Issue 8 Proposal

CALSSA, and IREC and SCE Edits Combined

8-28-18

[remaining to do list:

- Finalize policy and cost considerations section- Revise flow chart and integrate- Receive/place final counterproposals- Clean up Roger’s figure 1- Rewrite summary- Cost/benefit- 8.n explanation- Final SCE and CALSSA input on 8q- Timelines

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Table of Contents

Proposal Summary.....................................................................................................................4

Issue 8: How should the Commission incorporate the results of the Integration Capacity Analysis into Rule 21 to inform interconnection siting decisions, streamline the Fast Track process for projects that are proposed below the integration capacity at a particular point on the system, and facilitate interconnection process automation?...................................................4

Summary of Revised Flow Chart.............................................................................................6

Background.................................................................................................................................8ICA and Interconnection Overview.........................................................................................8

Threshold Considerations.......................................................................................................10Policy Considerations.............................................................................................................10Cost Considerations................................................................................................................11Implementation Dependencies...............................................................................................11Proposed ICA Validation Study.............................................................................................11

Proposal Summaries................................................................................................................12Proposal 8.a: Remove Existing Fast Track Eligibility Limit.................................................12Proposal 8.b: Modification of Initial Review Process to Include Verification and Explanation of Updated ICA..................................................................................................12Proposal 8.c: IOUs will keep track of when ICA values are updated outside of the required monthly update to inform future ICA discussions.................................................................14Proposal 8.d: Modification of Projects if ICA Values are Out-of-Date To Stay Under ICA Limit and Maintain Queue Position.......................................................................................14SCE suggests it would, as a part of its initial review response, indicate whether a customer passed or failed initial review, including technical information delineated in Proposal 8.b. If the customer desires to make modifications to its interconnection request, the customer can do so by utilizing the approved Material Modification procedures. PG&E and SDG&E generally agree with SCE, but conclude the proposal adds complexity without providing substantial value.....................................................................................................................14Proposal 8.f: Apply Screen F to Projects Larger than 30 kVakVAkVA; Provide Earliest Available Indication where Screen F Failure is Likely..........................................................14Proposal 8.g: Apply Screen G to Projects Larger than 30 kWkVAW; Provide Earliest Available Indication where Screen G Failure is Likely.........................................................16Proposal 8.h: Screen H should be modified to note that Screen H does not apply to Generating Facilities with a Gross Rating of 30 kVA or less................................................17Proposal 8.i: Non-export projects must be evaluated for all screens.....................................17Proposal 8.j: Apply Screen J to Projects Larger than 30 kWkVAW......................................18Proposal 8.k: Screen L should be modified to include the transmission overvoltage and transmission anti-islanding test..............................................................................................18Proposal 8.m: Screen M should be modified to reflect ICA..................................................20

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Proposal 8.n: The Commission should adopt additional Initial Review Screen F1...............23Proposal 8.o: The Commission should adopt additional Supplemental Review Screen M2. The IOUs are required to develop <API? Translator?>.........................................................23Proposal 8.p: Changing Supplemental Review Screens.........................................................24Proposal 8.q: Screen P should be modified… .......................................................................24Proposal 8.r: The Interconnection Application should have an option to combine Initial Review and Supplemental Review, with applicants pre-paying for Supplemental Review. .24Proposal 8.s: Rule 21 tariff should adopt new timelines that reflect additional efficiencies driven through the incorporation of ICA, <better enforce timelines>, and reduce interconnection fees................................................................................................................25Proposal 8.t: Queue management...........................................................................................25Proposal 8.u: IOU Validation Exercise..................................................................................26Proposal 8.v: non-ICA related automation of Rule 21 Screens.............................................26

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Proposal Summary

Issue 8: How should the Commission incorporate the results of the Integration Capacity Analysis into Rule 21 to inform interconnection siting decisions, streamline the Fast Track process for projects that are proposed below the integration capacity at a particular point on the system, and facilitate interconnection process automation?

The following proposals were developed by various stakeholders as part of the Working Group process to address Issue 8.

Proposals to modify the Rule 21 process and integrate the results of ICA include:

o Proposal 8.a: Remove Existing Fast Track Eligibility Limito Consensus: yes? o Non-consensus (supported by/opposed by)

o Proposal 8.b: Modification of Initial Review Process to Include Evaluation of Updated ICA

o Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.c: IOUs to track updated ICA values to inform future ICA discussions with regards to frequency of updates

o Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.d: Modification of Projects if ICA Values are “Stale” To Stay Under ICA Limit and Maintain Queue Position

o Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.e: Identification of ICA results shared during Initial Review Results Meetingo Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.f: Screen F should be modified to note that Screen F does not apply to Generating Facilities with a Gross Rating of 30 kVA or less; Known Results> of Screen F may be shared on <maps>

o Consensus: ?? to change/?? on sharing information on map vs. pre-app, how it’s implemented

o Non-consensus (supported by/opposed by)o Proposal 8.g: Screen G should be modified to note that Screen G does not apply to

Generating Facilities with a Gross Rating of 30 kVA or less; <Known Results> of Screen G may be shared on <maps>

o Consensus: ?? to change/?? on sharing information on map vs. pre-app, how it’s implemented

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o Non-consensus (supported by/opposed by)o Proposal 8.h: Screen H should be modified to note that Screen H does not apply to

Generating Facilities with a Gross Rating of 30 kVA or lesso Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.i: Non-export projects which pass Screen I should still be reviewed under Screen M

o Consensus: ?o Non-consensus (supported by/opposed by)

o Proposal 8.j: Screen J should be modified to ask, “Is the generating facility ≤ 30 kVA?”o Consensus: yes o Non-consensus (supported by/opposed by)

o Proposal 8.k: Screen L should be modified to include the transmission overvoltage and transmission anti-islanding test.

o Proposal 8.l: Some indicators of where projects are likely to fail Screen L should be flagged on the <ICA map> in advance, where known transmission deficiencies have already been identified.

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.m: Screen M should be modified to reflect ICAWOF (w or w/o buffer?)o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.n: The Commission should adopt additional Initial Review Screen F1o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.o: The Commission should adopt additional Supplemental Review Screen M2. The IOUs are required to develop <API? Use of 3rd party? Integrated into map, app, or pre-app?>

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.p: The IOUs made language changes to Supplemental Review Screens language to reflect evaluation of operational flexibility considerations

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.q: Screen P should be modified to reflect <consideration of x/r ratio> before requiring upgrades

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.r: The Interconnection Application should have an option to combine Initial Review and Supplemental Review, with applicants pre-paying for Supplemental Review

o Consensus: ?

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o Non-consensus (supported by/opposed by)o Proposal 8.s: Rule 21 tariff should adopt new timelines that reflect additional

efficiencies driven through the incorporation of ICA, <better enforce timelines>, and reduce interconnection fees

o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.t: <Queue management>o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.u: <IOU validation exercise>o Consensus: ? o Non-consensus (supported by/opposed by)

o Proposal 8.v: <non-ICA related automation of Rule 21 Screens>o Consensus: ? o Non-consensus (supported by/opposed by)

Summary of RevisedCurrent Rule 21 Flow Chart

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[add narrative relating this to proposals]

As a key objective of Issue 8 is to understand how the Rule 21 process will be streamlined, the WG identified that proposals to modify the tariff should clearly highlight:

- Steps to be eliminated- Steps to be streamlined- Steps to be added- Who takes each step- What data is used - How the action is executed

This section presents a summary of the proposals only. The “Working Group Proposals” section further describes the proposals and the positions for and against each. Please review the Appendix for complete Issue Proposals by supporting WG members and identification of the steps mentioned above.

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Background

The Integration Capacity Analysis (ICA) is a tool,was developed under the Distribution Resources Plan (R.14-08-013) proceeding. California Public Utilities Commission (CPUC) Decision D. 17-09-026 adopted the use of ICA for online maps, interconnection streamlining, and distribution planning, and authorized implementation of ICA across the utilities’ system-wide territories. This Decision reiterated that one of the key purposes of the DRP is to dramatically streamline the interconnection process, and that ICA results can help customers design DER systems by providing accurate information about the amount of DER capacity that can be interconnected at specific locations without significant distribution system upgrades or study process.1

ICA and Interconnection OverviewICA is a tool that provides information on the distribution system conditions capabilities that helps inform interconnection applicants on proposed project sizing. and location. This information is based on analyses of grid conditions tied to accounting for thermal limitations of distribution components, power quality, steady state/ /voltage, protection, and safety (, and operational flexibility requirements). . The Distribution Resource Plan Working Group report described its expectations for using the ICA to support interconnection as follows2:

Developers should be able to submit a Rule 21 Fast Track application for DER interconnection up to the identified ICA value at the proposed point of interconnection, based on ICA figures shown on the map, changes in queued DER since the last map update and the underlying data, and be able to pass those screens representing criteria the ICA has evaluated….

The ICA values identified at a point of interconnection are expected to replace and/or supplement the size limitations in the Fast Track eligibility criteria and will be able to address and/or improve the technical screens in the Rule 21 Fast Track process which are part of the ICA methodology…With few exceptions, interconnection customers should be able to use the ICA value at their point of interconnection to know whether a proposed project will pass these screens in the Fast Track process. In the near-term, there will be additional screens that still need to be evaluated due to data not currently analyzed in the ICA.

Decision D. 17-09-026 further specified how ICA should be implemented and the specifics of the methodology that should be used but identified Rule 21 as the proceeding to decide how ICA

1 D.17-09-026, p. 272 ICA Working Group Final Report, p. 8-9 (https://drpwg.org/wp-content/uploads/2016/07/ICA-WG-Final-Report.pdf)

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can be incorporated into the Rule 21 tariff. The R. 17-07-007 Scoping Memo identified three Phases of the proceeding and scoped issues to be addressed by various working groups. Working Group Two is tasked with discussing ICA and Streamlining Interconnection Issues.

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Threshold ConsiderationsThe Working Group spent much of its effort identifying and developing consensus proposals, andproposals and exploring issues where consensus may exist. In identifying changes to the Rule 21 tariff, members of the WG also identified where there are “threshold considerations” to adopting the recommended changes. These threshold considerations include 1) policy issues, 2) cost considerations, and 3) implementation dependencies.

Policy Considerations The Working Group identified several policy issues for consideration when discussing proposed changes to the Rule 21 tariff. Given the current phase (Phase 1) of this proceeding is not scoped to addressas ratemaking and cost responsibility for distribution system upgrades would have major cost implications cost considerations, the WG has agreed to summarize the discussion on the related policy issuescost responsibility to date in this WG report for the Commission’s subsequent consideration in Phase 2 (“Ratesetting Issues Requiring Coordination with 14-08-013”). For some proposed modifications, the WG has presented different proposals on how to proceed in the interim until after the Commission resolves related policy questions. This report identifies those proposals.

