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DRAFT

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

AGENDA ID # 16697ENERGY DIVISION RESOLUTION E-4944

August 23, 2018

R E S O L U T I O N

Resolution E-4944. Formats and implementation of annual Grid Needs Assessment and Distribution Deferral Opportunity Report filings, pursuant to Decision 18-02-004.

PROPOSED OUTCOME: • This Resolution approves formats with modifications for

PG&E and SCE’s annual Grid Needs Assessment and Distribution Deferral Opportunity Report filings and rejects SDG&E’s proposed formats.

• This Resolution approves all three of the IOUs’ implementation workplans.

• This Resolution orders SDG&E to complete its GNA and DDOR consistent with either PG&E or SCE and the changes ordered herein.

SAFETY CONSIDERATIONS:• There are no safety considerations.

ESTIMATED COST: • This Resolution entails no incremental costs.

Decision 18-02-004 established a memorandum account to record the incremental costs of implementing the Grid Needs Assessment and Distribution Deferral Opportunity Report.

By Pacific Gas and Electric Company Advice Letter 5277-E, Southern California Edison Company Advice Letter 3787-E, and San Diego Gas & Electric Company Advice Letter 3211-E filed on April 16, 2018.

__________________________________________________________

218224376 1

Resolution E-4944 DRAFT August 23, 2018PG&E AL 5277-E, SCE AL 3787-E, SDG&E 3187-E/mm7

SUMMARY

On April 16, 2018, Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), and San Diego Gas & Electric Company (SDG&E)—collectively, the Investor-Owned Utilities (IOUs)—filed Advice Letters (ALs) 5277-E, 3787-E, and 3211-E, respectively, proposing formats and implementation workplans for their annual Grid Needs Assessment (GNA) and Distribution Deferral Opportunity Report (DDOR) filings in compliance with Ordering Paragraph (OP) 2.k of Decision (D.)18-02-004. This Resolution approves the IOUs’ proposed implementation workplans and adopts formats for the annual GNA and DDOR filings. PG&E and SCE’s GNA and DDOR formats are approved with modification. SDG&E’s format is rejected and SDG&E is ordered to use either PG&E or SCE’s format for their 2018 GNA and DDOR.

BACKGROUND

The GNA and DDOR are foundational elements of the annual Distribution Investment Deferral Framework, enabling the Commission and stakeholders to ensure that candidate distribution deferral projects proposed by IOUs maximize the ratepayer benefits of distributed energy resources.

On August 14, 2014, the Commission issued Rulemaking (R.)14-08-013 to establish policies, procedures, and rules to guide California IOUs in developing Distribution Resource Plans (DRPs) required by Public Utilities (P.U.) Code §769. On October 21, 2016, the Commission issued the Assigned Commissioner’s Ruling on Track 3 Issues, which included consideration of a Distribution Investment Deferral Process as the third Sub-track of DRP Track 3.

Subsequently, the Commission issued D.18-02-004 (the Decision) on February 15, 2018 approving an annual Distribution Investment Deferral Framework (DIDF) whose central objective is to identify and capture opportunities for distributed energy resources (DERs) to cost-effectively defer or avoid traditional IOU investments that are planned to mitigate forecasted deficiencies on the distribution system. The

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Decision adopted two new IOU reports that serve as the foundation of the annual DIDF: the GNA and DDOR. The GNA, due June 1 of each year, documents the assumptions and results of the annual distribution planning process, while the DDOR, due September 1 of each year, presents the planned investments needed to address deficiencies identified in the GNA, as well as a candidate distribution deferral opportunity shortlist determined by applying an approved set of deferral screening criteria to the list of planned investments.

