement of an existing inverter towith an inverter that is of equal or greater ability than the original is allowed per Section H. Section Hh, may be used in all or in part, for replacement inverter-based technologies by mutual agreement of the Distribution Provider and the Applicant. If a developer replaces an existing inverter with an inverter of greater ability, the replacement inverter
- Page 2 -

ADVICE 4009-E-A (U 338-E) -3- August 1, 2019 shall have all of the required functionalities and be set according to current Commission requirements as of the date the new smart inverter is installed, unless the Applicant can demonstrate that safety or operational needs necessitate otherwise. 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 This advice letter is submitted with a Tier 2 designation, which is the same tier designation as the original advice letter, Advice 4009-E. EFFECTIVE DATE SCE respectfully requests that this supplement advice letter becomes effective on the same day as the original submittal was requested to become effective, July 4, 2019. 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: 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
- Page 3 -

ADVICE 4009-E-A (U 338-E) -4- August 1, 2019 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 R.11-09-011, and R.17-07-007 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) 302-4039. 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 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:jm
- Page 4 -

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: AdviceTariffManager@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) #: 4009-E-A Subject of AL: Supplement to Advice 4009-E, Modifications to Electric Tariff Rule 21 Pursuant to the Working Group One Decision 19-03-013 in Rulemaking 17-07-007 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 #: Decision 19-03-013 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: 7/4/19 No. of tariff sheets: -4- 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: Rule 21 and Table of Contents 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
- Page 5 -

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: (415) 929-5515 Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: karyn.gansecki@sce.com Clear Form
- Page 6 -

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
- Page 7 -

Public Utilities Commission 4009-E-A Cal. P.U.C. Sheet No. Revised 67381-E Revised 67382-E Revised 67384-E Revised 67385-E Title of Sheet Rules 21 Rules 21 Rules 21 Rules 21 Attachment A Cancelling Cal. P.U.C. Sheet No. Original 59960-E Original 59961-E Revised 59978-E Revised 62611-E 1
- Page 8 -

Southern California Edison Rosemead, California (U 338-E) Cancelling Revised Original Cal. PUC Sheet No. Cal. PUC Sheet No. Rule 21 GENERATING FACILITY INTERCONNECTIONS F. 67381-E 59960-E Sheet 103 (Continued) REVIEW PROCESS FOR INTERCONNECTION REQUESTS (Continued) 7. Cost Envelope Option (Continued) (T) e. Cost Elements Not Subject to Cost Envelope (Continued) The cost of any Distribution Provider’s Interconnection Facilities and/or Distribution Upgrades triggered by one or more earlier-queued Interconnection Requests that are also required for interconnection of a later-queued Generating Facility under the Cost Envelope Option shall not be subject to the Cost Envelope. In the event one or more of the earlier-queued projects withdraws (or is delayed to the extent the upgrade will not be completed in time to meet the later-queued Generating Facility’s requested InService Date) all, or a portion, of Distribution Provider’s Interconnection Facilities and/or Distribution Upgrades may become the responsibility of the later-queued Generating Facility. Upon such an occurrence, the Generator Interconnection Agreement shall be amended to reflect the Applicant’s responsibility for such Distribution Provider’s Interconnection Facilities and/or Distribution Upgrades based on actual costs unless Applicant requests in writing, within ten (10) Business Days of Applicant’s receipt of Distribution Provider’s non-binding estimated cost of such required facilities, that it elects to include such facilities in the Cost Envelope. Within ten (10) Business Days of Applicant’s request, Distribution Provider shall provide to Applicant an estimate of the cost required to update the Cost Envelope Estimate. Applicant shall notify Distribution Provider in writing within ten (10) Business Days of Applicant’s receipt of Distribution Provider’s estimate whether (i) Applicant elects to proceed with the update to the Cost Envelope Estimate at Applicant’s expense, or (ii) that Applicant withdraws its request to include the additional facilities in the Cost Envelope. If Applicant elects to proceed with the update to the Cost Envelope Estimate, Distribution Provider shall complete the update within the sum of the time allowed for each step utilized by the Distribution Provider in preparation of the initial Cost Envelope Estimate pursuant to Section F.2 for Interconnection Requests evaluated under the Fast Track Process, or Section F.3.b for Interconnection Requests evaluated under the Independent Study Process, from receipt of payment of the estimated cost of the update. Should Applicant fail to so notify Distribution Provider within the ten (10) Business Day period, Applicant’s request to include such additional facilities in the Cost Envelope shall be deemed withdrawn and such additional facilities shall be the responsibility of Applicant based on actual cost. f. Modifications Under the Fast Track Process, Type I Modifications to the Generating Facility are permitted to be made to pending Interconnection Requests so long as the modification would not require a re-evaluation of the Initial Review or Supplemental Review, and will be processed pursuant to Section F.2.f of this Rule. An Applicant may also identify and suggest minor changes to the Interconnection Facilities (e.g., minor adjustments to physical location of switchgear or other equipment, adjustments to routing of conductor from the Point of Common Coupling to the Point of Interconnection, etc.) upon or near completion of Applicant’s final design of its Interconnection Facilities. (T) (T) (Continued) (To be inserted by utility) Advice 4009-E-A Decision 19-03-013 103D7 Issued by Kevin Payne Chief Executive Officer (To be inserted by Cal. PUC) Date Submitted Aug 1, 2019 Effective Resolution
- Page 9 -