[Note on this section: CALSSA continues to object strongly to the suggestion that anything that costs money is out of scope. That is not true according to Commission rules. And the Commission knew when it directed the IOUs to implement ICA that it would cost money. Doing the analysis is costing them money. Showing up for meetings costs money. I think there is only one area that needs to be in a ratesetting forum. The cost responsibility associated with the IOUs’ proposal to move Screen I is clearly about assigning costs, similar to designing rates to recover utility revenue requirement.

Beyond that, everyone has been reasonable and has recognized that if something is not core and would cost too much it might not be worth the effort. This has come up in relation to the flags on Screens F, G, and L, and for automation. For the flags, we have heard the utilities say they have not had the chance to think through how difficult it will be and whether it will be worth the effort. For automation, they have resisted much of the proposal but have not done a real analysis of costs and benefits. If we had more time, we would have that cost-benefit discussion here. Because we do not have more time, I think we need to punt to an advice letter process as described below, with the exception of PG&E and Screen L.

In these edits, CALSSA moved parts of the cost responsibility section to the proposal on non-export storage, where it is relevant, and moved some of the language on costs and benefits of the Screen F, G, and L flags to those sections. We recommend deleting the rest of this section.]

Responsibility for grid upgrades when load changesRule 21 currently holds interconnecting generators responsible for grid upgrades which are necessary to accommodate the interconnecting generator (see Rule 21 Section E.4). In the event load changes (increase or decrease) subsequent to that interconnection, triggering the need for additional grid upgrades, the utility would plan for necessary upgrades, seek approval of those

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costs from the Commission through a general rate case during the utilities filing period, and, if approved, collect the costs of the upgrade from all customers. In the past, DER penetration has been relatively low, so load decreases have not triggered the need for upgrades and load increases were handled through overarching grid planning as a normal course of business. This dynamic has been aided by Screen M, which allows interconnection requests to pass simplified interconnection if the aggregate generation is less than 50% of the minimum load on the feeder. The WG asked, under a new R21 framework using ICA in which DER penetration edges upward, what may be the effect of changing load? And how should these changes be evaluated under Rule 21?

The WG discussed scenarios in which the existing approach to cost recovery for grid upgrades may warrant further consideration. Scenarios discussed include both situations involving Rule 21 and one scenario that impacts the proposals made herein related to interconnection processes and cost responsibilities for non-export projects. The WG discussed that, with a reduced margin of available capacity, non-exporting generating facilities could have a material impact on power flow, potentially triggering system upgrades. The WG asked, under a new R21 framework using ICA, what happens when non-exporting systems reduce the minimum load on the feeder? Does this change how they should be evaluated under Rule 21 to interconnect onto the grid?

Under the existing Rule 21 Fast Track process, non-export projects which pass the Fast Track Screens A-H will also pass Screen I, bypassing Screen M which is meant to determine when aggregate generation is approaching or exceeding minimum load on a feeder. As detailed in Proposal 8.i, IOUs propose to eliminate the Screen I exemption for non-exporting systems, so that non-export projects are screened to determine whether further study is required to identify if system upgrades are required, similar to any other Rule 21 interconnection request.would be evaluated under Screens M and L. Similarly, those WG members identified that if needed, non-export projects should be required to pay for system impact studies. Other WG members propose that Screen I should be retained as is until the Commission addresses the broader policy issues raised herein.

This likely includes additional cost implications for non-export projects to pay the fees for Supplemental Review and increase the time to review and approve a non-export project.

Cost Considerations The WG discussed whether and how to consider the costs of implementing proposals suggested here. This question arises in several proposals. First, the question of cost comes up in Proposals 8.f, 8.g., and 8l, in which some utilities are considering presenting information related to the likelihood of interconnecting generators to pass Screens F, G, and L. Second, the question of cost comes up in Proposal 8.v, concerning non-ICA related automation of Rule 21 screens. , can Implementation of these proposals may result in new costs to IOUs.

The WG agreed to include a high-level sense of whether these proposals result in costs and the reasonableness of such costs, but to defer detailed consideration of costs to the Ratemaking portion of this Proceeding.

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Implementation Dependencies New tools and processes will be needed to achieve use of ICA values in the interconnection process, to achieve Proposals 8.a – 8.t. Those include:

1. Tool or process to efficiently reference the ICA values [2.] Tool or process to efficiently update the ICA valuevalues[3.] Tools to reference external information (such as PV watts), including processing typicalprocessing typical PV operational profiles2.[4.] Processes related to new interconnection process flow (applications, forms)

Proposed ICA Validation StudyActivitiesGiven the complexity of ICA and that ICA production is new, the IOUs are conducting quality control and assurance efforts to ensure the results of that analysis can be used in the ways proposed herein. The Working Group has significant discussion of these efforts and agreed they are worthwhile. The Working Group agrees that these efforts should be conducted immediately and be completed prior to the point that the ICA will be used to evaluate interconnection requests as part of Rule 21. Unless specific, documentable concerns are identified it is expected that the utilities will be able to utilize the ICA in the screening process proposed herein by the implementation date without the need for further validation of the results.

Proposal SummariesProposal 8.a: Remove Existing Fast Track Eligibility Limit ProposalThe Commission should remove the existing Fast Track Eligibility Limit.

StatusConsensus

DiscussionFast Track evaluation allows for rapid review of certain projects to determine whether they require further Detailed Study. Fast Track is comprised of an Initial Review and, if required, a Supplemental Review. Because a project’s size has been a primary indicator of whether it is likely to be approved for interconnection under Fast Track, eligibility for Fast Track review currently is dependent on the project’s size. PG&E and SCE currently use a 3 MW size limit to determine Fast Track eligibility, while SDG&E uses a 1.5 MW size limit.

The ICA provides an estimation about what size project can likely be interconnected on a specific circuitat a specific point of in a circuit without likely requiring distribution upgrades., replacing the need for the 3 MW or 1.5 MW limits currently used to determine Fast Track Eligibility. Indeed, it is possible that in some locations the ICA may indicate capacity for projects larger than these Fast Track limits pushing projects to detailed study when it may not be needed. In addition, in some cases projects which are proposed above the ICA limit may be able to be interconnected without further study after Initial or Supplemental Review is conducted if

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minor upgrades or system changes are possible to address the limitation. Thus, this proposal will allow applicants to select Fast Track as their preferred study track.

All WG members supported the elimination of Fast Track Eligibility Limits. Two caveats to this proposal were emphasized by the WG. First,

First, the ICA only evaluated certain technical criteria and thus even projects that are below the ICA may still be required to go to Supplemental Review or Detailed Study if they fail the other screens not evaluated by the ICAICA is informational only and projects may be required to go to Supplemental or Detailed studies and projects may trigger upgrades to allow interconnection. Elimination of the Fast Track eligibility limit does not increase an interconnecting generator’s chances of passing through Iinitial or Ssupplemental Rreview if the project is sized above the ICA with or without Operational Flexibility. Applicants are therefore encouraged to reference the ICA.

Second, net-energy metering (NEM) projects under 30kVAW are currently processed as Fast Track projects. The WG recommends this practice continue, regardless of the ICA.

Proposal 8.b: Modification of Initial Review Process to Include Verification and Explanation of Updated ICA ProposalThe IOUs will modify their Initial Review processes to incorporate an additional run of specific node/feeder ICA where an updated ICA valuevalues may be required. IOUs will provide interconnecting generator an explanation of the update if necessary. . If needed the update will be completed within the Initial Review timeframe.

[Need to define where this step goes. Is it within Screen M or is it a separate step that needs its own step on the flow chart?]

StatusNon-consensus

DiscussionPer implementation requirements from D. 17-09-026, the ICA is currently updated on a monthly basis on circuits where significant system changes have occurred and those monthly updates are reflected in the ICA maps and public data portals. The WG noted that this frequency of updates means that sometimes interconnection requests could be sized based upon a ICA value values which is are not up-to-date; that is, the ICA value values reflected on the public data portal and online map may not reflect changes which have occurred in the grid (such as circuit reconfigurations, load changes, equipment changes, etc.) or changes in the interconnection queue (such as new interconnection applications and/or withdrawals).) since the ICA was last run.

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Each of the IOUs have proposed a different process for how they will verify whether the ICA value needs to be updated. These are the three IOU proposals with stakeholder modifications or objections noted below each:

1. SCE proposes to use the Initial Review process to determine if the ICA values at the proposed Point of Interconnection (POI) need to be updated. If it is determined that the ICA value values at the POI needs to be updated, SCE will use the ICA tool on the specific electrical node or will run the ICA on all the electrical nodes in the circuit, depending on future ICA tool capabilities. SCE believes that the Initial Review process may reveal the need for an updated ICA value values when the Interconnection Request-to-ICA ratio at the requested POI is greater than 50% for any hour. SCE will not perform additional analyses of interconnection requests with less than 30kW 30kVA nameplate capacity.

This proposal can be implemented without changes to the existing timelines for Initial Review.

[1.] PG&E and SDG&E generally agree with SCE’s approach, butapproach but proposes that verification of the ICA through the Initial Review Process may also be accomplished through simple calculations without rerunning the ICA.

a. Other WG members believe the ICA should produce the values used in the screening process and thus object to this proposal because it leaves open the possibility that interconnection applicants will not understand how the screening limit is derived and applied.

b. Today, it takes PG&E several hours to days to produce a full update to a single feeder. While in theory ICA can be calculated at a single node, the CYME module was not designed for this. If the Commission requires the IOUs to integrate ICA into their application platforms, that would require more resources and effort with CYME to change the module. CYME has already developed a sibling module to the ICA module that is designed to quickly analyze interconnection impacts called the DER Impact module. With the existing ICA process, when applications come into the process it will trigger the need to update. If available, then PG&E could use the new values, but it is not likely that it will be available within the timeline. If simpler methods are not allowed, PG&E proposes the ability to implement and use the DER Impact module since this is optimized and intended for this use and would be much faster to complete within the existing timelines.

c. OtherNon-IOU WG members believe the ICA should produce the values used in the screening process and thus object to this proposal because it leaves open the possibility that interconnection applicants will not understand how the screening limit is derived and applied.

All utilities propose to This proposal can be implement thisted without changes to the existing timelines for Initial Review.

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In addition to these questions of how ICA values would be verified, the WG discussed what steps the IOUs should take to share the results of their analysis with the interconnecting generator. Most WG participants agree an explanation of the following is warranted:

- Grid condition changes- Interconnection queue changes- New results of ICA rerun or alternative calculation

In the event disclosing ICA results fails any confidentiality provision, IOUs will provide information in aggregation or at a level of granularity that would allow IOUs to continue to comply with the Commission’s data redaction ruling. 15/15 confidentiality rules

Finally, SCE agreed to consider future implementation of system for “flagging” if the ICA valuesvalue likely needs an update. If possible, SCE would attempt this during Q1 2019.