Both reports serve the purpose of providing transparency into the annual distribution planning process, such that the Commission and stakeholders can ensure that the DIDF meets the objectives of maximizing ratepayer benefits by sourcing cost-effective DERs that satisfy distribution planning objectives per P.U. Code §769. Specifically, the reports are the main inputs to the Distribution Planning Advisory Group (DPAG)—consisting of IOUs, Commission staff, DER market participants, and other interested stakeholders—whose main charge is to advise and recommend to the IOUs distribution deferral opportunities, identified in the DDOR candidate deferral shortlist, that should be issued for solicitation. The GNA provides the necessary background information on the distribution planning process that allows the DPAG to evaluate the IOUs’ candidate shortlist and advise the IOUs on recommended deferral projects. D.18-02-004 adopted several requirements for the annual GNA and DDOR filings pertaining to data attributes, display, and formatting.

Section 3.4.1. of D.18-02-004 outlines the following requirements by which the IOUs are to organize and populate their annual GNA and DDOR filings:

General GNA and DDOR Requirements

Data shall be made available in map form, as a pop-up layer atop the circuit models being developed for the [Integration

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Capacity Analysis] (ICA), and in downloadable, machine-readable datasets

Datasets shall be organized by the circuits or geographic region containing each identified grid need, planned investment, and candidate deferral pertaining to one of the four distribution services adopted by D.16-12-036

Each grid need, planned investment, and candidate deferral will occupy its own row in its respective database. There may be multiple items, and thus multiple rows, for an individual circuit or region, while circuits or regions without grid needs or planned investments should be identified as such.

GNA-Specific Requirements

Circuit level planning assumptions: the GNA shall include the following planning assumption data for each substation and circuit over a five-year forecast horizon. This data should be integrated into the GNA map layer, but provided in a separate dataset:

1. Demand and DER Growth Forecast2. ICA planning values based on trajectory case demand and

DER growth assumptions

GNA contents: The GNA will present a report of the grid needs that result from the annual distribution planning process. Each grid need shall be characterized by the following attributes:

1. Substation, Circuit, and/or Facility ID: identify the location and system granularity of grid need

2. Distribution service required: capacity, reactive power, voltage, reliability, resiliency, etc.

3. Anticipated season or date by which distribution upgrade must be installed

4. Existing facility/equipment rating: MW, kVA, or other

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5. Forecasted percentage deficiency above the existing facility/equipment rating over five years

DDOR-Specific Requirements

Planned investments: The DDOR will present a report of the IOUs’ planned investments that provide one or more of the four distribution services adopted by D.16-12-036 in the Integrated Distributed Energy Resource (IDER) Proceeding. Each planned investment shall be characterized by the following attributes:

1. Project description 2. Substation3. Circuit4. Deficiency (MW/kVA, %)5. Project type: Type of equipment to be installed6. Project description: Additional identifying information7. Distribution service required: capacity, reactive power,

voltage, reliability, resiliency, etc.8. In-Service Date9. Deferrable by DERs, Y/N?10. Estimated [Locational Net Benefits Analysis] (LNBA)

Range

Candidate deferral projects: The DDOR will also present the candidate deferral project shortlist that results from applying initial deferral screens to planned investments. Each candidate deferral project shall be characterized by the following attributes:

1. General geographic region of deferral opportunity, where appropriate, and/or specific location (e.g., Substation, Circuit, and/or Facility ID)

2. In-Service Date3. Distribution Service required

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4. Expected performance and operational requirements (e.g., season needed, day(s) needed, range of expected exceedances/year, expected duration of exceedances)

5. Expected magnitude of service provision (MW/kVA)6. Estimated LNBA range7. Unit cost of traditional mitigation

GNA and DDOR data reporting requirements will be subject to DRP data redaction criteria established to ensure customer privacy and the physical and cyber security of the distribution system. D.18-02-004 OP 2.g ordered the IOUs to propose data redaction criteria in Tier 2 ALs, which were filed on April 16, 2018.1 However, the assigned Administrative Law Judge (ALJ) issued a ruling on June 8, 2018 ordering the IOUs to file motions requesting confidential treatment of information pursuant to General Order (GO) 66-D. The IOUs complied and filed motions on June 15, 2018, with stakeholder responses filed June 22, 2018. The ALJ will issue a ruling setting consistent DRP data redaction criteria across the three IOUs.

