Details for: PGE Comments on Draft Resolution E-5127.pdf


Click on the image for full size preview

Document data

Erik Jacobson
Director
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

February 18, 2021

California Public Utilities Commission - Energy Division
Attention: Tariff Unit
505 Van Ness Avenue
San Francisco, CA 94102
Subject:

Comments of Pacific Gas and Electric Company (U 39 E) on Draft
Resolution E-5127: Approval of Pacific Gas and Electric Company’s
Community Microgrid Enablement Program Submitted in Advice
Letter 5918-E.

Dear Energy Division Tariff Unit:
Pacific Gas and Electric Company (PG&E) appreciates the opportunity to comment on
the California Public Utilities Commission’s (Commission) Draft Resolution E-5127 (Draft
Resolution) approving (1) PG&E’s Community Microgrid Enablement Program and (2) the
pro forma Community Microgrid Enablement Tariff (CMET), for use on an experimental
basis. PG&E generally supports the Draft Resolution and looks forward to implementing
this experimental tariff and new program consistent with the guidance the Commission
has provided. However, PG&E recommends the Draft Resolution be revised as set forth
in more detail below.
Discussion
A. The Draft Resolution Correctly Notes the Need for Flexibility in Program
Design at the Outset, Allowing the Program to be Adapted Over Time.
In the context of rejecting Concentric’s request to require PG&E to procure all Resource
Adequacy-qualifying capacity from projects in a CMEP-qualifying microgrid, the Draft
Resolution correctly notes the importance of starting with flexibility of contracting and
procurement structures 1 and remaining “open to change so this experimental tariff
evolves with experience.” 2 The Draft Resolution correctly identifies the risk of unintended
See Draft Resolution, p. 12 (“[T]he Commission used as a guiding principle that providing
PG&E operational flexibility was warranted to enable the program to move forward. This
approach is reasonable while setting follow-up expectations for PG&E to report back with
additional information or analysis as the program gains experience and lessons learned.”).
2 Draft Resolution, p. 7.
1





- Page 1 -

PG&E Comments on Draft Resolution E-5127 -2- February 18, 2021 consequences that may come about because of overly prescriptive conditions or requirements at the outset, including impairing the ability of microgrid resources from realizing revenue streams from other (non-PG&E) sources and/or jeopardizing distribution system safety and reliability. 3 Subsequent to PG&E’s filing of Advice Letter 5918-E, the CPUC adopted a new Microgrid Incentive Program (MIP) in Track 2 of the Microgrid and Resiliency Rulemaking (R. 1909-009). 4 Like CMEP, the MIP will fund clean energy microgrids to support the critical resilience needs of communities, focusing on vulnerable customers. In Decision (D.) 2101-018, the CPUC authorized PG&E to propose changes to its CMEP that may be necessary to integrate that program more fully with the MIP. 5 In the spirit of continually improving the CMEP and CMET, and to allow modifications to be made as the program evolves and is integrated with the MIP, PG&E recommends that it be allowed to seek modifications through future advice letters, whether before or after submission of its initial program evaluation. This request would change Ordering Paragraph 6 of the Draft Resolution in the following manner: PG&E may seek modifications to the CMEP, including the Community Microgrid Enablement Tariff, prior to filing its program evaluation as part of its 2023 General Rate Case Application through a subsequent Tier 2 Advice Letter on its own motion or in response to direction from the Commission. B. The Commission Should Incorporate the Definition of Critical Facilities As Revised in the Public Safety Power Shutoff Rulemaking. The Draft Resolution correctly notes that it is not within the scope of R.19-09-009 to change definitions that are under consideration in other Commission proceedings, including, but not limited to, those involving the Self Generation Incentive Program and the De-energization Proceeding (R.18-12-005). As stated in PG&E’s Reply to Protests of Advice Letter 5918-E, PG&E supports using the latest adopted definition of Critical Facilities developed under the PSPS proceeding 6 for purposes of the CMEP, and in this respect agrees with the Joint Community Choice Aggregators (CCAs) in that aspect of their protest. It is important to not begin the CMEP program with outdated definitions from the outset. Adopting for CMEP the most recent definition of Critical Facilities adopted by the Commission in the De-energization Proceeding only harmonizes the implementation of PSPS and microgrid policy and would not conflict with the Commission’s goal of keeping the initial definition of Critical Facilities solely within the scope of the Deenergization Proceeding. Id. See Decision (D.) 21-01-018, pp. 114-115 (Ordering Paragraphs 5 and 6). 5 Id., p. 62. 6 Otherwise known as the De-Energization Proceeding, R.18-12-005. 3 4
- Page 2 -