Southern California Edison Rosemead, California (U 338-E) Cancelling Revised Original Cal. PUC Sheet No. Cal. PUC Sheet No. Rule 21 GENERATING FACILITY INTERCONNECTIONS F. 67382-E 59961-E Sheet 104 (Continued) REVIEW PROCESS FOR INTERCONNECTION REQUESTS (Continued) 7. Cost Envelope Option (Continued) If an Applicant identifies such changes, Applicant shall notify Distribution Provider of the requested changes and if, in the reasonable judgement of Distribution Provider, a re-evaluation of the costs under the Cost Envelope Option is required, Distribution Provider will provide Applicant within ten (10) Business Days of receipt of Applicant’s notice an estimate of the time required to re-evaluate the costs under the Cost Envelope Option and the estimated cost of such re-evaluation. Applicant may either (i) accept the additional time and cost to complete the re-evaluation, (ii) withdraw the proposed changes, or (iii) proceed with a new Interconnection Request for such changes. Applicant shall provide Distribution Provider written notice of its election within ten (10) Business Days following Applicant’s receipt of Distribution Provider’s estimated additional time and cost required for the re-evaluation. If Applicant elects to proceed with the re-evaluation of the costs under the Cost Envelope Option, Distribution Provider shall complete the re-evaluation within twenty (20) Business Days from receipt of all required technical data related to the proposed changes and payment of the estimated cost of the re-evaluation. Should Applicant fail to so notify Distribution Provider within such ten (10) Business Day period, Applicant’s request to make the proposed changes shall be deemed withdrawn. (T) Under the Independent Study Process, any requested modifications, including required updates to costs under the Cost Envelope Option, shall be made in accordance with Section F.3.b.v. If Applicant elects to proceed with re-evaluation of the costs under the Cost Envelope Option pursuant to Section F.3.b.v, Distribution Provider shall complete the re-evaluation within the sum of the time allowed for each step utilized by the Distribution Provider for preparation of the initial Cost Envelope Estimate pursuant Section F.3.b from receipt of all required technical data related to the proposed changes and payment of the estimated cost of the re-evaluation. g. Tender of the Generator Interconnection Agreement Under the Cost Envelope Option Negotiation and execution of the Generator Interconnection Agreement shall be in accordance with Section F.2.e for Interconnection Requests evaluated under the Fast Track Process, and in accordance with Section F.3.e.ii for Interconnection Requests evaluated under the Independent Study Process. (Continued) (To be inserted by utility) Advice 4009-E-A Decision 19-03-013 104D5 Issued by Kevin Payne Chief Executive Officer (To be inserted by Cal. PUC) Date Submitted Aug 1, 2019 Effective Resolution
- Page 10 -