Most Working Goup Group members support this proposal. except as noted above. GPI opposes this proposal as it asserts this proposal would add a new step to interconnection and may make interconnection review more complicated.

Proposal 8.c: IOUs will keep track of when ICA values are updated outside of the required monthly update to inform future ICA discussions ProposalThe IOUs will track when the ICA is updated for interconnection requests and identify when the posted ICA deviates from the actual ICA.

StatusNon-consensus

DiscussionThe Working Group discussed whether tracking of the deviations from the posted ICA values would help inform future discussions on the ICA.

Some WG participants suggestedpropose that the IOUs should track deviations from the posted ICA values which surface during the implementation of Proposal 8.b to inform future discussions of ICA refinement. Tracking of these deviations will help inform future discussions about how frequently the ICA needs to be updated systemwide and also in what manner and when it may need to be updated on a case by case basis for individual applications.

Many WG members support this proposal.

SCE expressed a willingness to consider tracking ICA updates for those projects that require Supplemental Review. PG&E and SDG&E oppose this proposal at this time, finding it better related to long-term ICA refinements within the DRP proceeding.

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Proposal 8.d: Modification of Projects if ICA Values are Out-of-Date To Stay Under ICA Limit and Maintain Queue Position ProposalApplicants who apply based on posted ICA should have an opportunity to make modifications to their application should they fail Initial Review screens because the postedthe ICA value values change by the time their application is reviewed. Applicants will have ten business days to modify their application or elect to go to Supplemental Review. If they do not respond the project will go to Supplemental Review after ten days.

StatusNon-consensus

Discussion in SupportThe WG discussed whether that projects which apply to be studied under Fast Track and apply based on the posted ICA valuevalues may mayshould have an opportunity to modify their application request, should if the ICA valuevalues have sve changed at the time their application is evaluated in the queue.

The current Material Modification rules under Fast Track review do not allow an applicant to reduce the size of a proposed project without resubmittal. Working Group One made a recommendation to allow size reductions up to 20% if it does not impact another project lower in the queue. That recommendation is pending. Even if it were to be adopted, it would not address this situation because the point of this proposal is to maintain queue position when it would impact another applicant lower in the queue.

This theoretical situation illustrates the issue. Suppose there are published ICA values sufficient to interconnect 2 MW of south-facing solar. After that number is published, Customer A submits an application for a system for 900 kW, leaving approximately 1.1 MW. Without knowing that, Customer B submits an application for 1.5 MW based on the published ICA values, then Customer C submits an application for 600 kW. Customer B is informed that there is actually only 1.1 MW of capacity and chooses to downsize. If Customer B is allowed to downsize without resubmitting, Customer C will not be able to interconnect without upgrades. If Customer B is required to resubmit and goes behind Customer C, only 500 kW of capacity will available. This proposal would allow Customer B to interconnect 1.1 MW because that customer was acting on posted ICA data in the initial submittal and should not be punished due to another project that submitted right ahead of them. Customer C would have to pay for upgrades to interconnect, which is what would have happened if all customers had access to up-to-date information.

A drawback of this proposal is that it would add ten days to the process and some applicants would not be able to make a decision within that timeframe, which would slow things down without providing a benefit. However, CALSSA believes solar providers will become accustomed to presenting multiple options to customers ahead of time in order to make speedy decisions when these situations arise.

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Discussion in OppositionSCE suggests it would, as a part of its initial review response, indicate whether a customer passed or failed initial review, including technical information delineated in Proposal 8.b. If that if the customer desires to make modifications to its interconnection request, it is SCE’s proposal that the customer can do so by utilizing the approved Material Modification procedures . are sufficient . . PG&E and SDG&E generally agree with SCE . They , but conclude the proposal adds complexity without providing substantial value.

This proposal adds complexity and makes the Fast Track process much slower than it is intended to be. It also reflects the challenges of the prior serial study process and why the Independent Study Process was introduced. It begs the question whether the Utilities should receive multiple interconnections requests under the Fast Track process with such interdependencies. Adding provisions to allow size changes that impact others in the queue means that completed interconnection studies would have to be re-done potentially impacting other customers project plans. There is no data supporting this proposal and thus not prudent to add complex rules on a scenario that may or may not happen frequency. Today, the number of projects that fail the Fast Track process is small and it is unclear whether adding ICA and the additional transparency would lead to that number of failures growing or not.

CALSSA offers a counterproposal (8.dx) in Appendix X. Stakeholders supporting CALSSA’s 8.dx include: x, y, and z.

Proposal 8.f: Apply Screen F O nly to Projects Larger than 30 kVA ; p rovide e arliest a vailable i ndication where Screen F f ailure is l ikely ProposalTwo parts:

(1) Apply Screen F to Projects Larger than 30 ; kVA ;

(2) Provide Earliest Available Indication where Screen F Failure is Likely

StatusModification #1: consensus

Modification #2: non-consensus

DiscussionModification 1:

The existing Rule 21 tariff language for Screen F includes the following language:

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 11 kVA or less.

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SomesomeSome WG members agreed that this should beThe WG discussed expanding the exemption from 11 kVA to expanded to 30 kWkVAW to allow standard NEM and other small projects to easily pass the Screen and maintain the goal of streamlining the interconnection process for small projects. It is not anticipated that projects below 30 kVA would be likely to raise any safety or reliability concerns if they skipped this screen.

This proposal can be implemented to tariff language being revised to:is tariff language is changed to

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 30 kVA or less.

All WG stakeholders agree the increase from 11 kVakVA to 30kVa30 kVakVA is an improvement. Some WG members are concerned the threshold could be larger than 30kVa30 kVakVA. The IOUs emphasize the 30kVa30 kVakVA is an acceptable number, but not derived from technical analysis. Stakeholders request additional analysis and reasoning behind the 30kVa30 kVakVA threshold. Resolving this difference was beyond the bandwidth of the WG.

Modification 2:

Screen F (“Is the Short Circuit Current Contribution Ratio within acceptable limits?”) identifies whether a project may have an impact on the system’s short circuit duty, fault detection sensitivity, relay coordination, or fuse-saving schemes. While the ICA Working Group report had indicated that the ICA could provide resultsenable an updated methodology for this screen,3 the WG identified that all elements of the tests conducted under Screen F are not evaluated within ICA, which identifies reduction in the portion of a circuit that benefits from protective equipment (“reduction of reach”) of reach, but does not study reduction in the ability of different pieces of protective equipment to work in concert (“coordination”). Further, Screen F requires the IOUs to study impacts in aggregate with other generating facilities on the circuit. In order to determine if a project fails Screen F it is necessary to run short circuit flow models. In sum, the ICA does not provide a an indication whether a project is likely to required Supplemental Review or Detailed Study forwill pass or fail this screen.

In the place of the ICA, IOUs considered whether/how they may provide an early indication whether a project is likely to face challenges related to Screen F. Some WG members propose that the utilities post information on the ICA maps that indicate whether Screen F is likely to be a problem at that location.

SCE is evaluating the feasibility to display locations where projects would likely fail Screen F. If SCE determines it can develop and when this capability at a reasonable cost and information is available, SCE would display this information along with the ICA values in the interconnection maps.

PG&E proposes that screen F results can be provided in the Pre-Application report given that itsour CYME DG Screening tool has the capability to analyze Screen F quickly. Information can

3 Integration Capacity Analysis Working Group Final Report, March 15, 2017, pp. 8-9.

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be provided as an additional screen in the pre-application report once the DG Screening Tool is modified to add this new feature.

SDG&E indicates it does not have the capability to provide additional information before its Initial Review results.

In light of these different positions, some of the Working Group members have proposed that the Commission require the utilities to file an Advice Letter 120 days after the Commission’s Order which would set forth their proposed approach to posting or otherwise providing information on likely Screen F results including any analysis of the costs of providing this information. If parties disagree with the proposals they can protest the advice letters.

Finally, some stakeholders have reservations about this proposal, noting that a “pass/fail” flag for Screen F may have limited value, given that successfully passing Screen F is a function of the project’s size. This concern is greater for customer-sited projects, relative to projects in front of the meter. Given these observations, the benefits of the proposal may not outweigh the costs. Other stakeholders emphasize that the value of the proposal depends on what exact information the IOU provides and what the information means, both questions which remain unanswered.

Proposal 8.g: Apply Screen G to Projects Larger than 30 kW k VA W ; Provide Earliest Available Indication where Screen G Failure is Likel y

ProposalTwo Parts:

(1) Apply Screen G to Projects Larger than 30 kVa ; kVA ;

(2) Provide Earliest Available Indication where Screen G Failure is Likely

StatusModification #1: consensus

Modification #2: non-consensus

DiscussionModification 1:

The existing Rule 21 tariff language for Screen F includes the following language:

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 11 kVA or less.

The WG/some WG members agreed that this should be expanded to 30 kVA, to allow standard NEM and other small projects to easily pass the Screen and maintain the goal of streamlining the interconnection process for small projects. It is not anticipated that projects below 30 kVA would be likely to raise any safety or reliability concerns if they skipped this screen.

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This tariff language is changed to

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 30 kVA or less.

Modification 2:

Screen G (“Is the Short Circuit Interrupting Capability Exceeded?”) identifies and studies whether a generating facility, in aggregate with other generating facilities on the distribution circuit, cause disturbances to protective devices and equipment, risking overstressing the equipment. This Screen allows the IOUs to evaluate how a generation project on the distribution system affects interrupting devices on the entire system, including at the distribution substation level, sub-transmission substation level (where applicable), and at the transmission level.

The ICA Working Group Report had indicated that this screen would be addressed by Screen G,4 but IOUs determined later that this was not the case since Screen G requires the IOUs to study impacts in aggregate with other generating facilities on the circuit. The information required to determine failure of Screen G may be from cluster studies, Rule 21 interconnection studies, and other internal studies. Identifying where these substations may be located and flagging them as “likely to fail Screen G” upfront will facilitate streamlining of the interconnection process. However, the IOUs assert this information is not easily obtainable and may not be available until a study (such as cluster study or Rule 21 study) is complete for the relevant circuit or substation.

In the place of the ICA, IOUs considered whether/how they may provide an early indication whether a project is likely to face challenges related to Screen G. Some WG members propose that the ICA maps include an indication of where Screen G may be a problem for projects.

SCE is evaluating the feasibility to display locations where projects would likely fail Screen G. If SCE determines it can develop this capability at reasonable cost, SCE would display this information along with the ICA values in the interconnection maps.