D.18-02-004 Ordering Paragraph 2.k orders the IOUs to propose work plans by which they will develop and implement GNA and DDOR data compilation and reporting capabilities, and to propose formats for the GNA and DDOR datasets based on Section 3.4.1 requirements.

D.18-02-004 recognized that the GNA and DDOR data and reporting requirements would entail a significant implementation effort on behalf of the IOUs in terms of modernizing the IOUs’ planning tools, developing new information technology and analytics capabilities, and honing internal work flows by which the annual planning exercise is completed. To launch this effort, OP 2.k orders the IOUs to propose work plans by which they will develop and implement the data compilation and reporting capabilities needed to complete the annual GNA and DDOR exercise, including a high-level description of the steps necessary to develop such internal capabilities and estimated

1 PG&E AL 5276-E, SCE 3786-E, and SDG&E 3210-E

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interim milestones. Given the size and tight timelines associated with this implementation effort, OP 2.j allows the IOUs to file their 2018 GNAs with the best available data in the first year,2 and orders full GNAs to be filed June 1, 2019. The full DDOR, however, is due September 1, 2018.

Furthermore, while Section 3.4.1. establishes a number of requirements pertaining to the content and layout of the annual GNA and DDOR filings, the Decision did not prescribe an exact format for these two reports. Instead, OP 2.k orders the IOUs to propose formats for the GNA and DDOR datasets based on the most effective representations of the data attributes laid out in Section 3.4.1.

OP 2.k required the IOUs to file both proposals in a Tier 3 AL within 60 days of the issuance of the decision.

The IOUs filed their GNA and DDOR implementation workplans and formats on April 16, 2018.

D.18-02-004 was issued February 15, 2018. Subsequently, PG&E, SCE, and SDG&E filed ALs 5277-E, 3787-E, and 3211-E, respectively, on April 16, 2018. The IOUs’ GNA and DDOR workplan and format proposals are summarized below.

PG&E Advice Letter 5277-E

Work Plan: PG&E describes the following high-level process steps needed to implement GNA and DDOR, and presents a Gantt chart, summarized in Table 1 and 2, describing the time requirements to complete those process steps:3

1. Develop grid planning tools and processes to forecast grid needs over a five-year forecast horizon; develop DDOR data

2 The IOUs complied with this directive and filed their GNAs on June 1, 2018.3 While PG&E also describes related process steps pertaining to ICA and LNBA development, those are omitted here for the purposes of this discussion.

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extraction methods, DER Solution Requirements, and deferral ranking criteria;

2. Calculate forecasted grid needs; implement DDOR data extraction methods, DER Solution Requirements, and ranking criteria;

3. Extract GNA and DDOR data; produce GNA report and GNA and DDOR online map layers;

4. Publish GNA and DDOR reports, data, and maps

Table 1. PG&E timeline of GNA-related implementation stepsDate Range Activity

By June 1, 2018

Compile “as available” grid needs and forecast assumption dataDevelop and finalize map layers for GNA submission data

By December 31, 2018 Make enhancements to load forecasting tool

By December 31, 2018

Develop distribution planning tool capabilities and IT structures to run automated hourly power flow simulations and consolidate grid needs deficiency reports

January 1, 2019 – June 1, 2019

Planning studies are conducted for forecast years; grid needs are identified and consolidated into machine-readable report

Table 2. PG&E timeline of DDOR-related implementation stepsDate Range Activity

By July 1 Planned investments are recommended and entered into DDOR list; candidate deferral list produced

By August 1 Develop DER solution requirements for candidate deferrals

By August 15 Develop LNBA and extract data to enter into candidate deferral list

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Date Range Activity

By September 1

Establish and implement candidate deferral prioritization metricsDevelop and finalize map layers for DDOR submission data

By September 1, 2019

Enhance and implement candidate deferral prioritization metrics

Risks and constraints: PG&E describes the risks and constraints associated with meeting a number of OPs in D.18-02-004. Such risks stem from internal changes the company is making to source databases that feed distribution planning tools such as its electric GIS database, interconnection database, and tools that load information from those databases to its distribution planning tools. As experienced in other system-wide rollouts, PG&E anticipates that there will be a debugging period for tools that GNA and DDOR depend on.

