Details for: 4455-E (Part 1 of 1).pdf

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

March 30, 2021
(U 338-E)
Recommendations Regarding Standard Review, Certification
Requirements, and Interconnection Processes Pursuant to
Decision 20-09-035


Southern California Edison Company (SCE) hereby submits for approval by the
California Public Utilities Commission (CPUC or Commission) recommendations for
implementing the Issue 9 counter proposal adopted in Ordering Paragraphs (OPs) 15
and 51 of Decision (D.)20-09-0351 (Decision) as further discussed below.
The Commission adopted Order Instituting Rulemaking (R.)17-07-007 on July 13, 2017
to consider a variety of refinements to the interconnection of distributed energy
resources (DER) under Electric Tariff Rule 21 of Pacific Gas and Electric Company
(PG&E), San Diego Gas & Electric Company (SDG&E), and SCE (jointly, Utilities) and
the equivalent tariff rules of the small and multi-jurisdictional electric utilities.2
The October 2, 2017 Scoping Memo of Assigned Commissioner and Administrative Law
Judge (Scoping Memo) set forth the scope and schedule of the proceeding. The
Scoping Memo was subsequently revised in the Assigned Commissioner’s Amended
Scoping Memo and Joint Administrative Law Judge Ruling issued November 16, 2018

Decision Adopting Recommendations from Working Groups Two, Three, And Subgroup,
issued September 30, 2020.
The Rule 21 tariff describes the interconnection, operating, and metering requirements for
certain generating and storage facilities seeking to connect to the electric distribution
system. Rule 21 provides customers access to the electric grid to install generating or
storage facilities while protecting the safety and reliability of the distribution and
transmission systems at the local and system levels. (See R.17-07-007 at 2.)