PG&E proposes that screen G results can provided in the Pre-Application report given that itsour CYME DG Screening tool has the capability to analyze Screen G quickly. Information can be provided as an additional screen in the pre-application report once the DG Screening Tool is modified to add this new feature.

SDG&E indicates it does not have the capability to provide additional information before its Initial Review results.

In light of these different positions, some of the Working Group members have proposed that the Commission require the utilities to file an Advice Letter 120 days after the Commission’s Order which would set forth their proposed approach to posting or otherwise providing information on likely Screen F results including any analysis of the costs of providing this information. If parties disagree with the proposals they can protest the advice letters.

4 Integration Capacity Analysis Working Group Final Report, March 15, 2017, pp. 8-9.

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Finally, some stakeholders have reservations about this proposal, noting that a “pass/fail” flag for Screen G may have limited value, given that successfully passing Screen G is a function of the project’s size. This concern is greater for customer-sited projects, relative to projects in front of the meter. Given these observations, the benefits of the proposal may not outweigh the costs. Other stakeholders emphasize that the value of the proposal depends on what exact information the IOU provides and what the information means, both questions which remain unanswered. Finally, some stakeholders strongly support consolidating this information in the ICA maps to ease access.

Proposal 8.h: Screen H should be modified to note that Screen H does not apply to Generating Facilities with a Gross Rating of 30 kVA or lessProposalScreen H should be modified to note that Screen H does not apply to Generating Facilities with a Gross Rating of 30 kVA or less.

StatusConsensus

DiscussionThe existing Rule 21 tariff language for Screen F H includes the following language:

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 11 kVA or less.

The WG/some WG members agreed that this should be expanded to 30 kVA, to allow standard NEM and other small projects to skip the Screen and maintain the goal of streamlining the interconnection process for small projects. It is not anticipated that projects below 30 kVA would be likely to raise any safety or reliability concerns if they skipped this screen.

This tariff language is changed to

Note: This Screen does not apply to Generating Facilities with a Gross Rating of 30 kVA or less.

Proposal 8.i: Non Discontinue exempting Non N n on -export projects must be evaluated for all screens from Screen M ProposalOption A: Non-export projects must be evaluated for all screens Screen I should be removed so that non-exporting projects above 30 kVA are reviewed under all screens.

Option B: Screen I should be retained and non-exporting projects of all sizes should still skip screens K, L and M. This is status quo, with the expectation that the issue will be reviewed in Phase 2

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Statusdependent on resolution of policy considerations (above). )Non-consensus. ).

Background on responsibility for grid upgrades when load changesRule 21 currently holds interconnecting generators responsible for grid upgrades which are necessary to accommodate the interconnecting generator (see Rule 21 Section E.4). In the event load changes (increase or decrease) subsequent to that interconnection, triggering the need for additional grid upgrades, the utility would plan for necessary upgrades, seek approval of those costs from the Commission through a general rate case during the utilities filing period, and, if approved, collect the costs of the upgrade from all customers. In the past, DER penetration has been relatively low, so load decreases have not triggered the need for upgrades and load increases were handled through overarching grid planning as a normal course of business. This dynamic has been aided by Screen M, which allows interconnection requests to pass simplified interconnection if the aggregate generation is less than 50% of the minimum load on the feeder. The WG asked, under a new R21 framework using ICA in which DER penetration edges upward, what may be the effect of changing load? And how should these changes be evaluated under Rule 21?

Under the existing Rule 21 Fast Track process, non-export projects that pass the Fast Track Screens A-H will also pass Screen I, bypassing Screen M which is meant to determine when aggregate generation on a line section is likely to exceed load. If Screen I is eliminated, a need for upgrades could be identified in the review of a non-export storage project even though the upgrade would be for the purpose of handling the nearby generation, not the storage project. The storage project in such a case would bear the cost burden for the generation-related upgrade. It would also have cost implications for non-export projects to pay the fees for Supplemental Review and increase the time to review and approve a non-export project. The Commission needs to decide whether this new cost burden is appropriate.

Discussion in Support of Option AScreen I (“Will power be exported across the PCC?”) essentially asks whether a project is export or non-export. Currently, if a project passes Screen I, it is allowed to bypass Initial Review Screens J, K, L, and M. Consequently, it also is not required to undergo Supplemental Review as long as it also passed Initial Review Screens A-H. The WG discussed whether non-export projects, which pass Screen I, should be required to be evaluated under subsequent screens.

The IOUs perspective is that the technical screens itself should provide the technical results. Even with varying levels of DER penetration, Screens J, K, L, and M can result in a non-exporting project or exporting project to pass the Initial Review. Therefore, subjecting a project to screens does not necessarily mean that those projects will all fail those screens. Second,, as levels of DER penetration are increasing in the distribution system, the level of ICA margin at various parts of the distribution system are diminishing to the point at which non-export projects which remove load from the system can potentially adversely affect the safety and reliability of

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the distribution grid by causing overvoltage conditions and possible overloads. In order to insure that all DERs are connected to the grid in a safe and reliable manner, an adequate level of technical evaluation needs to be performed. This includes evaluating how non-export projects may affect the ICA parameters, including thermal, voltage, and protectionunder the same technical evaluation as exporting projects.

Discussion in Support of Option B

Never in the past have customers been required to guarantee the utility any specific amount of load. Customers may change the nature and quantity of their demand using a wide variety of tools and due to many different reasons. For example, customer demand may decrease if a customer reduces operations, changes business practices, installs more efficient equipment, adopts specific energy efficiency measures, installs DERs onsite to serve load, or if customers go out of business or decrease the number of people living at a residence. The customer with departing load does not pay to replace its load with other solutions. The Commission has not approved any departing load charge for distribution capacity except in cases where facilities are built specifically to provide power to the departing customer.

Customers have a fundamental right to decide how much energy they purchase from the utility and to generate and/or store their own power onsite to serve their needs. The utility does not hold title to a customer’s consumption and should not be able to threaten them with upgrade costs if they chose not to purchase as much electricity from the utility as they did previously. Thus, if a customer reduces consumption through any of these methods, including by installing DERs, they should not have cost responsibility for failing to support nearby DERs.

If a customer changes its demand in any of the ways outlined above, the utility may need to reconfigure circuits or install new equipment to support DERs that still exist in the neighborhood. If a DER is given permission to interconnect based on load conditions at the time and those load conditions change such that upgrades are needed, the costs of those upgrades are borne by ratepayers just as upgrades triggered by gradual load growth are borne by ratepayers.

Due to an expected increase in applications for large non-exporting systems, the utilities believe there is a need to study each non-exporting system above 30 kVA for its potential impact on nearby generation that may have depended on the load that will be met with the proposed system. The utility proposal to move Screen I would cause some applicants to pay fees for Supplemental Review and to pay for distribution upgrades. This would be a major departure from existing cost responsibility and would discriminate between customers on the basis of the method they choose to use to reduce their load—even if the impacts are identical. For example, if a customer decreases their load by 20% via energy efficiency measures they would not be

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subject to any additional study or upgrade costs, but, by removing Screen I, a customer reducing their load by 20% through the use of onsite non-exporting DERs would be subject to additional study and upgrade fees. Some WG members believe this is discriminatory treatment and also violates a customer’s fundamental right to manage their energy demand.

The Commission will likely need to arbitrate this dispute in a ratesetting venue, concerning both the Supplemental Review fee for non-export projects and the cost of any upgrades that may be required to support other DERs when a customer reduces load. That can be done in Phase 2 of this proceeding. Until that question is resolved, the Commission should reject the proposal to remove Screen I.

This approach is reasonable at this time because the utilities have indicated that to-date this situation has never yet arisen and thus there is likely at least a little more time before this reaches the point where it is happening frequently enough to be of concern. In addition, it would be unfair and inappropriate to fundamentally change the way costs are allocated, with potentially significant impacts on certain customers but not others, without proper discussion in a ratesetting phase of this docket.

Tesla suggests a counterproposal 8.ix detailed in Appendix X. Stakeholders supporting Tesla’s counterproposal include X, Y, and Z.

The WG agrees this proposal cannot be resolved in isolation. It must be considered in the context of the “Policy Consideration” identified above. that these proposals may need to be revisited upon resolution of the “Policy Considerations” identified above.

Proposal 8.j: Apply Screen J to Projects Larger than 30 kVa k V A a ProposalApply Screen J to Projects Larger than 30 kW kVA .

StatusConsensus.DiscussionThe existing Screen J asks, “Is the gross rating of the generating facility ≤ 11 kVA?” If a project passes this screen it is then allowed to bypass Screens K through M. The WG agreed that this should be expanded to 30 kVA, to allow standard NEM and other small projects bypass Screens K through M and maintain the goal of streamlining the interconnection process for small projects. . It is not anticipated that projects below 30 kVA would be likely to raise any safety or reliability concerns if they skipped screens K through M.

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Proposal 8.k: Screen L should be modified to include the transmission overvoltage and transmission anti-islanding test.ProposalOption A: Screen L should be modified to include the a transmission overvoltage and transmission anti-islanding test . proposed by PG&E . This proposal is PG&E (only).

Option B: Screen L should be modified to include a less conservative transmission overvoltage and transmission anti-islanding test.

Option C: Screen L should be modified to include only a transmission overvoltage test.

StatusNon-consensus

DiscussionThe existing Screen L (Transmission Dependency and Transmission Stability Test) tests whether the interconnection request is made in an area where there are known or posted transient stability limitations, or the proposed generating facility has interdependencies known to the utility with earlier-queued transmission system interconnection requests. The ICA does not identify the results of Screen L, because the analysis is not conducted up to the transmission level. However, PG&E contends discussed that there are some areas where utilities have identified known transmission deficiencies that will impact the application of ICA.

Currently, Screen M (“Is nameplate generation > 15% of peak load?”) evaluates whether there is a risk that aggregate generation could exceed 15% peak and also 50% of minimum load, and if so, tests for minimum circuit loading conditions and identifies which projects should proceed to Supplemental ReviewDetailed Study. This 1% peak is It is designed to approximate when generation on a circuit segment exceeds 50%In the application of minimum load which is calculated in Supplemental Review currently. The 15% peak and 50% min load calculations are used in conjunction in the Initial and Supplemental Review to This this screen washas , the IOUs also been used by PG&E toThis 50% min load screen was also identifying when projects should undergo more detailed protection tests which are currently performed in Supplemental ReviewDetailed Study such as traditional anti-islanding (when the ratio of machine-based synchronous generation to inverter-based generation is over 40% and 50% min load for aggregate generation) and transmission overvoltage (when a transmission breaker opens on a substation that has an ungrounded high side. ). The WG identified that these transmission protection screens are not incorporated into ICA and therefore modifying Screen M with ICA meant that these screens need to be captured elsewhere. The WGPG&E proposed that these screens be identified in Screen L because L is also evaluating transmission. The benefit here is that this evaluation is conducted in Initial Review instead of Supplemental.