GNA and DDOR dataset formats: PG&E provides the following mock-ups of GNA and DDOR datasets to propose formats to meet the requirements of D.18-02-004 Section 3.4.1.:

1. Demand Forecast (included in GNA)

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2. DER Growth Forecast (included in GNA)

3. Grid Needs Assessment

4. Planned Investments (DDOR)

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5. Candidate Deferral Projects (DDOR)

SCE Advice Letter 3787-E

GNA and DDOR formats: SCE proposes formats for its GNA and DDOR based on inputs and outputs from its annual distribution planning process over a five-year forecast horizon, and notes that its proposals are illustrative and do not represent actual forecasts, needs, or projects. SCE’s proposals respond to the required elements laid out in D.18-02-004 Section 3.4.1., as well as the requirement in OP 7 of D.18-03-0234 requiring the GNA to identify the primary driver of each grid need. SCE also provides an explanation as to how it calculates percent deficiency.

o Grid Needs Assessment

4 Final Decision in DRP Track 3 Sub-track 2 pertaining to a Grid Modernization Investment Framework

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Circuit-Level Planning Assumptions (GNA)

Planned Investments (DDOR)

Candidate Deferral Projects (DDOR)

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Work Plan: SCE explains that specific steps of the distribution planning process need to be complete before the GNA and DDOR can be populated. Further, these reports require development of specific software tools to identify needs pertaining to the four distribution services and to develop long term time series forecasts for those needs. SCE describes the high-level steps it is undertaking to develop and submit the initial GNA and DDOR in 2018 and the software being developed to submit the full reports in 2019 as follows:

1. Identify Grid Constraints: SCE’s annual distribution planning process identifies areas that are expected to exceed capacity limits or require voltage/VAR support due to forecasted changes in load or generation. SCE identifies all “no cost solutions” to meet constraints, i.e., solutions that only incur O&M expenses. SCE will only include grid needs in its GNA that remain after all no-cost solutions have been exhausted.

2. Develop Distribution Projects: SCE will develop alternative project(s) that include either replacing existing or installing new equipment and will select the least-cost solution that meets the long-term needs of the system. This will result in an identified traditional solution that requires equipment to be installed on the electric system. At this

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process step, cost estimates reflect high-level scope definition and leverage unit costs that are based on historical averages.

3. Perform Deferral Screens: SCE will apply technical and timing deferral screens to distribution projects as it compiles the DDOR. The projects that pass both of the screens will be selected for the DDOR candidate deferral list. For the technical screen, DERs must provide one of the four distribution services established by D.16-12-036.5 The timing screen was developed based on the existing assumptions regarding the steps, approvals, and time required to hold a competitive solicitation, finalize contracts, and install DERs. With 2018 being considered the first year of the plan, all potentially deferrable projects to address identified distribution needs starting in 2021 will pass the timing screen.

4. Subsequent GNA/DDOR Enhancements SCE’s 2018 GNA will not identify voltage needs. SCE’s

current tools and datasets do not provide the ability to systematically and precisely identify forecasted voltage needs throughout the distribution grid. SCE is pursuing advanced analytical capabilities through its Grid Modernization software investments to address this, with production functionality anticipated in late 2018 through Q1 2019.

SCE’s existing planning tools are not capable of producing forecasted load profiles for the distribution feeders and substations within SCE’s service territory. For 2018, these profiles will be developed through a labor-intensive, manual process that utilizes measured historical data, load forecasts, and DER information. As such, SCE will only create profiles for the distribution projects that pass the deferral screens. SCE is

5 Distribution capacity, voltage support, reliability (back-tie), or resiliency (microgrid)

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developing its Long-term Planning Tool and expects to have the software capability and advanced analytics tools to create long-term time series forecasts in 2019.

