Details for: PGE Reply to Protest of AL 6141-E.pdf

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Erik Jacobson
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

April 26, 2021
California Public Utilities Commission - Energy Division
Tariff Unit
505 Van Ness Avenue, 4th Floor
San Francisco, CA 94102

Pacific Gas and Electric Company’s Reply to the Protest from
Interstate Renewable Energy Council, Inc. to Advice Letter 6141-E –
Modification of Electric Rule 21 for Qualifying Non-export and
Limited Export Inverters to Use a Time-of-Year Maximum Monthly
Export Value Settings Pursuant to Decision 20-09-035 Ordering
Paragraphs 51 and 15

Dear Energy Division Tariff Unit:
In accordance with the California Public Utilities Commission (“CPUC” or “Commission”)
General Order 96-B, Section 7.4.3 Pacific Gas and Electric Company (“PG&E”)
respectfully submits this Reply to the April 19, 2021 protests of The Interstate
Renewable Energy Council, Inc. (“IREC”), titled (“IREC’s Protest to San Diego Gas &
Electric’s Advice Letter 3721-E, Pacific Gas & Electric’s Advice Letter 6141-E, and
Southern California Edison’s Advice Letter 4455-E – Implementing Limited Generation
Profiles Pursuant to Decision 20-09-035”) to PG&E’s Advice Letter (“AL”) 6141-E 1
submitted as Tier 3 pursuant to California Public Utilities Commission (“CPUC” or
“Commission”) Decision (“D”). 20-09-035 2, Ordering Paragraphs (“OP”) 15 and 51.
On March 30, 2021, PG&E submitted AL 6141-E to address D. 20-09-035 OPs 15 and
51. The other Utilities 3 did similarly. The OPs 15 and 51 address:


AL 6141-E – Advice Letter Modifying Electric Rule 21 Pursuant to Decision 20-09035 for
Working Group 2 and 3 (due 120 Days from Issuance) for Ordering Paragraphs 5, 6, 8 and
11 - submitted January 28, 2021
Decision 20-09-035 - Date of Issuance 9/30/2020 - Decision Adopting Recommendations
from Working Groups Two, Three, and Subgroup
The Utilities consist of Pacific Gas and Electric Company (PG&E), Southern California Edison
Company (SCE) and Southern California Gas & Electric Company (SDG&E).