It is noted that there is some overlap in this topic with Issue 18 (“should the Commission adopt changes to anti-islanding screen parameters to reflect research on islanding risks when using UL

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1741-certified inverters in order to avoid unnecessary mitigations? IF yes, what should those changes entail?”). Working Group Four, tasked with Issue 18, is scoped to consider changes to the existing anti-islanding test while PG&E’s Issue 8 proposal is to move this evaluation from Supplemental Review to Screen L in the Initial Review. Note however that detailed evaluation of Screen L failure requires detailed study vs. Supplemental Review.

The proposals:

PG&E proposes that the anti-islanding and over votlagevoltage evaluation screen be transitioned to screen L as an equitable the its traditional anti-islanding test and the transmission overvoltage test should bebe normally evaluated in L from the current Screen ML.

Islanding is generally considered to possibly occurpossible when the ratio of machine-based synchronous generation to inverter-based generation is over 40% and aggregate generation is greater than 50% of min load for aggregate generation. 15% peak is used as the initial screen or filter to conduct additional screening on projects that exceed 15% peak.

Transmission overvoltage is generally considered to possibly occurpossible when a transmission breaker opens on a substation that has an ungrounded high side and aggregate generation is greater than 50% of min loadunder similar conditions. 15% peak is used as the initial screen or filter to conduct additional screening on projects that exceed 15% peak.

These two conditions are screened in Supplemental and for only those projects that failed the initial screen of 15% peak. The proposal for Screen M modifies the initial 15% screen to reflect ICA. However, it is important that this 15% screen to capture these two conditions be equitably maintained in Initial Review given that ICA did not address transmission related evaluations. PG&E thus proposes to move the 15% for the purposes of islanding and transmission overvoltage to Screen L.

Since these issues used the 15% evaluation in Screen M to evaluate the 50% minimum load condition, then this needs to get addressed else where given proposal to use ICA in screen M that does not include the evaluation of 50% minimum load.

PG&E proposalses is to that itdoes not introduce new tests or technical standards. PG&E currently evaluates both these conditions in Supplemental Review and Detailed Study and does so pursuant to theThe current PG&E standard. The would be followed and thus no changes to this would be proposed given that discussion will occur in Issue 18. The current standard for anti-islanding tests can be found here: https://www.pge.com/includes/docs/pdfs/shared/customerservice/nonpgeutility/electrictransmission/handbook/TD-2306B-002.pdf. No changes to the

technical evaluation is proposed here but the technical evaluation is in scope in evaluate projects for these conditions based on current standards used for this evaluation. Given that the screens and tests for this are being discussed in Issue 18 in the proceeding., then PG&E recommends language as such:

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“Screen L: Transmission Dependency, and Transmission Stability, and Anti-Islanding Test

Is the Interconnection Request for an area where: (i) there are known, or posted, transient stability limitations, or (ii) the proposed Generating Facility has interdependencies, known to Distribution Provider, with earlier-queued Transmission System interconnection requests, or (iii) islanding conditions are possible based on currently accepted conditions and standards. Where (i), or (ii), or (iii) above are met, the impacts of this Interconnection Request to the Transmission System may require Detailed Study.

by ….[fill in a description of their proposal for how the screening would work]

The current PG&E standard would be followed and thus no changes to this would be proposed given that discussion will occur in Issue 18. The current standard for anti-islanding tests can be found here: https://www.pge.com/includes/docs/pdfs/shared/customerservice/nonpgeutility/electrictransmission/handbook/TD-2306B-002.pdf

SCE and SDG&E propose……

[Some WG DER stakeholders contendstakeholdersmembersCALSSA contends that PG&E is misinterpreting the risk of anti-islanding failing to work. For Issue 8, these stakeholders opposeCALSSA opposes PG&E’s proposal not to use ICA values on circuits with machine-based synchronous generation. CALSSA Instead they propose….]

CALSSA does not oppose the addition of the transmission overvoltage screen. The reasoning for this position follows.

The overarching policy proposed as part of 8.k. is being driven by PG&E’s protection engineering department based on several studies conducted by Northern Plains Power Technology (NPPT) in cooperation with Sandia National Laboratories. These studies are:

1. “Unintentional Islanding Detection Performance with Mixed DER Types”, Ropp Ellis, July 2018.

2. “Risk of Unintentional Islanding in The Presences of Multiple Inverters or Mixed Generation Types”, Northern Plains Power Technologies, May 2015

3. “Suggested Guidelines for Assessment of DG Unintentional Islanding Risk”, Ropp Ellis, November 2012

In addition, PG&E has engaged NPPT to conduct its own internal study surrounding the impact of synchronous generators combined with UL 1741 certified inverters. This PG&E-funded study has been completed but the results have not been published.

All four of these studies were conducted using computer modeling programs, and their applicability is limited due to the lack of substantive real-world testing data. We take no exception to the methods employed in the study process, but as with any study, the theory should be proven before it is incorporated into wider policy.

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One independent study that reviewed real world UL 1741 inverter testing and grid conditions was conducted by General Electric in cooperation with PG&E for the Commission and is titled “Quantification of Risk of Unintended Islanding and Re-Assessment of Interconnection Requirements in High Penetration of Customer Sited PV Generation”, Bebic – 2016, (the GE Study). Within this study, much of the anti-islanding theory proposed by NPPT’s first two studies (1&2 above) was proven to be inaccurate. PG&E used the results of this study to relax some of their islanding review requirements. However, on a broader scale the discrepancy highlights an inherent inconstancy between computer models and real-world testing. In addition, PG&E’s current review standards omit some of the recommendations proposed in the report.

Proposal 8.k stipulates that islanding becomes a concern when the ratio of machine-based synchronous generation to inverter-based generation is over 40% and generation is more than 50% of minimum load. Breaking down the criteria in the proposal, we note the following:

1) 50% min load – The GE report states, “Power factor of the circuit has significant impact on island duration.” The proposed 50% of minimum load check in 8.k. completely omits any check of reactive power matching possibility. The GE report goes on to recommend the following changes to the review process to more accurately assess the risk of islanding. Note the use of the term simultaneous load, not minimum loading.

a. In initial review: raise the screening limit from 15% peak load to 60% of estimated simultaneous load; the estimated simultaneous load will be based on conversion factors as was defined and implemented in [3].

b. In supplemental review: Keep the existing minimum daytime load screen when SCADA data is available and allow 80% of estimated simultaneous load by maintaining the power factor of the section below 0.98 inductive.

c. In detailed review: Allow up to 105% of simultaneous load by de-tuning circuits to maintain the power factor between 0.95 and 0.98 inductive, to address islanding concern if needed.

Based on the recommendations in this report, CALSSA proposes adding a and b to replace the 50% minimum loading condition. In addition, we propose that c be allowed in circumstances that meet the defined criteria.

2) 40% Synchronous Generator Mix – This component of proposal 8.k is unproven. Adding it to Screen L as part of this working group is premature. No field testing has been conducted to verify the applicability of the research conducted by NPPT. Questions exist surrounding the field conditions that produce an extended run-on and whether the computer simulated grid are feasible in practice.

From a policy perspective, the intent of Issue #8 is to coordinate the implementation of the ICA, not to add in an unsubstantiated technical review measure. The question of anti-islanding review is going to be addressed by Issue #18 in this proceeding. From a policy perspective, Issue #18 is the more appropriate venue to address adding additional review points to the Rule 21 process.

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PG&E has stated that the current approximate percentage of circuits impacted by the PG&E anti-islanding standard is approximately 7%.5 This may be understated. Stakeholders should have the opportunity to independently verify this data point before any additional criteria are added to the anti-islanding standard. In addition, PG&E has implemented only one mechanism to address anti-islanding and that is to install Direct Transfer Trip at the substation level. The cost of this is typically above $1 million (either customer cost or ratepayer borne cost) and results in a delay to generation of up to 24 months. These results commonly cause projects to be withdrawn from the interconnection process.

Based on the impact of PG&E’s anti-islanding policies and the fact that the results are still unproven, there should be no changes to the Rule 21 anti-islanding policy at this time. Stakeholders should have an opportunity to challenge the theoretical data and propose alternative, more cost and time effective measures, to manage islandingIt is noted that there is some overlap in this topic with Issue 18 (“should the Commission adopt changes to anti-islanding screen parameters to reflect research on islanding risks when using UL 1741-certified inverters in order to avoid unnecessary mitigations? IF yes, what should those changes entail?”). Working Group Four, tasked with Issue 18, is scoped to consider changes to the existing anti-islanding test while thisPG&E’sthis Issue 8 proposal is movingmovingto moveing this evaluation from Supplemental Review to Screen L in the Initial Review. Note however that detailed evaluation of Screen L failure requires detailed study vs. Supplemental Review.

5 PG&E discussion slides for May 16, 2018 working group meeting, Slide 7.

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IREC: Modified Anti-Islanding Screen (temporary and only for PG&E) + Modified Transmission Overvoltage (for all utilities and not temporary)Anti-IslandingIREC shares CALSSA’s concerns about a possible misinterpretation of the risk of anti-islanding but appreciates that a more thorough consideration of this very technical issue must occur in Issue 18. With that understanding, IREC supports adopting a temporary set of screens, strictly for PG&E, for anti-islanding. In agreeing to adoption of these screens on a temporary basis IREC is not suggesting that we agree at this time that the screens are necessary. IREC believes these screens should only apply to PG&E at this time since they have a history of conducting this analysis in Supplemental Review and have provided stakeholders with statistics that help us understand their impact in PG&E’s territory. IREC is open to screens applying to all IOUs in the future following the consideration of Issue 18 if it is clear that they are needed. However, IREC believes that the first element of the anti-islanding screen proposed by PG&E (50% of minimum load) is unduly conservative. Instead of using 50% of minimum load, IREC proposes that the temporary screen look at 75% of minimum load. This would provide a sufficient buffer to prevent the creation of an unintentional island. At this time IREC does not have an alternative suggestion for the second element of PG&E’s proposed screen which asks whether “machine based generators are more than 40% of the total generator nameplate on the substation bank.” Transmission Overvoltage Finally, IREC supports implementing a transmission overvoltage screen [for all utilities] but again recommends that the screen look at 75% of the minimum load rather than 50% of minimum load, for locations when a transmission breaker opens on a substation that has an ungrounded high side. This screen is not dependent upon the Issue 18 and thus it does not need to be a temporary screen.

Proposal 8.l. Provide Earliest Available Indication where Screen L Failure is Likely

ProposalWhere there are known transmission deficiencies likely to cause projects to fail Screen L, indicate as much through ICA maps (preferably) or an alternative means identified herein.

