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Shinjini C. Menon
Managing Director, State Regulatory Operations

November 19, 2021
ADVICE 4422-E-A
(U 338-E)
PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ENERGY DIVISION
SUBJECT:

Supplement to Advice 4422-E, Modifications to Electric Tariff
Rule 21 to Incorporate IEEE 1547.1 Test Procedures into
Testing Regime for Phase 2 and 3 Requirements in
Compliance with Resolutions E-5000 and E-5036

PURPOSE
The purpose of this supplemental advice letter is to update and extend the attestation
timeframe incorporating the Institute of Electrical and Electronic Engineers (IEEE)
1547.1 test procedures into the testing regime for Phase 2 and 3 requirements as
established by Resolution E-5000 and modified in Resolution E-5036.1 SCE will accept
manufacturer attestations as sufficient evidence of compliance with Phase 3 Function 1
(Monitor Key Data) until March 28, 2023. The attestation timeframe has been modified
from November 21, 2021 until March 28, 2023, due to the Underwriters Laboratory (UL)
clarification to the IEEE1547.1 testing standard being published on September 28,
2021.2
The approved IEEE testing procedures or regime for Phase 2 and 3 requirements as
established by Resolution E-5000 and modified in Resolution E-5036 will be clarified in
a future advice letter, which will provide for a dual path where existing Rule 21 Section
Hh will be utilized for available existing technologies and a separate section will allow
technology that complies with requirements under UL1741SB. This provision will allow
the industry to adapt to new requirements as requested by stakeholders in the October
1
2

Resolution E-5000 was effective July 12, 2019. Resolution E-5036 was effective December
5, 2019.
Ordering Paragraph (OP) 5 of Resolution E-5036 reaffirms OP 7 of Resolution E-5000 and
states in pertinent part, “PG&E, SCE, and SDG&E must accept manufacturer attestations
as sufficient evidence of compliance with Phase 3 Function 1 (Monitor Key Data) until 18
months after the publication of a nationally recognized test procedure containing said
function.”