In its 2018 GNA, SCE will communicate the amount of temperature reduction that would be required to reduce underground cable temperature to satisfy planning criteria. Underground cable in SCE’s grid is routed through duct banks, which typically consist of a “bank” of PVC pipes (conduit) enclosed in concrete. Multiple circuits can run through the same duct bank and create a mutual heating effect, such that a forecasted load on one circuit might lead to a thermal overload on another, requiring engineers to reduce load via a number of potential load transfers. SCE recognizes that the temperature reduction required to alleviate a duct bank temperature overload does not indicate the amount of load reduction or capacity a DER would need to provide to alleviate the same condition. By coupling long-term time series forecasts from its Long-term Planning Tool with advanced duct bank modeling capabilities in its System Modeling Tools, SCE seeks to better understand the optimal amount of load reduction on each circuit to alleviate a duct bank temperature violation.

SDG&E Advice Letter 3211-E

GNA Work Plan: SDG&E reviews the impetus for the GNA within the context of the DRP process and provides an overview of the distribution planning process steps by which it will populate the GNA on an annual basis. SDG&E notes that the Commission’s new DRP requirements could cause a number of steps to increase in time and complexity, due to the need to model multiple forecasts and loading scenarios:

1. Update five-year forecast for all substations and circuits;2. Update circuit modeling configurations by extracting current

geographic information system circuit data from applicable

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databases into distribution planning modeling software (Synergi), which usually takes two months to complete. SDG&E plans to have model updates completed by mid-May of each year;

3. Disaggregate the updated forecast in Synergi using historic smart meter loading data to allocate circuit-level forecast data to distribution transformers and line sections;

4. Run power flow simulations for multiple loading scenarios, including identifying local thermal/voltage violations as well as power factor correction;

5. Identify grid needs associated with the engineering analysis of forecasted violations within the GNA.

GNA Format: SDG&E proposes the following GNA format to meet the requirements of D.18-02-004 Section 3.4.1. SDG&E notes that it has proposed redacting “Existing facility/equipment rating: MW, kVA, other” associated with grid needs in AL 3210-E filed April 16, 2018:

Grid Needs Assessment

DDOR Workplan and Format: SDG&E states that its planning department will immediately begin to develop the DDOR after finalizing grid needs by applying the adopted deferral screens to traditional utility solutions. SDG&E notes that traditional solutions are arrived at through evaluating different options, and that projects can be refined throughout the year. SDG&E proposes to format the DDOR nearly identically to the GNA, in tabular form, but with the additional following items required for the DDOR by D.18-02-004 Section 3.4.1.:

1. Project Titles 2. Project Descriptions 3. Circuit/Substation IDs

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4. Deficiency % 5. Project Type 6. Distribution Service Required 7. Planned in Service Date 8. Cost/Value Estimate (LNBA range) 9. Deferability 10. Electric Footprint/Location for potential DER Deferral 11. Requirements to Defer Need 12. Other Pertinent Information Required for Deferral

NOTICE

Notice of PG&E AL 5277-E, SCE AL 3787-E, and SDG&E AL 3211-E was made by publication in the Commission’s Daily Calendar. The IOUs state that they served copies of the ALs to the interested parties on the GO-96-B and R.14-08-013 service lists.

PROTESTS

The Office of Ratepayer Advocates (ORA) protested the three IOUs’ filings, claiming that the IOUs’ GNA and DDOR work plans lacked sufficient clarity, calling for consistent report formats to be implemented, and recommending that the Commission reject the IOUs’ ALs.

ORA submitted a timely protest to PG&E AL 5277-E, SCE AL 3787-E, and SDG&E AL 3211-E on May 7, 2018. ORA recommends that the Commission reject the ALs, hold a workshop to identify common data formats, require the IOUs to clarify their work plans and milestones, and adopt common GNA and DDOR formats beginning with the 2018 DDOR and 2019 GNA.

