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
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PG&E Comments on
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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
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PG&E Comments on
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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.
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PG&E Comments on
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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.
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PG&E Comments on
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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
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PG&E Comments on
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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.
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