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-3377

Fax (626) 302-6396





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ADVICE 4422-E-A (U 338-E) -2- November 19, 2021 28, 2021 Smart Inverter Working Group (SIWG) meeting. As such, this supplemental advice letter supplements Advice 4422-E in its entirety, extends the attestation timeframe for Phase 3 Functions 1 (Monitor Key Data), and otherwise defers the proposed tariffs and discussion contained within Advice 4422-E to be addressed in a future, standalone advice letter.3 BACKGROUND The Commission initiated Rulemaking (R.)11-09-011 on September 22, 2011, to review and, if necessary, revise the rules and regulations governing the interconnection of generation and storage facilities to the electric distribution systems of SCE, Pacific Gas and Electric Company (PG&E) and San Diego Gas & Electric Company (SDG&E), (collectively, the Utilities). The Utilities’ rules and regulations pertaining to the interconnection of generating facilities are set forth in each of the Utilities’ Commissionapproved Electric Rule 21 Tariffs (Rule 21). On June 23, 2016, the Commission adopted Decision (D.)16-06-052 (Decision), which effectively established the Commission’s clear policy direction toward communications capable smart inverters. The Decision directed the Utilities to file proposed revisions to Rule 21 setting forth any agreed upon technical requirements, testing and certification processes, and effective dates for the Phase 2 communications requirements and Phase 3 advanced functions. On December 20, 2016, SCE submitted Advice Letter (AL) 3532-E establishing these requirements. Resolution E-4832 approved AL 3532-E with modifications and established a mandatory effective date for Phase 2 communications that was defined as: the later of (a) March 1, 2018, or (b) nine months after the release of the SunSpec Alliance communication protocol certification test standard or the release of another industry-recognized communication protocol certification test standard. On March 31, 2017, the Smart Inverter Working Group (SIWG) issued final revisions to the Phase 3 recommendations. SCE submitted AL 3467-E to incorporate the recommendation with proposed Rule 21 tariff revisions that set forth agreed-upon technical requirements, testing and certification processes, and effective dates for the Phase 3 functions. In addition, the Phase 3 ALs proposed revisions to the smart inverters Phase 2 communications. On April 26, 2018, the Commission issued Resolution E-4898 that approved, with modifications, the revisions to Rule 21 put forth in AL 3467-E, thereby adopting the Phase 3 recommendations. 3 The changes proposed herein are made in accordance with General Order (GO) 96-B, General Rule 7.5.1, which authorizes utilities to make additional changes to an advice letter through the submittal of a supplemental advice letter.
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ADVICE 4422-E-A (U 338-E) -3- November 19, 2021 Resolutions E-4832 and E-4898 established the compliance deadlines for the Phase 2 communication requirements and for Phase 3 Functions 1 (Monitor Key Data) and 8 (Scheduling) as nine months after the release of the SunSpec Alliance (SunSpec) communication protocol certification test standard, which set February 22, 2019, as the effective deadline. On November 19, 2018, California Solar & Storage Association (CALSSA) submitted a letter to the Executive Director requesting a six-month extension of this compliance deadline. This request was granted, extending the compliance deadline to August 22, 2019. CALSSA submitted a Petition for Modification (Petition) of Resolutions E-4832 and E-4898 on February 11, 2019, to request that the Commission “include more details and not exceed areas of consensus.” In response to the Petition, the Commission issued Resolution E-5000 that clarified the implementation details of the smart inverter Phase 2 communications requirements and of Phase 3 Functions 1 and 8. In addition, Resolution E-5000 extended the compliance deadlines to January 22, 2020, for: 1) 2) 3) Phase 2 communications requirements; Phase 3 Functions 1 and 8; and Phase 3 Functions 2 (DER Disconnect and Reconnect) and 3 (Limit Maximum Active Power). Resolution E-5000, Ordering Paragraph (OP) 6 ordered the Utilities to submit a Tier 2 Advice Letter within nine months of publication of IEEE 1547.1 proposing the new testing regime and reporting on which elements thereof were supported by the consensus of the SIWG. Additionally, the Utilities are required to report the items of non-consensus. The IEEE 1547.1 test procedures were published May 21, 2020. SCE submitted Advice 4422-E on February 22,2021 in compliance with OP 6 of Resolution E-5000. However, additional processes and procedures have been identified which need to be addressed as mentioned above. DISCUSSION Aligning Rule 21 with IEEE 1547-2018 Resolution E-5000 OP 6 requires the Utilities to work with the SIWG to incorporate the new testing procedures, as appropriate, into the testing regime for Phase 2 and Phase 3 requirements. In order to incorporate the IEEE1547.1 testing procedures into Rule 21, it is necessary that the base standard requirements (IEEE1547-2018) also be incorporated into Rule 21. It is impractical and incomplete to only include the IEEE1547.1 testing procedures without incorporating the base standard requirements. In addition, as these testing procedures account for many functions within the base standard, the Utilities used this opportunity to align all the applicable technical
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ADVICE 4422-E-A (U 338-E) -4- November 19, 2021 requirements for inverter based technology, mainly outlined in Rule 21 Section Hh, to the IEEE1547-2018 standard. SCE proposed changes in Advice 4422-E to align SCE’s Rule 21 tariff to the applicable section of IEEE1547-2018 and IEEE1547.1-2020. However, given the need to develop a dual path as described above, SCE will provide final proposed tariff revisions in a standalone advice letter. Working with the Smart Inverter Working Group Although SCE will be providing a standalone advice letter incorporating the IEEE1547.1 testing procedures into Rule 21, SCE reports herein on the consensus and nonconsensus items discussed with the SIWG in compliance with Resolution E-5000 OP 6. Following the publication of the IEEE 1547.1 test procedures, Resolution E-5000 OP 6 required the utilities to work with the SIWG to incorporate the new procedures, as appropriate, into the testing regime for the Phase 2 and 3 requirements. SIWG discussions commenced on July 23, 2020 and continued through January 2021. Throughout these discussions, the Utilities discussed each Clause of IEEE 1547-2018 and related Rule 21 proposed modifications. In general, these discussions involved the Utilities providing an initial proposal of changes based on a specific IEEE1547-2018 clause. Input from SIWG members was sought for each proposal and revisions were then incorporated based upon stakeholder feedback until consensus or clear nonconsensus was achieved. This process continued until the last SIWG meeting held on January 21, 2021. A total of 11 SIWG meetings were held between July 23, 2020 and January 21, 2021. The process outlined above allowed the Utilities to modify their Rule 21 proposals, which led to consensus proposals to nearly all categories including: • • • • • • • • • • • • • • Applicability of IEEE1547 to interconnection requests at voltage < 50 kV Inclusion of Generating Facility Rapid Voltage Changes Limitations of overvoltage over one fundamental frequency period Limitations of cumulative instantaneous overvoltage events Enter Service ramp controls Storage Inverter Normal Operation Ramp Control requirements Replacement of existing Frequency-Watt function with Frequency-Droop Requirement on measurement and calculation accuracies Prioritization of Smart Inverter requirements Ride-through of consecutive voltage disturbances Restore output without dynamic voltage support Transition between performance operating regions Constant reactive power mode Inclusion of Reference Point of Applicability (RPA) and implication to