StatusConsensus/non-consensus?

DiscussionThe WG discussed how identifying locations where certain pre-existing grid conditions exist would be useful for developers in understanding where they may fail Screen L. These conditions are:

● fused high side of substation transformer

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● existing direct transfer trip or hard wire tripping scheme ● synchronous generators present (relevant if Proposal 8.k Option A is adopted)

Identifying where projects are “likely to fail” upfront will facilitate the transparency, predictability and streamlining of the interconnection process by allowing developers to make informed development choices. Thus, this proposal would provide more information for developers but is not an “actionable” number.

PG&E proposes to list this data with other feeder summarized data such as (feeder name, circuit voltage, customer counts, generation totals, etc.). PG&E proposes two fields to help identify locations that could be of concern for screen L:

Substation High Side Fuse: Y/N Substation DTT/Hard Wire Trip Installed: Y/N

As part of a potential future enhancement to SCE maps, SCE is evaluating the feasibility of displaying locations where projects would likely fail Screen L. If and when this capability and information is available, SCE would display this information along with the ICA values in the interconnection maps.

SDG&E does not support this proposal.

IREC supports requiring all three IOUs to post information on their maps that helps to flag known conditions that might indicate whether a project may fail Screen L.

CALSSA notes that circuits will not need to be highlighted for potential to fail an anti-islanding screen if the anti-islanding screen is not adopted in Proposal 8.k.

Proposal 8.m: Modify Screen M should be modified to reflect ICA ProposalChange the methodology of the penetration test in Screen M should be modified to reflect consistency with ICA for projects that can be evaluated against ICA

StatusConsensus/non-consensus?

DiscussionThere was much discussion in the working group about the differencet between treatment of the ICA with Operational Flexibility (ICA-OF) and the ICA for static grid conditions (ICA-SG). OpSystem OoperationalOperational flexibility6 is evaluated through the “safety and reliability” criterion in the ICA. As explained in the ICA Working Group Report, unlike the other three four criteria evaluated by the ICA (thermal, protection, steady state and voltage and power quality),

6 For a discussion of what operational flexibility means in this context please see page 25 of the ICA Working Group Report. [add link]

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the Group WG was not able to identify a method of measuring unreasonable limitations on operational flexibility that did not rely on a conservative proxy (or “heuristic”). The safety and reliability, or operational flexibility, criteria thus usesd a measurement of whether there would be any reverse power flow back to the substation low-side bus or at a SCADA-controlled cross-tie switch as a substitute for actually evaluating all the potential reconfigurations wherein which no reverse power flow would be allow at distribution SCADA devicesa proposed project could impact circuits that it might one day may be connected to.. What this results in is a screen that may beis relatively far more conservative than necessary. (i.e. leaving much more operational flexibility than is necessary for safe and reliable operations in many cases). It is for this reason that the ICA Working Group askedagreed on for the creation of two sets ofan ICA values – one with operational flexibility ( (ICA-OF) which includes modeling of potential backflow at substations and circuit switches accounts fori.e. including the operational safety limitationsand reliability screen) and one without (ICA-SG) which does not include that modeling (not account forincluding the operational safety limitations. The backflow modeling is known as the “safety” constraint. Therefore, the ICA-OF is made up of five limitationconstraints (Thermal, pProtection, Power Quality, Steady State Voltage, and Ssafety). In a large majority of cases, the ICA-OF is limited by the safety ICA criteria but not always. For the ICA-SG, it is comprised of four criteria (Thermal, Pprotection, Power Quality, Steady State Voltage) and the limiting factor can be any one of the four limits. In cases where the ICA-OF is not limited by the safety criteria, then both the ICA-OF and and ICA-SG are the same value.reliability screen results). Since the ICA is made up of four five separate criteria, when the “safety” criteria is the most limiting factor at a particular point that will be shown as the ICAWOF,ICA-OF W,, if one of the other criteria is the limiting factors then that will show as the ICA limit which will be used in Screen M.

[there has been no set up as to why a buffer is required at all, that should be included]The ICA measures actual hosting capacity, in contrast to the current screens that are designed to approximate hosting capacity but have large margins of error built inbased on a snapshot in time. The IOUs are concerned that if they allow interconnection up to the full hosting capacity, system conditions may change in ways that reducemodify hosting capacity and the installed generation maywould then exceed hosting capacity. For this reason, all parties agree that some level of buffer is reasonable.

Building on this understanding, the WG discussed whether a buffer was needed for ICA-OF or if was only necessary for ICA-SG. Stakeholders agree that a buffer to reserve some actual hosting capacity is reasonable to ensure against loading conditions changing soon after hosting capacity is used, but disagree on the size of the buffer and its applications.what criteria the buffer should be applied to. A larger buffer risks overbuilding the distribution system by leaving too much hosting capacity unused; a smaller buffer risks interconnecting more generation than can be accommodated without impacts to safety, reliability ortriggering the need for upgrades or circuit reconfigurations if system conditions change.

It is important to note that ICA values are only being developed for nodes on three-phase lines. There are no ICA values for nodes on single-phase laterals. For interconnection requests at nodes

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on single-phase laterals, the request will be evaluated against the ICA values for the node where the single-phase lateral connects to a three-phase feeder. In addition, such projects will be evaluated to make sure they do not exceed the thermal capacity or disrupt the voltage of the single-phase line.

Currently, these risks are addressed in Rule 21 by Screen M (“is the aggregate Generating Facility capacity on the line section less than 15% of line section peak load for all line sections bounded by automatic sectionalizing devices?”), which approximates whether the generation capacity is less than 50% of minimum load. ICA calculations are based on 100% of minimum load. It was identified that concerns about the creation of unintentional islands and the need for upgrades may be triggered when the aggregate generation on a line section exceeds the minimum load.

IOU Proposal:

The IOUs suggest a hybrid approach, applying a a a 210% buffer to the NOFICA-SG and no buffer to WICAWOFICA-OF. Under this proposal, when the ICAWNOF ICA-SG and ICAWOF ICA-WOFOF are separated at each hour by more than 110%, (as depicted in Figure 1) the following would occur:

Operational flexibilitySafety would be evaluated with the ICA-OF. If Interconnection request is greater than ICA-OF, then IRit would be sent to the Supplemental Review for further evaluation.

T hermal, voltage, power quality and pProtection would be evaluated against the ICA-SG with 10% buffer curve. If the Interconnection Request crosses this 10% buffer, then the necessary upgrades would be implemented to maintain the 10% buffer at minimum. Cost responsibility would apply per existing rules.

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Figure 1

When the ICA-SG and ICA--OF are NOT separated at each hour by more than 2010% (Figure 2) then the following would occur

Operational Flexibility, Safety and reliability (thermal, voltage, PQ and Protection) would be evaluated against the ICA with a 10% buffer curve. If the Interconnection Request crosses this 10% buffer, then the necessary upgrades would be implemented to maintain the 10% buffer at minimum. Cost responsibility would apply per existing rules.

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Figure 2

The IOUs propose the following language for that the Screen should be changed toM:

[1.] Screen M replace with following:

[2.] For IR Based on Nameplate – Is IR nameplate capacitynameplate capacity less than the lowest of 10% of ICA-SG or 100% of ICAW-OF lowest hour in the profile

a. When either of the two levels are exceeded, project must be evaluated under supplemental review or detailed studies to determine mitigation requirements

2. For IR Based on Typical PV output profile – Is typical PV IR real power production less than the lowest of 10% of ICA-SG for all hours in the ICA-SG profile orprofile or 100% of ICAW-OF lower hour in the ICA-OF profiles based on PV Watts and attributes provided by the customer (losses, efficiency, DC-AC ratio, etc.).

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a. When either of the two levels are exceeded, project must be evaluated under supplemental review or detailed studies to determine mitigation requirements

3. ICA information not available – Use existing language.

CALSSA and IREC propose the following language for Screen M:

Is the aggregate Generating Facility capacity on the line section less in each hour evaluated than 90% of the ICA-SG values for that hour and 100% of ICA-OF values for that hour. If screen fails, project is further evaluated under the supplemental review

The Interconnection request for uniform generation is less than than80%80% of the ICAWNOF ICA-SG ICA values or 100% of ICAWOF ICA-OF values.. If screen fails, project is further evaluated under the supplemental review

Further, the IOUsy propose if a project is interconnecting to an area of the system without ICA such as transmission-level, the project is evaluated against 15% peak load using current process.. If ICA is not available due to customer confidentiality, ICA will still be used, with certain details withheld consistent with the 15/15 rule for aggregating customer data.

If a project fails Screen M, it is sent to Supplemental Review to further study the project which may include evaluating the impact on the operational flexibility of the system, thermal, protection, and power quality, including studying probable switching configurations in order to determine mitigation requirements

Application Submittal Process

Under IOU Option 2 above (For IR Based on Typical PV Output Profile), non IOU stakeholders propose that customers The application submittal process after ICA is incorporated in Screen M will be much the same as it is today. Customers will specify the incremental equipment details necessary for PV Watts or equivalent to generate maximum instantaneous output. This information should provide sufficient detail on the proposed equipment along with they propose to install, together with basic information about the configuration. This information in addition to location based weather For solar, the utility interconnection application portals currently interface with the California Energy Commission’s EPBB Calculator to determine the expected annual maximum output. Instead, the portals will link with the PV Watts Calculator to determine the expected hourly output under ideal weather conditions data.7 can be used to calculate location specific generation capacity to be compared to This will be compared to the hourly ICA values.

Uniform generation will also be compared to the hourly ICA values, but there will be no need to create an hourly production profile for that comparison.

Note that this revision to the application submittal process will require an adjustment to NREL’s PV Watts tools to generate worse-case generation capability data and integration of this tool to each of the IOU’s application portals.

7 Default values for PV Watts are shown in Appendix X.

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The exceedance of an ICA value during any hour evaluated will constitute a failure of Screen M. Further investigation in Supplemental Review will determine whether there are simple ways to address thisa failure.

Counter Proposal 1

CALSSA proposesand IREC oppose applying the buffer to the Protection constraint. The reason for the buffer is because ICA provides hosting capacity based on constraints that are not under utility control. For example, new rates schedules in the future can materially impact available hosting capacity.to protect against load disappearing that generation was depending on. That is not an issue with the Protection constraint. This counter proposal would change the screen to the following.