ORA claims that the IOUs’ work plans do not clearly explain the steps they will take towards developing and implementing data compilation and reporting capabilities. According to ORA:

PG&E’s graphical flow chart does not line up with the accompanying narrative nor its Gantt chart.

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SDG&E’s work plan does not clearly identify milestones that indicate the anticipated completion of interim tasks with date estimates.

SCE’s work plan appears well developed, but it emphasizes the distribution planning process rather than development and implementation of data compilation and reporting capabilities.

Regarding proposed formats, ORA argues that:

SDG&E improperly omits a number of required GNA attributes that it is proposing to redact, and instead should have shown all data fields that would be provided to Commission staff and parties with Non-Disclosure Agreements.

SDG&E’s list of DDOR data fields does not constitute a proposed format, which it should provide a supplemental AL.

Regarding PG&E’s list of Risks and Constraints, ORA claims that:

It is not clear whether PG&E’s enumerated risks pertain to both the 2018 and 2019 GNA and DDOR filings.

In identifying “making actual costs of distribution system upgrades public” as its only high-risk area, PG&E misinterprets the meaning of “actual costs” in the context of D.18-02-004, which appears to use “actual costs” to refer to quantitative cost estimates as opposed to figurative cost descriptors such as “high, medium, or low” or “$, $$, $$$, or $$$$.”

Finally, ORA inquires whether PG&E and SDG&E will also adopt SCE’s proposal to only include in their GNAs grid needs that remain after no-cost solutions are exhausted.

The Interstate Renewable Energy Council (IREC) submitted a response to the IOUs’ ALs, requesting that the IOUs’ work plans ultimately comport with the Commission’s decision on data redaction criteria.

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IREC submitted a protest to the IOUs’ Tier 2 ALs that propose DRP data redaction criteria6, recommending a measured approach to balancing legitimate physical and cyber security concerns with the overarching objectives of GNA and DDOR to provide transparency into the distribution planning process. Within this protest, IREC responds to the IOUs’ concurrent ALs pertaining to GNA and DDOR work plans and formats. IREC states that SDG&E’s redacted GNA proposed in AL 3211-E would only give stakeholders a rough sense of grid needs and where they arise, whereas PG&E’s (and SCE’s similar one) would let stakeholders know the size and location of grid needs, would convey the types and scale of DER projects needed, and would provide stakeholders with a more holistic sense of grid needs. With this in mind, IREC requests that the IOUs’ final GNA and DDOR work plans comport with whatever decision the Commission reaches regarding redaction criteria.

The IOUs, in reply, push back on ORA’s claims and urge the Commission to ignore its call to reject the ALs.

The IOUs filed timely replies to ORA’s protest on May 14, 2018. PG&E, while not objecting to a workshop, questions whether ORA’s technical concerns are significant enough to delay approval of its AL or require significant changes to the GNA or 2018 DDOR. PG&E notes that it is integrating and coordinating its GNA and DDOR directly with its 2020 General Rate Case filing, and that there is not sufficient time to make major changes to the reports.

SCE counters ORA’s assertion that its work plan overemphasizes the “general distribution planning process,” by stating that its GNA and DDOR work plan milestones represent the completion of important planning tasks. SCE also responds to ORA’s request for more information concerning its “development and implementation of data compilation and reporting capabilities” by describing the manual process by which it will quantify the frequency and magnitude of grid needs. SCE explains that that such processes will exist until its Long-term Planning Tool is developed and enables streamlined forecasting, 6 See footnote 1.

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power flow and capacity analysis, project portfolio development, and integrated reporting. Finally, SCE argues that workshops are unnecessary and would create delays in meeting the September 1, 2018 DDOR deadline, and that it is premature to establish a single, common format across the IOUs, which was not required by the Decision. Instead, the Commission and stakeholders could make recommendation on consistent formats after experience with the initial DDOR filings and DPAG review.

