Details for: SCE Joint Comments to Draft Resolution E-5016 (3872e et al).pdf

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

November 27, 2019
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Comments of Southern California Edison Company,
Pacific Gas and Electric Company, and San Diego
Gas & Electric Company on Draft Resolution E-5016
Rejecting Pacific Gas and Electric Company’s,
Southern California Edison Company’s, and San
Diego Gas & Electric Company’s Proposal for
Standardized Reporting Methodologies to Monitor
the Frequency and Amount of Voltage Excursions.

Dear Energy Division Tariff Unit:
In accordance with Draft Resolution E-5016 (Draft Resolution) and Rule 14.5 of the Rules
of Practice and Procedure of the California Public Utilities Commission (Commission),
Southern California Edison Company (SCE), on behalf of itself, Pacific Gas and Electric
Company (PG&E), and San Diego Gas & Electric Company (SDG&E) (collectively, the
IOUs), submits these comments on the Draft Resolution regarding standardized reporting
methodologies to monitor the frequency and amount of voltage excursions.
On October 1, 2018, in response to Resolution E-4898, SCE submitted Advice Letter
(AL) 3872-E, PG&E submitted AL 5395-E, and SDG&E submitted AL 3283-E. The ALs
respond to a requirement to develop a monitoring and reporting framework proposal for
power curtailment due to the Volt-Watt function of Smart Inverters. On November 7,
2019, the Draft Resolution rejected the IOUs’ ALs. In addition, the Draft Resolution
ordered the IOUs to confer with the Smart Inverter Working Group (SIWG) and re-submit
their proposals in a Tier 1 Advice Letter within 150 days of the issuance of the resolution.
The IOUs appreciate the opportunity to provide the following comments on this Draft

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 November 27, 2019 Page 2 COMMENTS The IOUs support the direction provided in the Draft Resolution to meet the requirements of Resolution E-4898. The IOUs are committed to working with Energy Division (ED) and stakeholders and will hold at least two meetings with the SIWG to consider appropriate modeling tools, alternative proposed methodologies, and Advanced Meter Infrastructure (AMI) data capabilities. In addition, the IOUs concur with the requirement to re-submit ALs within 150 days after the issuance of the resolution and after meeting with the SIWG. Regarding the concerns raised about the IOUs’ participation in efforts leading to the AL (i.e., the “Additional Concerns” section of the Draft Resolution), the IOUs worked in good faith to develop the ALs they submitted on October 1, 2018. The IOUs participated in SIWG discussions on this issue while concurrently providing support to other matters within the Interconnection Rulemaking. In addition, the IOUs responded to ED’s data request about the capabilities of AMI and worked with ED to develop a proposed SIWG schedule in response to its June 15, 2018 request. Nonetheless, the IOUs acknowledge ED’s concerns and are committed to cooperating with ED, the SIWG, and other stakeholders in complying with the Commission’s resolution. The IOUs appreciate the importance of this issue and look forward to bringing closure to it. Southern California Edison Company/ Gary A. Stern /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:ac:cm cc: Edward Randolph, Director, CPUC Energy Division Franz Cheng, CPUC Energy Division Jose Aliaga-Caro, CPUC Energy Division Sophie Meyer, CPUC Energy Division Melicia Charles, Sunrun, Inc. Tim Lindl, Keyes & Fox LLP Steven Rymsha, Sunrun, Inc. Sky Stanfield, IREC Service Lists for R.11-09-011 and R.17-07-007
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