Is the aggregate Generating Facility capacity on the line section less in each hour evaluated than the lowest of 90% of the thermal ICA value, 90% of the voltage ICA values, 90% of the power quality ICA value, 100% of the protection ICA value, and 100% of the safety ICA value for that hour. If screen fails, project is further evaluated under the supplemental review

Counter Proposal 2

CALSSA and IREC support the approach proposed by the IOUs with the recommended revision in Counter Proposal 1. However, CALSSA believes the ICA would be much more user-friendly if the buffer were incorporated into the ICA values on the back end. If the thermal and voltage ICA values are de-rated by 10% before posting, it would be much more straightforward for the screen to simply follow the adjusted ICA values. The ICA values could be posted in the adjusted form such that customers can use them without adding an additional buffer.

The utilities have responded that they are too far along in calculating the ICA values to change the scripts now. If that is the case, the scripts can be adjusted at a later date. However, because there is still plenty of time before the ICA is put into practice, CALSSA and IREC suggest that this change can happen at some point before full implementation.

Counter Proposal 3proposes that the ICA values for certain constraints be devalued by ten percent to provide a buffer for potential future loss of load on the circuit segment. This may apply only to the thermal constraint.

Clean Coalition proposing basing the buffer on Total ICA value (including existing DER), not the remaining ICA value. On this basis a 10% margin may be appropriate.

GPI suggests a buffer of 90% or higher.

These proposals are detailed in Appendix X.

NEW PROPOSAL: Update Screen N Methodology

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Proposal

Update Screen N methodology from 100% of minimum load to ICA values for applications that can be evaluated according to ICA. Incorporate the extent to which the characteristics of the line section support the ability of the Volt-Var function to mitigate potential impacts of the Generating Facility on circuit voltage.

Discussion

Screen N is a quick review of failure of the penetration test to determine the requirements to address the failure. Projects with an ICA value will skipLike the Screen M penetration test, the Screen N penetration test needs to be updated from its current methodology to a methodology based on ICA. In Screen N, projects that exceed ICA values will be evaluated to determine if there is indeed an impact on the distribution system and, if so, whether there are simple mitigations that can be identified without Detailed Study.

For projects with no ICA value or that fail Screen F1, the project will be evaluated under Screen N as currently drafted which looks at If a project cannot be evaluated according to ICA values, Screen N will evaluate whether the aggregate Generating Facility capacity on the Line Section less than 100% of the minimum load. If a quick review of the failure does not determine the requirements to address the failure, Electrical Independence Tests and Detailed Studies are required.

Currently screen N is used to determine whether a project is below 100% of minimum load. If it is not, the project would proceed to Detail Study in most cases. If it is below 100% of minimum load, then the utilities evaluate, through Screens O and P, whether there are any reasons a project would require more study. The 15% of peak load test in Screen M and the 100% of minimum load in Screen N have served as reasonable measures in absence of ICA, but now that the utilities have ICA it replaces those proxies. The whole point of The ICA is to measure designed to approximate true hosting capacity constraints rather than relying on proxiesthe100% of minimum load proxy and thus . the ICA results replace the need for Screen N in most cases. Where there is no The 15% of peak load test in Screen M and the 100% of minimum load in Screen N have served as reasonable measures in absence of ICA, but now that the utilities have ICA it replaces those proxies.

In cases where ICA is not relevant because the project fails Screen F1 or there is no ICA available for the proposed point of interconnection, the Screen N penetration test will continue to be based on 100% of minimum load.

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Voltage conditions are a particular concern for solar interconnections because solar can cause voltage on the line segment to increase slightly. If a circuit segment already has voltage near the high end of the acceptable range and a new solar system is proposed, the proposed system must be studied carefully to make sure it does not push the voltage out of range. However, Rule 21 Section Hh now contains requirements that all new interconnections must have certain smart inverter functions enabled. Among these is the Volt-Var function, which is designed to force each solar system to mitigate its own voltage impacts.

The voltage constraint may cause the application to fail Initial Review but in Supplemental Review the utility will consider the impact of Volt-Var and may conclude that there is no negative impact on voltage. Alternatively, the utility may find that an adjustment to the standard Volt-Var settings is needed due to the electrical characteristics of the specific line segment.

As part of the long-term refinements to ICA methodology, the utilities are working with software vendors to incorporate Volt-Var and other smart inverter functions into the calculation of ICA values. Until that time, this impact can be considered in Supplemental Review.

Proposal 8.n: The Commission should a A dopt additional Initial Review Screen F1 ProposalGenerating systems with 1.2 p.u. short circuit contribution can reference the ICA value for meeting the reduction of reach ICA protection screen. For generating facilities with short circuit current contribution greater than 1.2 p.u. the utilities will use the protection ICA value at the point of interconnection in conjunction with the project specific p.u. short circuit contribution to determine if it passes Screen F.1

If the project screen fails Screen F.1, it must be evaluated under supplemental review for impacts to reduction in reach.

StatusConsensus?

DiscussionThe ICA cannot be used to evaluate synchronous or induction generation facilities. The ICA uses 1.2p.u short circuit duty contribution for inverter-based technology. Thus, an additional screen is proposed to evaluate whether a DER’s short circuit duty contribution is under the allowable level; if yes, the interconnection request would pass Screen F1; if no, the interconnection request would fail Screen F1 and may need to be evaluated under Supplemental Review for impacts to reduction of reach. While the ICA was calculated using 1.2 p.u., Screen F1 can be passed even when the DER short circuit contribution is greater than 1.2 p.u. so long as the DER nameplate value multiplied by its DER per unit contribution

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does not exceed the ICA value multiplied by 1.2pu. Below is an example to illustrate how the screen would be applied.

Project MVA (MW) Nameplate capacity = 3 MW

Project Specific SCC Per Unit contribution = 2.5 p.u

Updated protection ICA value at the PCC = 5 MW

Calculated project specific protection ICA value = 2.4MW

Project fails Screen F.1 because the project nameplate capacity is greater than Project Specific Protection ICA value

Proposal 8.n: The Commission should adopt additional Initial Review Screen F1ProposalGenerating systems with 1.2 p.u. short circuit contribution can reference the ICA valuevaluevalues for meeting the reduction of reach ICA protection screen. For generating facilities with short circuit current contribution greater than 1.2 p.u. SCE will use the protection ICA valuevaluevalues at the point of interconnection in conjunction with the project specific p.u. short circuit contribution to determine if it passes Screen F.1.

If the project screen fails Screen F.1 it must be evaluated under supplemental reviewSsupplemental Rreview for impacts to reduction in reach.

Screen F1 will be a part of the Initial Review process, reviewed concurrently with Screens A-H.

StatusConsensusDiscussionThe ICA assumed 1.2p.u short circuit duty contribution for inverter-based technology. Therefore, a DER with higher level of Short Circuit Duty Contribution need to be adjusted to ensure that project passes this screen consistent with ICA calculations methodology.[[need further explanation here]

The ICA did not evaluate synchronous or induction generation facilities. Thus, an additional screen is proposed to evaluate whether a DER’s with short circuit duty contribution is less than or equal togreater than 1.2 p.u could have an impact on protection reduction of reach;.

;. If it is, the DER passes Screen F1; if not, the application fails the Screen and may need to be evaluated under Supplemental Review for impacts to reduction of reach.

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Proposal 8.o : The Commission should adopt additional Supplemental Review Screen M2. The IOUs are required to develop <API? Translator? > [NOTE: Proposal 8.o is no longer needed with the Screen M evaluation based on PV Watts hourly generation numbers]Proposal

StatusPending? DiscussionICA for uniform generation is agnostic of DER technology type. If a project fails Screen M, the WG agrees that applicants should have the option of providing an Typical Output Generation Profile, to be evaluated against the ICAWOF (w/ or w/out 80% buffer?). This evaluation determines that the 576 hour Typical Output Profile does not exceed 80% for each of the 576 hours evaluated in ICA. This allows the project to be reviewed using ICA within the Fast Track process under Supplemental Review, without going to Detailed Study.

To translate project-specific inputs into a Typical Output Profile, the WG recommends that...

Proposal 8.p: Changing Supplemental Review Screens Proposal

Status?DiscussionLanguage of supplemental review screens should reflect that they are evaluating op-flex considerations

Proposal 8.q: Modify Screen P should be modified ProposalAdd an item to the list of factors that may affect the nature and performance of an interconnection (G.2.c):

Advanced inverter functionality and settings

Add an example of an item that may be considered under this screen (G.2.c):

Will the proposed system cause any voltage impacts considering the settings of the Volt-Var function and the characteristics of the circuit segment?

Default setting in Smart Inverters (such default volt/var) cause negative impacts on the grid (such excessive reactive power flow)

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[This bullet point needs to be better explained. This has not been discussed. The default settings of the Phase 1 Smart Inverter Working Group (minimum 0.95 power factor) were selected such that they would not put undue burden on substations to provide reactive power. In system conditions where a system is using the default Volt-Var settings, even if a circuit segment has voltage that is near the upper end of the range, the project will not put undue burden on substations to provide reactive power.]

StatusConsensus?

Discussion

Screen P is a final review of the proposed system in Supplemental Review to determine if there are mitigations that can avoid having to perform Detailed Study. The list of the types of issues that are considered should include advanced inverter functionality.

Proposal 8.r: The Interconnection Application should have an option to combine Initial Review and Supplemental Review, with applicants pre-paying for Initial Review and Supplemental Review

ProposalWith the publication of the ICA results and the additional transparency elements discussed in this WG report, customers will have the ability to know in advance that they might fail certain of the Initial Review Screens. Thus, it is proposed that projects can opt to combine the Initial Review and Supplemental Review process to skip the initial review results meeting and increase the efficiency of the process.

Customer projects exceeding 1) 30kVA for exporting projects, or 2) 500 kW for NEM projects, or 3) the posted ICA valuevaluevalues, will fail Initial Review under Screens, I, J, K, L and the modified Screen M. As such, any customer that believes that it is likely to fail IR, because it exceeds these amounts, will be provided an option to go through IR and SR as a combined study process, skipping the IR results meeting and thus saving significant time and IOU engineering hours

StatusConsensus

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DiscussionWhile the ICA serves as a guide for projects to better understand whether they may pass Fast Track, there is the potential that projects over ICA-OF may still pass Fast Track after being evaluated under Supplemental Review for operational flexibility concerns or other screen violations, or after small modifications are made during the Fast Track process. The WG identified that some larger projects, and particularly exporting projects (as described above), have a high likelihood of failing Initial Review and proceeding to Supplemental ReviewDue to the .ICA and the additional transparency measures proposed in this WG report, customers will be empowered to know in advance if they will, or have a high likelihood of, failing Initial Review. While these projects will know that they fail Initial Review, In addition, it is also the case that many projects can pass Supplemental Review even after failing Initial Review, and thus still pass Fast Track.

