Details for: SDGE Protest Reply to AL 3721-E.pdf

Click on the image for full size preview

Document data

Clay Faber – Director
Regulatory Affairs
8330 Century Park Court
San Diego, CA 92123

April 26, 2021

ED Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, California 94102
Subject: San Diego Gas & Electric Company (SDG&E) Reply to Protest of Advice
Letter 3721-E
In accordance with Section 7.4.3 of General Order 96-B, San Diego Gas & Electric
Company (SDG&E) hereby replies to the protest submitted by Interstate Renewable
Energy Council, Inc. (IREC) of Advice Letter (AL) 3721-E, San Diego Gas & Electric
Company’s Recommendations Regarding Standard Review, Certification
Requirements, and Interconnection Processes Pursuant to Ordering Paragraph 15 of
Decision 20-09-035.
On March 30, 2021, SDG&E submitted a Tier 3 AL to the California Public Utilities
Commission (Commission) pursuant to Ordering Paragraph (OP) 15 of Decision 20-09035 (the Decision).
On April 19, 2021, IREC filed its timely protests to SDG&E AL 3721-E and the
corresponding Pacific Gas and Electric Company’s AL 6141-E and Southern California
Edison’s AL 4455-E (collectively, the IOUs).
D.20-09-035 OP 15 required SCE, SDG&E, and PG&E (the Utilities) to commence
discussions with the Smart Inverter Working Group (SIWG) focused on implementing
the Utilities’ counter proposal to resolve Issue 9.
On December 15, 2020, the Utilities held the first SIWG meeting discussing these
complex issues. Meetings continued through March 4, 2021 for a total of five meetings.
During these meetings, the SIWG discussed the following topics:


- Page 1 -

Public Utilities Commission Protest Reply – AL 3721-E      2 April 26, 2021 Requirements for the customer project preparation phase, which include downloading and analyzing available Integration Capacity Analysis (ICA) data and using such data to prepare Limited Generation Profile (LGP) values Determination of what additional project location information is needed (e.g., circuit name, node identifier, day that data was extracted) Study processes for LGP-type requests, which include the use of nameplate capacity for queue management and determining impact to subsequent projects and addressing cases where one or more monthly LGP values in the application request is greater than the corresponding lowest monthly ICA Static Grid (ICASG) value Interconnection agreements, field verification, and issuance of Permission to Operate (PTO) Verification of performance requirements. Stakeholders did not request that any additional topics be discussed. IREC protests the IOU ALs, citing that they are inconsistent with D.20-09-035. SDG&E responds to IREC’s protest below.  Rule 21 should not require quarterly reports of certified system performance. IREC protests that the customer must “provide in a quarterly basis export performance data (profile export) on a quarterly basis to the utility” and “For systems which do not have telemetry, the customer must provide quarterly generation export data which can be used to determine if the generating facility is limiting its export to the approved limits.”1 The IOUs presented their proposal to require LGP projects, which do not provide telemetry, to provide quarterly generation output data during the first Smart Inverter Working Group (SIWG) meeting held on December 15, 2020. Discussions on this topic continued in subsequent meetings held January 7, 2021, January 21, 2021, February 18, 2021, and March 4, 2021. Stakeholders, including IREC, did not object to this requirement during the SIWG meetings. Notably, the IOUs presented their proposed approach for incorporating customer elected limited generation profile (LGP) applications where the final workflow step is for customers to provide quarterly reports of certified system performance. While the specific output data and granularity were not mentioned within SDG&E’s Tier 3 AL 3721-E, the quarterly reporting requirement could be as minimal as providing maximum monthly output values and timestamps. This would only constitute 24 datapoints per year for an IOU to verify that the customer’s power control system (PCS) abides by the LGP values approved at the time of interconnection. 1 IREC protest at 3.
- Page 2 -

