Details for: SDG&E Protest Reply_AL 3822-E_IREC.pdf

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Clay Faber - Director
Regulatory Affairs
8330 Century Park Court
San Diego, CA 92123-1548

September 10, 2021
Energy Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, California 94102

Reply to Protest of SDG&E Advice Letter 3822-E

In accordance with Section 7.4.4 of General Order (GO) 96-B, San Diego Gas &
Electric Company (“SDG&E”) hereby replies to Energy Division’s approval of the late
protest submitted by Interstate Renewable Energy Council, Inc. (IREC) to SDG&E’s
Advice Letter (“AL”) 3822-E – San Diego Gas & Electric Company Modifications to the
Electric Rule 21 Interconnection Application Process for Non-Export, Limited Export,
and Inadvertent Export Pursuant to Decision 20-09-035.
On August 6, 2021, SDG&E submitted AL 3822-E requesting authority from the
California Public Utilities Commission (“Commission or CPUC”) to modify Rule 21 in
compliance with Ordering Paragraphs (“OPs”) 7, 49, and 50 of Decision 20-09-035 (“the
Decision”). On September 2, 2021, IREC submitted a late protest to SDG&E AL 3822E. Energy Division subsequently notified the service list that the protest was accepted
and that the IOUs must reply within five business days. SDG&E replies to each issue
raised in IREC’s protest below.
1. Protest: The requirements in the newly added Mm1 through Mm4 are
unduly restrictive and are only acceptable as a temporary solution.
SDG&E supports revisiting existing criteria in the future, based upon new empirical data
to avoid or add requirements.
2. Protest: No evidence indicates that an open loop response time of 2 or 10
seconds is insufficient to ensure the safe and reliable operation of the grid,
and it is not rational to conclude that the Decision imposes additional
SDG&E argues the opposite: no evidence existing to indicate the open-loop response
time of 2 or 10 seconds is sufficient to ensure safety and reliability, especially given
expected accelerated adoption of energy storage to meet state resiliency, Senate Bill
100, and other goals. IREC accuses that to “interpret the language in the Decision as


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Protest Reply to SDG&E AL 3822-E 2 September 10, 2021 imposing additional restrictions beyond the open loop response time is not rational.” However, Ordering Paragraph (OP) 49 states: ii) use a power control system that has an open-loop response time of no more than two seconds, as provided in the control systems specification data sheets, and must be able to reduce export power to the approved export limit within two seconds of exceeding the approved export limit” (emphasis added) SDG&E does not misinterpret the OP language and is concerned with indulging this protest issue any further, given extensive stakeholder discussions acknowledging and agreeing on the existence of a problem here. Still, the language in the Decision is unquestionably clear: “must be able to reduce export power to the approved export limit within two seconds of exceeding the approved export limit.” It is IREC who misinterprets this language. In fact, as acknowledged within AL 3822-E, the IOUs and Stakeholders agreed to add language to ensure compliance with the OP 49 ii) requirement to “reduce export power to the approved export limit” as agreed on by IREC and all stakeholders within the Working Group 2 report. The reality is the PCS has fallen short of its expectations and cannot meet the performance requirements of OP 49 to “reduce export power to the approved export limit.” When IREC realized that the PCS control system could not perform as required by the Decision, IREC backtracked from on the consensus proposal in the Working Group 2 report. IREC’s comment that this is “essential to avoid a repeat of this process, where all stakeholders first agree on an approach, and then the IOUs return at a later time with new or different concerns” is misdirected. Non-IOU stakeholders, including IREC, changed their positions from what they had agreed on in Working Group 2 report once IREC realized that the PCS was not able to perform as expected. The IOUs and stakeholders are in this situation because the PCS did not meet the requirements that we anticipated. If the PCS had performed as expected by reducing export power to the approved export limit, there would not be issues and the requirements would now be available for customers. We cannot ignore safety concerns for the sake faster interconnections. However, SDG&E is committed to continuing the work on these issues with stakeholders. When sufficient information is available that shows that there are no safety issues due to the performance of the PCS, then at that point SDG&E can support modifications to the requirements. Until then, we must be conservative. 3. Protest: Section Mm1 needs revision to clearly state that projects will be treated as nonexpert during the screening process. Section Mm1 was agreed on by both IOU and non-IOU stakeholders. SDG&E is confused about this protest. In AL 3822-E, SDG&E proposed the exact language that
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Protest Reply to SDG&E AL 3822-E 3 September 10, 2021 was sent by IREC. 1 SDG&E is puzzled and frustrated that IREC now protests its own proposed language, delaying the utilization of these new options for customers and further straining IOU resources on this issue. Further, as it relates to section Mm1, there was no conversation to include anything related to screen N within section Mm1, because projects under section Mm1 would not make it to Supplemental Review (Screen N). These projects are considered non-export and thus the response to Screen I (will power be exported across the PCC) would be a “No.” The projects will then bypass Screens J, K, L, M, N, O, and P. There is some exception for larger projects (i.e., those greater than 600 kilovolt amperes) with a steady state greater than one percent. But again, all this language was agreed on and should not require additional language. 4. Protest: Section Mm4 is Missing Part of the Consensus Language. The proposed language, “Use only the largest facility in the line section for aggregate evaluation for subsequent interconnection requests” was intentionally removed from Section Mm4 because Section Mm4 is for exporting generators. All exporting generators are part of the queue and are used to study subsequent interconnection requests. The language remains for Section Mm3, which is inadvertent export and where it is not expected that all projects would be in the inadvertent export mode at the same time. However, these are exporting generators and are studied according to the expectation that they will exporting at the same time. 5. Protest: PG&E’s proposed language contains minor inconsistencies with the language proposed by the other IOUs in three places. This issue does not apply to SDG&E. 6. Protest: SCE proposes to revise its Interconnection Application forms, but PG&E and SDG&E have not. SDG&E agrees to revise its Interconnection Application Form consistent with SCE’s proposed revisions. CONCLUSION For the reasons set forth in this reply, the Commission should approve SDG&E’s Advice Letter 3822-E without undue delay. /s/ Clay Faber Clay Faber Director – Regulatory Affairs 1 Email from Sky Stanfield at 11:58 a.m. on July 26, 2021.
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Protest Reply to SDG&E AL 3822-E CC: 4 Sky Stanfield, IREC ( Eric Jacobson ( Gary A. Stern ( Tara S. Kaushik ( Service List: R.17-07-007 September 10, 2021
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