Finally, SDG&E responds to the observation made by both ORA and IREC that its proposed work plans and formats reflect its pending data redaction criteria proposal. SDG&E notes that it will ultimately comply with Commission directives on GNA and DDOR formats and work plans.

All three IOUs call for the Commission to approve their ALs, and to dismiss ORA’s call for rejection.

DISCUSSION

The IOUs’ implementation work plans meet the intent of D.18-02-004 and are approved.

We find that the IOUs’ work plans satisfied the requirements of D.18-02-004, and we approve the IOUs’ work plans. We disagree with ORA’s argument that the IOUs’ work plans do not clearly explain the steps they will take towards developing and implementing data compilation and reporting capabilities. OP 2.k ordered the IOUs’ work plans to include “a high-level description of the steps necessary to develop such internal capabilities and estimated interim milestones.” The IOUs’ submissions provided helpful transparency into their current capabilities and approaches to modernizing their planning processes in order to efficiently execute the distribution resource planning process.

PG&E and SCE’s proposed GNA and DDOR formats meet the requirements of D.18-02-004 Section 3.4.1 and are approved with two important modifications.

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We find that PG&E and SCE’s format proposals adequately responded to the GNA and DDOR content requirements outlined in Section 3.4.1. of the Decision. PG&E and SCE’s proposed formats are substantively similar and well-developed. We agree with SCE in reply that formats do not need to be consistent across the three IOUs for the initial September 1, 2018 DDOR and approve PG&E and SCE’s formats as they are proposed. We disagree with ORA that a workshop needs to be held to identify common data formats, nor that matching formats are necessarily required across the three IOUs. We expect that the experience gained through this initial round of DRP and DIDF will help the IOUs and stakeholders identify improvements to the GNA and DDOR formats, which can be effectuated through the annual Tier 2 AL process adopted in OP 2.gg of D.18-02-004.

PG&E and SCE include in their proposed DDOR mockups a qualitative “$-$$$$” value for the “LNBA range” attribute. Consistent with D.18-02-004 OP 2.q, we clarify that LNBA Range should be expressed as a quantitative $/kW-year range and not “$-$$$$.” We order the IOUs to adopt this modification in their ongoing DDOR filings.

Furthermore, we order that substation, circuit, and facility IDs be consistent across GNA and DDOR reports, such that the Commission and stakeholders can easily track grid needs from the GNA through to planned investments in the DDOR.

SDG&E’s proposed report formats do not meet the requirements of D.18-02-004 OP 2.k. SDG&E is ordered to adopt either PG&E or SCE’s GNA and DDOR formats.

We find that SDG&E’s proposed formats did not meet the requirements of D.18-02-004 Section 3.4.1. We agree with ORA that SDG&E improperly omits a number of required GNA attributes that it is proposing to redact, and instead, should have shown all data fields that would be provided to Commission staff and parties with Non-Disclosure Agreements. We further agree with ORA that SDG&E did not propose a DDOR format, but instead copied the list of required DDOR attributes from Section 3.4.1.3. We reject SDG&E’s proposed

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format proposals, and instead order them to adopt either PG&E or SCE’s formats for their ongoing GNA and DDOR filings.

We dismiss ORA’s protest and affirm IREC’s response.

For the reasons stated in the above discussion, we dismiss ORA’s protest to the IOUs’ ALs. We further affirm IREC’s response that the annual GNA and DDOR filings shall comport to the DRP data redaction criteria established in a forthcoming ALJ ruling.

COMMENTS

Public Utilities Code section 311(g)(1) provides that this resolution must be served on all parties and subject to at least 30 days public review and comment prior to a vote of the Commission. Section 311(g)(2) provides that this 30-day period may be reduced or waived upon the stipulation of all parties in the proceeding.

The 30-day comment period for the draft of this resolution was neither waived nor reduced. Accordingly, this draft resolution was mailed to parties for comments, and will be placed on the Commission's agenda no earlier than 30 days from today.