Public Utilities Commission Protest Reply – AL 3721-E  3 April 26, 2021 Screens should use Limited Export Values instead of Gross Nameplate Rating in certain circumstances. IREC asserts that the IOUs “should not use the Gross Nameplate Rating when evaluating Screens D, I, J, K, M, N, O, and P for Power Control System with an openloop response time of 2 seconds or less. The Advice Letters should also discuss the consideration of limited export values in Supplemental Review pursuant to Order Paragraph 50 and proposal A-B 2.”2 Using the LGP in lieu of gross nameplate rating within Rule 21 screens is imprudent, as subsequent revisions to LGP through OP 16 implementation can change the original agreed-upon generation output. Not studying the generation nameplate rating impair the IOU’s ability to implement subsequent upward revisions in allowable generation. SDG&E’s AL 3721-E attempted to reconcile the OP 15 requirement to address Issue 9 with OP 51 requirement for Proposal A-B 3, consistent with agreement in the SIWG (including IREC). Because OP 9 requires that ICA-SG values be used, then the same utilization of ICA values must be applied to implement Proposal A-B 3. Given that ICASG values do not account for screens D, J, and K, then it is appropriate to evaluate screen D using gross nameplate rating. Further, Screen I is a question of export versus non-export; because all LGP projects will be exporting projects, then screen I is irrelevant. Additional Screens M, N, O & P should be studied at the gross nameplate capacity such that an IOU’s ability to implement subsequent upward LGP revisions in allowable generation is not impaired.  The IOU’s have not yet addressed reductions to Limited Generation Profiles. IREC incorrectly states the Utilities did not discuss reductions to LGP within the SIWG. The Utilities discussed this issue during both the February 18, 2021 and March 4, 2021 SIWG meetings. As indicated in the Working Group 2 Report,3 there are known complexities with the application of limited generation that may affect if and how limitations to approved values are developed, including:  Lack of infrastructure or systems to realize the needed generation reductions;  Impact to subsequent interconnection requests, especially those that interconnect under the Wholesale Distribution Access Tariff;  A determination of what systems are needed to operationalize these rules (including the reduction of power production rules); and  Complexities in modeling and how it affects other modeling requirements, such as those needed to develop the ICA values as required by D.17-09-026. SDG&E is continuing to collaborate with the SIWG on implementation of D.20-09-035 requirements related to ICA and LGP in a way that is fair to all applicants. To that end, 2 3 Id. at 6. Working Group 2 Final Report, at 123.
- Page 3 -

Public Utilities Commission Protest Reply – AL 3721-E 4 April 26, 2021 SDG&E will supplement AL 3721-E based upon the outcome of SIWG discussions.  The IOUs should allow non-certified devices to use Limited Generation Profiles by mutual agreement. IREC asserts that developers (1) should not provide quarterly generation output reports to ensure compliance with signed interconnection agreements and (2) should not be bound by any nationally approved PCS certification. 4 Implementing policies with lacking accountability on high-voltage systems pose a safety and reliability threat to all interconnected customers. SDG&E believes that LGP inverter settings should be vetted through national standards development organizations working on smart inverter requirements, who have robust testing and vetting practices to safely implement distributed generation.  The Energy Division should align the timeline for implementation of Ops 15 and 51. SDG&E agrees that OP15 should be implemented within the same timeframe as OP 51.  The Commission should require Rule 21 to include all technical requirements for Power Control Systems until more experience is obtained. SDG&E does not support a requirement to publish LGP technical requirements within 60 days of adoption of a certification scheme. The Utilities must have experience using the UL Power Control Systems to adequately develop these technical requirements. Specifying requirements now will be premature and could result in revised requirements being added later. The current version of the single limit UL Power Control standard has demonstrated numerous issues in its control capabilities, which further justifies the need for Utilities to have experience with these control systems before specifying requirements. 4 IREC protest, at 7.
- Page 4 -

Public Utilities Commission Protest Reply – AL 3721-E 5 April 26, 2021 CONCLUSION SDG&E appreciates the opportunity to submit this reply to the protests of AL 3721-E. /s/ Clay Faber CLAY FABER Director – Regulatory Affairs cc: Yochanan Zakai IREC ( Eric Jacobson ( Gary A. Stern ( Tara S. Kaushik ( Service List: R.17-07-007
- Page 5 -