Details for: SCE's Protest Response to Advice 4559-E IREC.pdf


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Shinjini C. Menon.
Managing Director, State Regulatory Operations

September 10, 2021
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
SUBJECT:

Southern California Edison Company’s Reply to the Protest of Interstate
Renewable Energy Council, Inc., to Advice 4559-E

Dear Energy Division Tariff Unit:
In accordance with General Rule 7.4.3 of General Order (GO) 96-B, Southern California
Edison Company (SCE) hereby replies to the protest of Interstate Renewable Energy
Council, Inc., (IREC) to SCE’s Advice 4559-E.
On August 6, 2021, SCE submitted Advice 4559-E modifying Rule 21, Generating
Facility Interconnections, as required by Decision (D.)20-09-035 (the Decision).1
On September 2, 2021, IREC submitted a late-filed protest to Advice 4559-E.2
I. SCE’s Response to IREC’s Protest
a. IREC’s “Next Steps” Document is Incomplete and Should Not be Adopted
by the Commission
SCE confirms that there was discussion on the “next steps” document
prepared by IREC. However, SCE does not recall agreeing to insert this
incomplete “next steps” document into its advice letter filed August 6,
2021. The “next steps” document was and continues to be incomplete.
Indeed, the last version that SCE reviewed (prior to receiving IREC’s latefiled protest) was a redline draft version of the document. In one of the
last stakeholder calls on this issue, SCE, Pacific Gas and Electric
Company, and San Diego Gas & Electric Company (collectively, the IOUs)
provided feedback to IREC and understood that IREC would recirculate an
updated version based on comments from the groups performing some of
1
2

Decision 20-09-035 was issued September 30, 2020.
Energy Division has indicated it will accept this late-filed protest.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-3377

Fax (626) 302-6396





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Energy Division California Public Utilities Commission September 10, 2021 Page 2 the research activities. IREC has yet to circulate this revised document. Consequently, SCE did not include the “next steps” document in Advice 4559-E. While it is not appropriate to include the “next steps” document within the advice letter, SCE is committed to completing its portion of the analysis and taking additional actions, including updating the appropriate Mm sections of Rule 21 if the analysis demonstrates that updates to these sections will not compromise equipment operations and/or grid safety. b. The Certified Power Control System (PCS) Did Not Reduce Export to the Approved Certified Limit as Intended SCE participated in Working Group 3 and accepted Proposal A-B #1 and A-B #2 based on the working group consensus that the control system would be able to reduce export to the approved limit within a required time (2 seconds or 10 seconds). Ordering Paragraph 49 states: OP 49 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; Contrary to IREC’s representation, SCE is not misinterpreting the Decision to impose additional restrictions. The language in the Decision is clear that the PCS “must be able to reduce export power to the approved export limit within two seconds of exceeding the approved export limit” (emphasis added). To date, the PCS has been unable to meet OP 49’s requirement to “reduce export power to the approved export limit” within two seconds. Accordingly, IREC is now opposed to this requirement notwithstanding that stakeholders agreed to it in Working Group 3.3 It is therefore inaccurate to state that all stakeholders agreed on an approach “and then the IOUs return[ed] at a later time with new or different concerns.” If the PCS had performed as expected (reduced export power to the approved export limit), there would be no issues and the Ordering Paragraphs would have been effective and the PCS option available for use by customers. 3 See Working Group 3 Final Report, p. 131 (noting Proposal A-B#1 was a “consensus” proposal).
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Energy Division California Public Utilities Commission September 10, 2021 Page 3 SCE is unable to ignore the export associated with these systems without evaluating the risks. However, SCE is committed to continuing to work on these issues with stakeholders. Indeed, SCE and stakeholders already agreed to add language to Sections Mm1 and Mm2 to bring the requirement closer to the PCS operational performance.4 Moreover, when sufficient information is available that shows that there are no safety issues due to the performance of the PCS, SCE would be supportive of reviewing and modifying the requirements. c. Section Mm1 Received Consensus from IOU and Non-IOU Stakeholders IREC states that Section Mm1 needs revision to clearly state that projects will be treated as non-export during the screening process. IREC provided the proposed language in an email dated July 26, 2021. It is therefore inappropriate for IREC to propose additional changes via protest after the stakeholder process has concluded. In any event, the proposed language is unnecessary. For projects that meet the requirements of Section Mm1the response to Screen I (will power be exported across the PCC) would be “NO” and the project would therefore bypass Screens J, K, L, M, N, O, and P (with few exceptions for larger projects (>600KVA) with Steady State>1%). d. All Exporting Generating Facilities Under Section Mm4 Must be Queued 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 and all exporting generators are part of the queue and are used to study subsequent interconnection requests. The language remains for Mm3, inadvertent export, because it is not expected that all projects would be in inadvertent export mode at the same time. However, Section Mm4 addresses exporting generators that are expected be exporting at the same time, so they must be studied as such. e. IREC Proposes Modifications That Eliminate Approved Tariff Language and Adopt Undefined Terms 4 SCE added the following language to address the fact that the PCS cannot meet the Decision’s requirements: “A PCS that is certified with an open-loop response time of two seconds or less, and a time to reach steady state of 10 seconds or less, meets this requirement.”
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Energy Division California Public Utilities Commission September 10, 2021 Page 4 SCE opposes IREC’s proposed modifications to its Interconnection Application forms as follows: Form 14-918 - Rule 21 Exporting Generating Facility Interconnection Request Section 2.A of Attachment A was not modified in Advice 4559-E and IREC’s changes should be rejected to retain existing, approved tariff language and consistent terminology throughout Form 14-918. IREC suggests replacing “rated output” with “Gross Nameplate Rating.” Rated output is existing language that is not capitalized and therefore not intended to represent a Rule 21 defined term. Additionally, rated output is used consistently in both Form 14-918 and Rule 21. IREC suggests replacing “operating capacity” with “Generating Profile.” Generating Profile is not a defined term and is not used anywhere in Rule 21 or Advice 4559-E. Therefore, this suggested change should be rejected. IREC suggests that SCE add “power” to the term “certified power control system.” SCE agrees and will make the change in a supplemental advice letter. The term “net capacity” in Section 2.C of Attachment A was not modified in Advice 4559-E and IREC’s changes should be rejected to retain approved tariff language and consistent terminology throughout Form 14918 and Rule 21. Form 14-732, Generating Facility Interconnection Application IREC suggests SCE consider adding Protection Option #9 in section C; however, no changes related to Option #9 are required. This Option is correctly listed in Form 14-918, which is the Rule 21 Exporting Generating Facility Interconnection Request form.
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Energy Division California Public Utilities Commission September 10, 2021 Page 5 II. Conclusion SCE appreciates the opportunity to submit this reply to IREC’s protest. Southern California Edison Company /s/ Shinjini C. Menon Shinjini C. Menon SCM:mb:jm cc: Edward Randolph, Director, CPUC Energy Division Sky C. Stanfield, IREC Service Lists SCE’s GO 96-B and R.17-07-007
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