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ADVICE 4422-E-A (U 338-E) • • • • • • • -5- November 19, 2021 generating facility operating requirements Update of existing Rule 21 language related to flicker and harmonic distortion Replacement of existing voltage ride-through and trip tables for Section Hh with new IEEE1547-2018 tables Replacement of existing frequency ride through and trip tables for Section Hh with new IEEE1547-2018 tables Update of existing IEEE1547-2003 references to IEEE1547-2018 references Requirement for Rate of Change of Frequency (ROCOF) ride-through requirement Update of reactive power requirements for Smart Inverters and default settings Update to communication requirements Non-Consensus Items The Utilities and SIWG members worked diligently and resolved differences to achieve consensus. However, there appears to be only one item where one SIWG stakeholder did not concur with the Utilities’ proposal, even with the inverter manufacturers supporting the Utilities’ position. This non-consensus issue is related to the default setting for the Frequency-Droop function (the replacement of the existing Rule 21 frequency-watt function). The Utilities propose that this function continues to perform as approved by the Commission in Resolution E-4898. The stakeholder asserted that it would be more appropriate to use the IEEE 1547-2018 default settings given that rest of the industry has not yet adopted the CPUC approved default setting for the frequencywatt function. The Utilities believe that the default settings, as currently utilized, are identical and no more restrictive than what was approved by the Commission in Resolution E-4898. In addition, the Utilities believe that going to a slower frequency-droop default value essentially reduces the capabilities that Smart Inverters can provide to the grid during potential emergency conditions where frequency may deviate from nominal. This requirement has been in place for new Smart Inverters since September 7, 2017 and the Utilities have not received any complaints that this function may be reducing energy production. Therefore, the Utilities’ position is that the Commission-approved default settings should remain. Attestation Requirements Phase 3 Function 1 – Monitor Key Data In accordance with OP 7 of Resolution E-5000, manufacturer attestations are accepted as sufficient evidence of compliance with Phase 3 Function 1 (Monitor Key Data) until 18 months after the publication of a nationally recognized test procedure containing Phase 3 Function 1. IEEE 1547.1 was published on May 21, 2020 with UL clarification
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ADVICE 4422-E-A (U 338-E) -6- November 19, 2021 to the testing standard published on September 28, 2021 and thus 18 months from such day is March 28, 2023. Therefore, attestations for Function 1 requirements would be accepted until March 28, 2023as required by Resolution E-5000. Phase 3 Function 8 - Scheduling OP 8 of Resolution E-5000 allows manufacturer attestations as sufficient evidence of compliance with Phase 3 Function 8 (Scheduling) until 12 months after the publication of a nationally recognized test procedure containing Phase 3 Function 8. Since IEEE 1547-2018 and therefore IEEE 1547.1 did not address Function 8, attestation will continue to be used for compliance with this function as outlined in OP 8 until such time that a nationally recognized test standard is published to address this function. At this time, SCE has no projections as to when this may occur. PROPOSED TARIFF CHANGES Within Advice 4422-E, SCE provided proposed tariff changes to incorporate the IEEE 1547 2018 Standards into Rule 21. California Solar & Storage Association (CALSSA) and Tesla protested SCE’s Advice 4422-E on March 15, 2021. SCE provided its response on March 22, 2021 and concurred with certain comments and changes while disagreeing on others. As explained above, SCE proposes to retract the tariff changes incorporating IEEE 1547 2018 Standards and will address any remaining areas of concerns within the future advice letter. SCE will submit the standalone advice letter implementing the appropriate tariff changes in early 2022. No cost information is required for this advice letter. This advice letter will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule. TIER DESIGNATION Pursuant to OP 6 of Resolution E-5000, this advice letter is submitted with a Tier 2 designation, which is the same Tier designation as Advice 4422-E. EFFECTIVE DATE SCE requests that supplemental advice letter become effective on December 19, 2021, the 30th calendar day after the date submitted. 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
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ADVICE 4422-E-A (U 338-E) -7- November 19, 2021 Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: EDTariffUnit@cpuc.ca.gov 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: Shinjini C. Menon Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-3377 Facsimile: (626) 302-6396 Email: AdviceTariffManager@sce.com 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: Karyn.Gansecki@sce.com 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 GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, R.11-09-011 and R.17-07-007 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com 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 Process_Office@cpuc.ca.gov. 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 https://www.sce.com/wps/portal/home/regulatory/advice-letters.
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ADVICE 4422-E-A (U 338-E) -8- November 19, 2021 For questions, please contact Darrah Morgan at (626) 302-2086 or by electronic mail at Darrah.Morgan@sce.com. Southern California Edison Company /s/ Shinjini C. Menon Shinjini C. Menon SCM: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: AdviceTariffManager@sce.com E-mail Disposition Notice to: AdviceTariffManager@sce.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 4422-E-A Subject of AL: Supplement to Advice 4422-E, Modifications to Electric Tariff Rule 21 to Incorporate IEEE 1547.1 Test Procedures into Testing Regime for Phase 2 and 3 Requirements in Compliance with Resolutions E-5000 and E 5036 Keywords (choose from CPUC listing): Compliance, Rules AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Resolutions E-5000 and E-5036 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: 12/19/21 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: EDTariffUnit@cpuc.ca.gov Name: Shinjini C. Menon 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) 302-3377 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: advicetariffmanager@sce.com 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: karyn.gansecki@sce.com 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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