PG&E Comments on Draft Resolution E-5127 -3- February 18, 2021 PG&E therefore recommends the following changes to language on page 5 of the Draft Resolution: 7 CEJA and Joint CCAs requested the Commission to modify or expand definitions for DAC and critical facilities to include additional essential services that customers rely upon during outage events. While it It is not within the scope of R.19-09-009 to change definitions which are under consideration in other Commission proceedings including but not limited to those involving the Self Generation Incentive Program and the De-energization Proceeding (R.18-12-005), the parties here have requested only harmonization of the definition between the two proceedings. Consequently, the Commission finds that these requests are reasonable and should be adopted. PG&E shall utilize the most recent definition of Critical Facilities adopted in R.18-12-005 or a successor proceeding, as that definition may be updated from time to time, for purposes of the CMEP Programrejected for technical reasons. C. The Commission Should Correct Minor Errors in the Draft Resolution. a. Some Microgrid Controllers May Be Tested at Third-Party Facilities. The Draft Resolution states: The microgrid control functions will be tested at PG&E’s San Ramon Applied Technology Services (ATS) where PG&E will be using a plan based on microgrid specific standards including IEEE 2030.72 and IEEE 2030.8.3. PG&E’s system performance evaluation at ATS will be based on IEEE 1547-2018 voltage and frequency ride-through requirements and may incorporate other performance metrics required by PG&E technical or operational requirements. 8 It is correct that PG&E is testing the microgrid control functions and evaluating system performance at ATS for the Redwood Coast Airport Microgrid (RCAM) project. However, PG&E anticipates that most of the system performance evaluation elements for CMEP Projects will be performed by PG&E’s Engineers or Engineering Consultants outside of ATS. The controls testing for future projects would be performed by the controls vendor according to a factory acceptance plan defined by PG&E. This factory acceptance plan would be based on microgrid specific standards, including IEEE 2030.7 and IEEE 2030.8. PG&E’s role would be to review and validate the results of these tests. See Section 10 of the Technical Best Practices Guide for more information. 7 8 Corresponding changes should be made to Finding 20 on page 15 of the Draft Resolution. Draft Resolution, p. 8.
- Page 3 -

PG&E Comments on Draft Resolution E-5127 -4- February 18, 2021 In light of these clarifications, PG&E requests that the paragraph cited above from the Draft Resolution be amended as follows: The Commission understands that PG&E will be evaluating the microgrid to verify the project’s distributed energy resources meet PG&E Rule 2 requirements in both blue sky and islanded modes. The microgrid control functions will be tested at PG&E’s San Ramon Applied Technology Services (ATS) where PG&E will be using a plan based on microgrid specific standards including IEEE 2030.72 and IEEE 2030.8.3. The evaluation of the microgrid performance on PG&E’s system performance evaluation at ATS will be based on IEEE 15472018 voltage and frequency ride-through requirements and may incorporate other performance metrics required by PG&E technical or operational requirements. From a protection standpoint for parallel/blue sky operation, PG&E applies California Rule 21, the Wholesale Distribution Access Tariff, Distribution Interconnection Handbook, Transmission Interconnection Handbook, and PG&E protection standards. For island mode operations, IEEE 2030.7 and internal PG&E Protection processes are applied. b. PG&E Will Provide Advance Notice of Planned Outages and Islanding in Accordance with Applicable Federal Energy Regulatory Commission (FERC) Rules, But Advance Notice May Not Be Provided In Emergencies. The Draft Resolution notes that PG&E “intends to provide advance notice to microgrids regarding [Public Safety Power Shutoff (PSPS)] events and planned outages according to operating protocols in the Microgrid Operating Agreement and as consistent with PG&E’s pro forma Operating Agreement in the Transmission Interconnection Handbook.” 9 While this statement is correct, PG&E wishes to clarify how and when it can provide this advance notice. PG&E affirms its intention to provide advance notice of planned outages in accordance with applicable FERC rules. However, PG&E would like to clarify that under the special circumstances of PSPS events, PG&E must notify PG&E’s Public Safety Partners prior to notifying Community Microgrid Aggregators. Additionally, advance notice of service interruptions will not be possible in unplanned situations, and PG&E must therefore retain the right to island without notice in emergencies. These clarifications will be further addressed in the forthcoming Microgrid Operating Agreement. 9 Draft Resolution, p. 6.
- Page 4 -