FINDINGS

1. The GNA and DDOR are foundational elements of the annual DIDF, enabling the Commission and stakeholders to ensure that candidate distribution deferral projects proposed by IOUs maximize the ratepayer benefits of DERs per P.U. Code §769.

2. D.18-02-004 adopted several requirements for the annual GNA and DDOR filings pertaining to data attributes, display, and formatting.

3. D.18-02-004 Ordering Paragraph 2.k orders the IOUs to propose work plans by which they will develop and implement GNA and DDOR data compilation and reporting capabilities, and to propose formats for the GNA and DDOR datasets based on Section 3.4.1 requirements.

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4. PG&E, SCE, and SDG&E filed ALs 5277-E, 3787-E, and 3211-E, respectively 3187-E on February 16, 2018 in compliance with Ordering Paragraph 2.k in D.18-02-004.

5. ORA protested the three IOUs’ filings, claiming that the IOUs’ GNA and DDOR work plans lacked sufficient clarity, calling for consistent report formats to be implemented, and recommending that the Commission reject the IOUs’ ALs.

6. IREC submitted a response to the IOUs’ ALs, requesting that the IOUs’ work plans ultimately comport with the Commission’s decision on data redaction criteria.

7. The IOUs, in reply, push back on ORA’s claims and urge the Commission to ignore its call to reject the ALs.

8. The IOUs’ implementation work plans meet the intent of D.18-02-004.

9. PG&E and SCE’s proposed GNA and DDOR formats meet the requirements of D.18-02-004 Section 3.4.1 except for two areas identified.

10.SDG&E’s proposed report formats do not meet the requirements of D.18-02-004 Section 3.4.1.

11.GNA and DDOR attributes required by D.18-02-004 Section 3.4.1. related to “LNBA Range” and “Substation, Circuit, and/or Facility ID” need to be clarified to comply with D.18-02-004.

THEREFORE IT IS ORDERED THAT:

1. This Resolution approves with modifications Pacific Gas and Electric Company’s Advice Letter 5277-E and Southern California Edison Company’s Advice Letter 3787-E with regards to their proposed Grid Needs Assessment and Distribution Deferral Opportunity Report work plans and formats. The companies are directed to implement their proposed report formats with the changes ordered by this Resolution, starting with the Distribution Deferral Opportunity Report filing due September 1, 2018.

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2.This Resolution approves San Diego Gas & Electric Company’s Advice Letter 3211-E with regards to its proposed Grid Needs Assessment and Distribution Deferral Opportunity Report work plans, but rejects its proposed Grid Needs Assessment and Distribution Deferral Opportunity Report formats.

3.San Diego Gas & Electric Company is ordered to adopt either Pacific Gas and Electric Company or Southern California Edison Company’s proposed formats as modified by this Resolution for its annual Grid Needs Assessment and Distribution Deferral Opportunity Report filings, starting with the Distribution Deferral Opportunity Report filing due September 1, 2018.

4. We dismiss the Office of Ratepayer Advocates’ protest of Pacific Gas and Electric Company’s Advice Letter 5277-E, Southern California Edison Company’s Advice Letter 3787-E, and San Diego Gas & Electric Company’s Advice Letter 3211-E.

5.We affirm the Interstate Renewable Energy Council’s response to Pacific Gas and Electric Company’s Advice Letter 5277-E, Southern California Edison Company’s Advice Letter 3787-E, and San Diego Gas & Electric Company’s Advice Letter 3211-E.

6.Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company are ordered to express the “LNBA Range” attribute in their Distribution Deferral Opportunity Report filings as a quantitative $/kilowatt-year range and not as qualitative “$-$$$$” range.

7.Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company are ordered to consistently implement substation, circuit, and facility IDs across their Grid Needs Assessment and Distribution Deferral Opportunity Report filings, such that the Commission and stakeholders can easily track grid needs from the Grid Needs Assessment through to planned investments in the Distribution Deferral Opportunity Report.

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This Resolution is effective today.

I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on August 23, 2018; the following Commissioners voting favorably thereon:

_____________________

ALICE STEBBINS

Executive Director

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