Southern California Edison Rosemead, California (U 338-E) Cancelling Revised Revised Cal. PUC Sheet No. Cal. PUC Sheet No. Rule 21 GENERATING FACILITY INTERCONNECTIONS G. 67384-E 59978-E Sheet 121 (Continued) ENGINEERING REVIEW DETAILS (Continued) (L) 3. Detailed Study Screens (Continued) a. Screen Q: Is the Interconnection Request electrically Independent of the Transmission System? (Continued) If Distribution Provider determines that no interdependencies exist or that interdependencies do exist but the proposed Generating Facility is not reasonably anticipated to require or contribute to the need for Reliability Network Upgrades, then the Interconnection Request will be deemed to have passed Distribution Provider’s Electrical Independence for the CAISO Controlled Grid. (T) | (T) If Distribution Provider determines that interdependencies exist and that they are reasonably anticipated to require or contribute to the need for Reliability Network Upgrades, then the Interconnection Request may be studied under the Transmission Cluster Study Process as set forth in Section F.3.d. (T) (T) (D) • • If Yes (pass), continue to Screen R. If No (fail), proceed to Section F.3.d. Exemptions: All NEM and inverter-based Generating Facilities with nameplate capacity less than or equal to 1 MVA will not be studied in the Transmission Cluster Study Process, but may be studied under the Independent Study Process. Significance: Generating Facilities that are electrically interdependent with the Transmission System must be studied with other interconnection requests that have Transmission System interdependencies. It is possible to pass this Screen Q (i.e., be found to have no electrical interdependencies with earlier-queued Distribution System and/or Transmission System interconnection requests as set out above), be studied under the Independent Study Process, and still trigger a Reliability Network Upgrade. (Continued) (To be inserted by utility) Advice 4009-E-A Decision 19-03-013 121D7 Issued by Kevin Payne Chief Executive Officer (To be inserted by Cal. PUC) Date Submitted Aug 1, 2019 Effective Resolution (T) (T)
- Page 11 -

Southern California Edison Rosemead, California (U 338-E) Cancelling Revised Revised Cal. PUC Sheet No. Cal. PUC Sheet No. Rule 21 GENERATING FACILITY INTERCONNECTIONS H. 67385-E 62611-E Sheet 137 (Continued) GENERATING FACILITY DESIGN AND OPERATING REQUIREMENTS (Continued) 3. Technology Specific Requirements (Continued) b. Induction Generators Induction Generators (except self-excited Induction Generators) do not require a synchronizing Function. Starting or rapid load fluctuations on induction Generators can adversely impact Distribution Provider’s Distribution or Transmission System voltage. Corrective step-switched capacitors or other techniques may be necessary and may cause undesirable ferro-resonance. When these counter measures (e.g. additional capacitors) are installed on Producer's side of the PCC, Distribution Provider must review these measures. Additional equipment may be required as determined in a Supplemental Review or an Interconnection Study. c. Inverters Grid-interactive inverters do not require separate synchronizing equipment. Non-gridinteractive or “stand-alone” inverters shall not be used for Parallel Operation with Distribution Provider’s Distribution or Transmission System. d. Limitations on inverters not classified as Smart Inverters i. Inverter based systems may continue to be installed per Section H until September 8, 2017. Section Hh, may be used in all or in part, for inverter based technologies by mutual agreement of the Distribution Provider and the Applicant. ii. The replacement of an existing inverter with an inverter that is of equal or greater ability than the original is allowed per Section H. Section Hh, may be used in all or in part, for replacement inverter-based technologies by mutual agreement of the Distribution Provider and the Applicant. If a developer replaces an existing inverter with an inverter of greater ability, the replacement inverter shall have all of the required functionalities and be set according to current Commission requirements as of the date the new smart inverter is installed, unless the Applicant can demonstrate that safety or operational needs necessitate otherwise. e. Non-Export AC/DC Converters A Non-Export AC/DC Converter must satisfy the definition of Section C. 4. Supplemental Generating Facility Requirements a. Fault Detection A Generating Facility with an SCCR exceeding 0.1 or one that does not cease to energize Distribution Provider’s Distribution or Transmission System within two seconds of the formation of an Unintended Island shall be equipped with Protective Functions designed to detect Distribution or Transmission System faults, both line-toline and line-to-ground, and cease to energize Distribution Provider’s Distribution or Transmission System within two seconds of the initiation of a fault. (Continued) (To be inserted by utility) Advice 4009-E-A Decision 19-03-013 137D5 Issued by Kevin Payne Chief Executive Officer (To be inserted by Cal. PUC) Date Submitted Aug 1, 2019 Effective Resolution (T) (T) | | | (T)
- Page 12 -