PG&E Comments on Draft Resolution E-5127 -5- February 18, 2021 D. PG&E Expects to Evaluate the CMEP in Phases, Beginning with Its 2023 GRC Resolution. The Draft Resolution correctly implements D.20-06-017 by requiring PG&E to evaluate the CMEP as part of its 2023 GRC application. 10 PG&E notes that it currently expects to file its 2023 General Rate Case Application by June 30, 2021, only four months in the future. This timing means that the initial CMEP evaluation will be based on very little experience administering the program. PG&E looks forward to supplementing this initial evaluation with subsequent assessments and modifications as it seeks to integrate the CMEP into the new MIP approved by the Commission in D.21-01-018 and in any future filings seeking to extend the CMEP beyond its approved initial phase through 2022. Conclusion PG&E appreciates the opportunity to comment on the Draft Resolution and respectfully requests the Draft Resolution be adopted with the minor modifications described above and reflected in the appendix. Respectfully submitted, /S/ Erik Jacobson Director, Regulatory Relations cc: Energy Division Tariff Unit Edward Randolph, Director, Energy Division Joyce Steingass, Energy Division Forest Kaser, Energy Division Heather Lewis, California Environmental Justice Alliance Jonathan Kevles, Concentric Power Jana Kopyciok-Lande, Marin Clean Energy C. Baird Brown, econ(n)law LLC Jin Noh, California Energy Storage Alliance Ben Schwartz, Clean Coalition Service List R.19-09-009 See, e.g., Draft Resolution p. 9-10 (requiring evaluation of 20 megawatt cap for CMEP projects, outcomes of using defined eligibility criteria and potential of expanding such criteria, and experience requiring certain milestones to be met before cost offsets are reserved). 10
- Page 5 -

PG&E Comments on Draft Resolution E-5127 -6- February 18, 2021 Appendix Specific Recommended Changes to the Draft Resolution Ordering Paragraph #6: PG&E may seek modifications to the CMEP, including the Community Microgrid Enablement Tariff, prior to filing its program evaluation as part of its 2023 General Rate Case Application through a subsequent Tier 2 Advice Letter on its own motion or in response to direction from the Commission. Discussion p. 5: CEJA and Joint CCAs requested the Commission to modify or expand definitions for DAC and critical facilities to include additional essential services that customers rely upon during outage events. While it It is not within the scope of R.19-09009 to change definitions which are under consideration in other Commission proceedings including but not limited to those involving the Self Generation Incentive Program and the De-energization Proceeding (R.18-12-005), the parties here have requested only harmonization of the definition between the two proceedings. Consequently, the Commission finds that these requests are reasonable and should be adopted. PG&E shall utilize the most recent definition of Critical Facilities adopted in R.18-12-005 or a successor proceeding, as that definition may be updated from time to time, for purposes of the CMEP Programrejected for technical reasons. Discussion p. 8: The Commission understands that PG&E will be evaluating the microgrid to verify the project’s distributed energy resources meet PG&E Rule 2 requirements in both blue sky and islanded modes. The microgrid control functions will be tested at PG&E’s San Ramon Applied Technology Services (ATS) where PG&E will be using a plan based on microgrid specific standards including IEEE 2030.72 and IEEE 2030.8.3. The evaluation of the microgrid performance on PG&E’s system performance evaluation at ATS will be based on IEEE 1547-2018 voltage and frequency ride-through requirements and may incorporate other performance metrics required by PG&E technical or operational requirements. From a protection standpoint for parallel/blue sky operation, PG&E applies California Rule 21, the Wholesale Distribution Access Tariff, Distribution Interconnection Handbook, Transmission Interconnection Handbook, and PG&E protection standards. For island mode operations, IEEE 2030.7 and internal PG&E Protection processes are applied.
- Page 6 -