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PG&E Reply to Protest of Advice Letter 6141-E -2- April 26, 2021 (i) (Ordering Paragraph (“OP”) 15) resolves Issue 9 by modifying the Rule 21 Interconnection Application Process to allow a distributed energy resources customer to include a Limited Generation Profile with their application, require the customer to enable generation profile limiting functionality, and allow Utilities opportunity to alter the profile if safety and reliability concerns warrant it. (ii) (Ordering Paragraph (“OP”) 51) allows an inverter approved for non-export and limited export to be set using different maximum monthly export value settings at different times of the year, when meeting the qualifications for either Rule 21 Working Group 3 Proposal A-B 1 or A-B 2; and In its protest of PG&E’s AL 6141-E, IREC cited/recommended: 1. QUARTERLY REPORTING IREC argues, the Utilities are not authorized to add new reporting requirements to verify that a certified system does what it is certified to do. 2. LIMITED EXPORT VALUES DISALLOWED AL 6141-E in the review screens fails to allow the use of Limited Export Values instead of Gross Nameplate Rating when qualifying power control systems are used. 3. CONSISTENT IMPLEMENTATION BETWEEN UTILITIES’ ALs IREC argues the Energy Division should ensure the consistent resolution of similar issues raised in different advice letters. The issues raised in the March 30 Advice Letters are interrelated with issues IREC raised when protesting the earlier advice letters implementing D.20-09-035 submitted on October 30, 2020 and January 28, 2021. 4. NON-CERTIFIED DEVICES TO USE LIMITED GENERATION PROFILES IREC suggests non-certified devices be allowed to use Limited Generation Profiles by mutual agreement. 5. ALIGN THE TIMELINES FOR IMPLEMENTATION OF OPS 15 AND 51.
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PG&E Reply to Protest of Advice Letter 6141-E -3- April 26, 2021 PG&E’S Response to Protest of AL 6141-E 1. Quarterly Reporting a. PCS Export Reporting Issues IREC notes that in AL 6141-E sections 4.a.iii and 5.b respectively call for ”the customer 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.” IREC cites numerous reasons to argue that these reporting requirements are “not appropriate or necessary nor discussed.” PG&E’s Response The Utilities have provided multiple opportunities for party comment through Smart Inverter Working Group (SWIG) discussions on proposed OP15 implementation with active IREC participation. Notably, the Utilities presented SWIG slides for incorporating customer Limited Generation Profile-elected 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, the quarterly reporting requirement could be as minimal as providing maximum monthly output values and timestamps. This would only constitute 24 datapoints a year for a Utility to verify customer’s Power Control Systems abides by the Limited Generation Profile values approved through the interconnection process. IREC incorrectly implies that installing a certified system is the only requirement needed to operate a system safely and reliability. Good Utility Practice is to verify that installed systems (especially those using new or newly certified equipment) are performing as expected. 2. Limited Export Values VS Gross Nameplate Rating. a. Use Limited Export Values not Gross Nameplate Rating. D.20-09-035 Proposal A-B 1 is a consensus position which allows a Power Control System with an open-loop response time of 2 seconds or less to use the “limited export value . . . in Screens D, I, J, K, M, N, O, and P.”
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PG&E Reply to Protest of Advice Letter 6141-E -4- April 26, 2021 IREC notes, the Utilities “Propose evaluating Screens D, I, J, and K using Gross Nameplate Rating instead of the limited export value” per proposal A-B 1” and contends the Utilities should not use the Gross Nameplate Rating. Furthermore, IREC believes “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.” PG&E’s Response The issues of using gross nameplate rating was discussed at multiple meetings. PG&E is confused as to why this issue should be coming up again at this time. Note that OP 15 addressing Working Group #2 Issue 9 and Working Group #3 Issue A-B 3 were combined on AL 6141-E. The combining of these two issues was agreed on by 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 OP 51 (proposal A-B #3). Given that ICA-SG values do not account for screen D, J, K it is appropriate to evaluate screen D using nameplate. Further Screen I is a question of export vs non-export and because all LGP project are will be exporting projects, then screen I is not relevant. 3. Reductions to Limited Generation Profile – Consistency in ALs IREC points out the January 28 D. 20-09-035 advice letters concerning whether and how the Utilities may require reductions to Limited Generation Profiles were protested by IREC as lacking specific, defined conditions. In the Utilities’ protest responses additional discussions were proposed. AL 6141-E did not provide any additional specificity. As of now, IREC notes, still no proposals exist. PG&E’s Response 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, 4 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 PG&E’s 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. 4 Working Group 2 Report at p. 123.
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PG&E Reply to Protest of Advice Letter 6141-E -5- April 26, 2021 PG&E is committed to finding a resolution that is fair for all interconnection applicants (Rule 21 and WDAT) and that does not create safety concerns. PG&E will submit a supplemental advice letter which will include input received during the SIWG meetings. 4. Use of Limited Generation Profiles for non-certified devices IREC claims customers may want to implement Limited Generation Profiles using non-certified devices and IREC would be open to discussing this proposal at the SWIG. PG&E’s Response PG&E does not agree that non-certified devices be used for LGP by mutual agreement. First, OPs 15 and 51 require the use of certified inverter systems. Second, these types of open-ended requirements often lead to disagreements between parties which then leads to customer complaints and delays in the interconnection process. Third, use of certified systems ensures consistency. And last but not least, the review and approval of non-certified devices takes time, which could be utilized on other interconnection issues to better serve customers. There have been other areas where utility discretion (mutual agreement) was allowed and that led to inconsistency in requirements and application, which in turn led to disputes especially when developers install projects across utility boundaries which may have different requirements. In such cases, the Commission has rules that requirements become more specific as to prevent disagreements. 5 5. ED should align the timeline for implementation of OPs 15 and 51. a. Timelines IREC believes, the Utilities should file a Tier 2 Advice Letter modifying Rule 21 to allow the use of Limited Generation Profiles within 60 days of adoption of a certification scheme for the Limited Generation Profile; those revisions should be effective within 9 months and IREC supports that OPs 15 and 51 should be implemented together as one proposal. IREC feels that to reconcile these different dates for the same requirement, the Energy Division should require the Utilities (i) “to file a Tier 2 Advice Letter modifying Rule 21 to allow the use of Limited Generation Profiles within 60 days of adoption of a certification scheme for the Limited Generation Profile” and (ii) “to implement the entire proposal within 9 months”. 5 D.19-03-013 at Page 25
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PG&E Reply to Protest of Advice Letter 6141-E -6- April 26, 2021 b. Technical requirements for Power Control Systems in Rule 21 IREC also requests the Commission require the Utilities to publish the technical requirements necessary for Power Control Systems to take advantage of Limited Generation Profiles in Rule 21 within 60 days of adoption of a certification scheme for the Limited Generation Profile. PG&E’s Response PG&E does not support a requirement to publish Limited Generation Profile 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. PG&E will commit to publishing technical requirements after observing the application of installed projects and learning the technical aspects of the control system. IREC notes PG&E’s table on Page 8 of AL 6141-E comparing the requirements of the two OPs mistakenly switched the requirements for OP 15 and 51. PG&E regrets this error and is submitting a correction. Conclusion PG&E appreciates IREC’s comments, and where noted above will work to resolve the outstanding issues where mentioned above. Otherwise, AL 6141-E should be approved as submitted. Sincerely, /S/ Erik Jacobson Director, Regulatory Relations cc: Yochanan Zakai, IREC Service Lists R.17-07-007, R.11-09-011
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