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 4455-E (U 338-E) March 30, 2021 -2- (Amended Scoping Memo). Pursuant to the Scoping Memo, the proceeding is to be conducted in three phases that address technical issues, cost-related issues, and issues related to small multi-jurisdictional utilities. The Scoping Memo also established the working group process, whereby resolution of the technical issues of the proceeding would be proposed by six working groups, Working Groups One through Six. The Amended Scoping Memo pared down the number of working groups to four and delegated certain issues to the Smart Inverter Working Group.3 D.19-03-013 adopted certain recommendations made by Working Group One. The Decision addresses the recommendations of Working Groups Two and Three and the Vehicle-to-Grid Alternating Current Interconnection Subgroup. In OP 15 the Commission adopted the Utilities’ counter proposal to resolve Issue 9, with modification, and in OP 51 the Commission adopted a modified Proposal A-B 3. OPs 15 and 51 required the Utilities to hold discussions with the Smart Inverter Working Group (SIWG) focused on implementing the proposals and, within six months of the issuance of the Decision, to submit recommendations (as applicable) regarding the standard review, certification requirements, and interconnection processes necessary for implementation of the proposals via Tier 3 advice letters. DISCUSSION As required in OPs 15 and 51, the Utilities commenced discussion with the SIWG within 90 days of the issuance of the Decision. The first meeting was held on December 17, 2020 and SIWG meetings continued until March 4, 2021 with a total of five working group meetings. Because of the similarities between OP 15 and OP 51, the Utilities proposed and the SIWG accepted that these two OPs should be implemented as one. Those similarities include: • • • • Both OPs relate to generating facilities that operate at different levels of export at different times in the year; Both OPs rely on a certification scheme using approved certification standards; Both OPs require the use of Smart Inverters; and Both OPs require the same level of engagement with the SIWG. Further, OP 51 provides that “the discussions and Tier 3 Advice Letter required in this ordering paragraph may be combined with those required in Ordering Paragraph 15.” 3 The Smart Inverter Working Group grew out of a collaboration between the Commission and the California Energy Commission in early 2013. The collaboration identified the development of advanced inverter functionality as an important strategy to mitigate the impact of high penetrations of distributed energy resources.
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ADVICE 4455-E (U 338-E) March 30, 2021 -3- As required by OPs 15 and 51, the SIWG discussions focused on standard review, certification requirements, and interconnection processes necessary for implementation of the proposals. During the December 17, 2021 SIWG meeting, the IOUs presented a draft process flow that outlined the requirements for: 1. 2. 3. 4. 5. Customer Pre-application Research Interconnection Request Technical Review Process Interconnection Agreement and PTO Operational Verification Requirements Refinement and discussion of the draft process flow continued until the final SIWG meeting on March 4, 2021. The processes outlined below are the outcome of the discussion. 1. Customer Preparation Phase: a. In this phase, customers who intend to use this operational method are to download the Integration Capacity Analysis (ICA) profiles from Utility ICA portals (when ICA values are available) for the three-phase electrical node that will be used for the interconnection request. b. Customers should examine and conform the downloaded data to inform applicant of the minimum monthly ICA-SG values from the ICA-SG profile. c. Customers should determine monthly export values to not exceed 90% of the monthly minimum ICA-SG values as determined in (b). d. Customers shall select a certified control system that can control the export limit to not exceed the values determined in (c). e. Customers shall capture the Distribution Feeder (circuit) name, the threephase electrical node identifier (Node ID), and the date of when the data extraction took place. This information will be needed when the customer submits the Interconnection Request. 2. Interconnection Request Phase: a. Customers are to provide the information that is typical and general to all interconnection requests. b. Customers are to provide the Limited Generation Values as determined in 1.c and the information for 1.e within the utility’s interconnection portal or via an alternative method as may be determined and provided by the utility. c. Customers are to provide information on certified control systems with the interconnection request information.
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ADVICE 4455-E (U 338-E) March 30, 2021 -4- i. Given that the UL Power Control System (PCS) standard for this type of application has not been approved and thus no control systems have provided certification information, it is not clear if additional information for these types of systems will need to be provided. Additional requirements for control information will be determined and provided once the UL PCS standard is approved. 3. Technical Evaluation Phase: a. SCE will apply all the applicable Initial Review Screens (A-L) based on Nameplate Capacity. b. Queue assignments will be based on Nameplate Capacity. This Nameplate Capacity will be used as a base line for subsequent impact studies, monthly ICA updates, and other applicable studies. c. SCE will verify that it has the most updated ICA value corresponding to the customer provided three phase electrical node (Node ID) from 1.e. d. SCE will evaluate the most updated ICA-SG profile and determine if the requested export values are at or below 90% of each month’s minimum ICA-SG value for each of the 12 months. i. If the export request for each of the 12 months is at or below 90% of each month’s minimum ICA-SG value, then the project can continue with its evaluation. ii. If all Initial Review Screens (A-L) are met including 3.d.i (all requested values are at or below 90% of each month’s ICA values), the project will pass Fast Track. iii. If the export request for one of more of the 12 months is not at or below 90% of each month’s minimum ICA-SG value, then SCE will inform the customer and the customer will be allowed 5 Business Days (BD) to update its requested profile to be at or below 90% ICA-SG for all 12 months. iv. If the customer does not respond within 5 BD of the notification, SCE will proceed to evaluate the project using full nameplate with not monthly limits. 4. Interconnection Agreement/PTO Phase: a. Execute Interconnection Agreements. The interconnection agreements should be updated to reflect the operational requirements including: i. Update Interconnection Agreement to ensure that the Generating Facility control systems meet the approved operating specification. ii. Update Interconnection Agreement to require prompt action by the customer if operating specifications are not followed and to allow utility to take actions, including termination of agreement.
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ADVICE 4455-E (U 338-E) March 30, 2021 -5- iii. Update Interconnection Agreement to require that the customer provide, on a quarterly basis, export performance data (profile export). b. Perform commissioning testing: i. Customer shall complete and, where necessary, provide the results of commissioning testing per Rule 21, Section L.5.a. c. Permission to Operate (PTO) will be issued if commissioning testing shows compliance with the approved limitations once all the agreements, documentation (such as AHJ release), and all other requirements have been provided and are complete. 5. Operation Performance Phase: a. For systems with telemetry, SCE will monitor the performance of the generating facility. b. For systems that do not have telemetry, the customer must provide quarterly generation output data, which can be used to determine if the generating facility is limiting its output to the approved limits. TIER DESIGNATION Pursuant to OPs 15 and 51, this advice letter is submitted with a Tier 3 designation. EFFECTIVE DATE This advice letter will become effective upon Commission approval. 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: 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:
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ADVICE 4455-E (U 338-E) March 30, 2021 -6- 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: Tara S. Kaushik Managing Director, Regulatory Relations c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: 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 General Order (GO) 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, R.19-09-009, and R.17-07-007 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-3719. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at 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 For questions, please contact Mary J. Brown at (626) 302-8103 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern Gary A. Stern, Ph.D. GAS:dm:cm Enclosures
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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: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 3 Advice Letter (AL) #: 4455-E Subject of AL: Recommendations Regarding Standard Review, Certification Requirements, and Interconnection Processes Pursuant to Decision 20-09-035 Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 20-09-035 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: No. of tariff sheets: -0- 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: None 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
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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: 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: Name: Tara S. Kaushik c/o Karyn Gansecki Title: Managing Director, Regulatory Relations Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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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
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