SupportersThus, Supporters of the proposal recommendthe proposal is to adding an upfront option on the interconnection application to allow a customer to pre-pay for Supplemental Review, alongside paying for Initial Review. The utility would then be authorized to combine the Initial and Supplemental Reviews into one analysis and to skip the time and steps that normally occur between those reviews. Applicants and the utility would benefit from additional time savings by opting to skip the Initial Results meeting. The applicant would still need to pay both fees for IR and SR and the project is still reviewed under both the IR and SR screens except for the IR screens made redundant by the SR. (Screen M, for example, is made redundant by Screen N).).). Fees and timelines for this combined study process may be adjusted as efficiencies are realized as part of the Working Group’s future efforts.

In discussing this proposal, project developers were asked how often they take the option to review the Initial Review results report and schedule an Initial Review results meeting with the IOU engineers. A number of developers, including Sunworks, Sunpower, Tesla and CalCom Energy responded, giving a range anywhere from 0-50% of projects electing to take the Initial Review results meeting before heading to Supplemental Review. Even when they decline the meeting, there is a time lag to do so that could be avoided.

Proposal 8.s: Reduce interconnection application fee for non-NEM systems Rule 21 tariff should adopt new timelines that reflect additional efficiencies driven through the incorporation of ICA, <better enforce timelines>, and reduce interconnection fees. ProposalA. Change the application fee for non-NEM systems smaller than 1 MW to match the application fee for NEM systems

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StatusPending (CALSSA proposed, follow-up discussion needed) DiscussionA. The $800 application fee level applies to non-NEM systems of any size. This includes relatively small non-export storage systems along with large wholesale systems. Until recently, most projects were either NEM solar systems smaller than 1 MW or solar systems larger than 1 MW that were not eligible for NEM. As energy storage has begun to become common, some of which is not paired with solar, there are applications for systems far smaller than 1 MW that are proposing to interconnect independent of NEM. These small-scale projects bear more resemblance to small solar projects than large wholesale projects.

With implementation of the net energy metering successor tariff, NEM systems pay an application fee that is based on actual utility costs to process applications. Because applications for non-NEM systems smaller than 1 MW require roughly the same amount of work to process as NEM systems, they should pay application fees at the new NEM level rather than the full $800.

In reviewing IOUs’ typical Rule 21 timelines, it was identified that some processes may need better-defined timelines, and others may need shorter timelines, as using ICA is expected to streamline the process.

Supporters of the proposal recommend that <enter recommendations>

To account for the reduction in review time, supporters of the proposal also recommend that fees should be adjusted to <enter recommendations>

<Enforcement and additional reporting recommendations>

Proposal 8.t: Queue management ProposalRequire identification of intended off-taker in the interconnection application; eEstablish an expiration date for the interconnection agreement for non-NEM projects; tighten deadlines; require justification for extending Commercial Operation Date; allow small projects to interconnect if they do not impact larger projects that are in front of them in the queue.

StatusNon-consensus

DiscussionCurrently, some DER developers apply for interconnection before they have a counterparty to buy the energy. or have a clear sense of whether they can obtain financing, environmental permits and other relevant factors that may affect a project’s viability. This has been necessary because energy purchasers, such as Community Choice Aggregators or direct access customers,

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have requirements for participants in their solicitations to have an interconnection agreement. Those purchasers want to have confidence that a winning bidder will develop will be able to build the proposed project.

The downside of this is that developers that do not win the bid in their intended solicitation have a project with no buyer and are motivated to sit on the reserved grid capacity for as long as it takes to find another buyer. This comes at the expense of customers that want to invest in behind the meter DERs in locations where there is not enough existing capacity for their projects in addition to previously queued projects. Developers of behind-the-meter systems sized to serve onsite load always have a counterparty because they are designing a system for installation on a customer’s property.

The current milestones in Rule 21 include the following.

Developer must have “site exclusivity” – own or lease the land or have an agreement for such – at the time of application.

Developer must pay a deposit for the interconnection study. There is no firm deadline for payment of this deposit. After ICA is made available there may be very large projects that go through Fast Track and thus are not required to put down study deposits, which would greatly diminish the significance of this step.

After agreeing to pay upgrade costs, if any, the utility sends a draft interconnection agreement to the developer within 15 business days and the developer has 90 calendar days to negotiate changes and sign the agreement. The agreement includes schedules for work to be completed by the developer and the utility associated with the distribution upgrades and interconnection facilities.

Developer must make good faith efforts to meet the schedules in the interconnection agreement.

If a project fails Screen R, developer has 40 business days to indicate whether they intend to be included in a Distribution Group Study. If a study window closes during that time, the project will be studied approximately six months later in the next Distribution Group Study.

Applicant has 30 business days to agree to scope of study. Developer has 60 calendar days to post initial financial security for grid upgrades and

interconnection facilities. Developer can propose a Commercial Operation Date that is far in the future and can

request extensions of that date. Utility is obligated to approve extensions as long as the developer has paid the required deposits.

The CALSSA Proposal includes the following changes to these milestones.

1-A. Require identification of intended off-taker in the interconnection application

Currently a developer does not need to know who will purchase or consume the energy produced by a proposed DER. We should not expect utilities to monitor the results of solicitations, but having information on the intended purpose of a proposed DER would inform later decisions of

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whether to grant deadline extensions. It would also discourage developers from proposing a system when there is no identified off-taker.

1-AB. Establish an expiration date for the interconnection agreement for non-NEM projects

Currently, per Rule 21 Section D.13.d, if a NEM project smaller than 1 MW is not installed within one year of approval, the project is deemed withdrawn. This sameA similar bar should exist for non-NEM and large NEM systems. Because the ICA will enable large projects to go through Fast Track, the timelines for the various pieces of the detailed study process are no longer sufficient as protection against sluggish development. A twoone-year deadline should be created from Fast Track approval for all projects that receive Fast Track approval.

1-BC. Tighten deadlines

Developers that want to go through the interconnection process quickly often do not use the full amounts of time allowed in the milestones listed above. Projects that are intentionally moving slowly should also respond more quickly. Ideas for trimming timelines include the following. [CALSSA would like to further review each of these, but offers them in this draft for reaction from stakeholders.]

Developers must pay detailed study deposit within ten business days. Timeline for negotiating an interconnection application should be reduced from 90

calendar days to 60 calendar days. After failing Screen R, a developer has 20 business days to decide whether to enter the

Group Study process with extension for an additional 20 days. Agreement on the scope of the detailed study should be completed within 20 business

days rather than 30. Developer must post initial financial security within 45 calendar days rather than 60.

1-CD. Require justification for extending Commercial Operation Date

A developer with an approved project but no power purchase agreement should not be allowed to extend the Commercial Operation Date without having made real progress in construction. If the developer is not able to quickly find another buyer after losing a bid, they should have to resubmit and lose queue position.

Rule 21 currently states the following (PGE F.3.e.iii) [emphasis added]:

Extensions of the Commercial Operation Date will be agreed upon in the executed Generator Interconnection Agreement. Reasonable Commercial Operation Dates will be discussed at theDGS Phase II Interconnection Study results meeting, or the DGS Phase I Interconnection Study results meeting if the DGS Phase II Interconnection Study results meeting is waived, in the case of the Distribution Group Study Process, the Interconnection Facilities Study results meeting, or the Interconnection System Impact Study results meeting if the Interconnection Facilities Study is waived in the case of the Independent Study Process. A request for an extension of the Commercial Operation Date after the Generator Interconnection Agreement is executed will be agreed to provided that, the Producer is still responsible for funding any Distribution Upgrades and Network Upgrades as specified in the Generator Interconnection Agreement

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and under the same payment schedule agreed upon in the Generator Interconnection Agreement. This provision has no impact on any power purchase agreement terms.

CALSSA proposes the following change: Commercial Operation Date must be set by mutual agreement considering intended

counterparty, reasonable construction time, and grid upgrades. Developer must demonstrate progress in construction and in securing a power purchase agreement when requesting an extension. Utility will grant extensions due to construction delays or circumstances outside of the control of the developer.

2. Allow small projects to interconnect if they do not impact larger projects that are in front of them in the queue

Large projects that take more than a year to study can hold up small projects that would not impact the results of the study of the larger project. If there is 1.5 MW of hosting capacity at a location and a 5 MW proposed project is undergoing detailed study to identify needed upgrades, a 1 MW project behind the larger project in the queue should be allowed to move forward if it would not impact the extent of the upgrades needed for the larger project.

Proposal 8.u: IOU Validation Exercise ProposalComplete ongoing Quality Assurance and Quality Control effortsControl efforts, leading to full and final implementation of the ICA as ordered by the Commission, before implementation of the proposals made herein.

StatusPending DiscussionGiven the complexity of ICA and that ICA production is new, the IOUs continue to

Proposal 8.v: non-ICA related automation of Rule 21 Interconnection Procedures ProposalThat the Commission review the Automation Status and Opportunities Report (attached as Appendix 1) and provide guidance on further action within this proceeding regarding:

1) how the Working Group can schedule additional discussion of the automation opportunities identified;

2) review of the likely costs and benefits of implementing automated data processes to reduce costs and streamline interconnection processes and schedules;

3) coordination of related IOU investments in line with the Commission’s Distribution Resources Plan (DRP) precedent, the DER Action Plan, and the merits of including automation goals in the DER Action Plan or a separate automation roadmap.

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StatusNon-consensus

DiscussionIn discussing Issue 8, the WG identified that certain actions that facilitate automation are not necessarily related to integration of ICA, but are part of the WG 2 scope.

Green Power Institute and Clean Coalition led the development of recommendations and identification of automation and streamlining opportunities for the Rule 21 process. The intent of the draft “automation roadmap” included in Appendix A is to form the starting point for an actionable “roadmap” for adoption by the CPUC, after additional discussion in this proceeding.

GPI and Clean Coalition, with support from Smarter Grid Solutions as engineering consultants, took the lead in drafting the proposal and solicited input from stakeholders, including IOU and non-IOU WG members, to refine the understanding of opportunities and develop recommendations. GPI and Clean Coalition had several opportunities to present their research and recommendations to the larger Working Group, and circulated the Appendix A document for written comment a number of times during the course of Working Group 2.

A summary of the most promising opportunities identified by the GPI/Clean Coalition draft proposal and resulting discussions are as follows:

• Automating the application process and completeness review • Reduce review time from 1-40 business days (BDs) to as little as 1 day for

projects that don’t require corrections• Reduce turnaround time for corrections from 10 BDs for each round of

corrections to 1-2 days with automated interconnection portals• Issue 22 has already scoped potential revisions to the interconnection portals, and

this contributes to that work• Automating (at least partially) Initial Review

• Automating analysis of refined screens toward reducing time from 15-17 BDs to 1 day for eligible projects

• Further evaluation of costs and benefits is required• Automating (at least partially) Supplemental Review

• Reduce time from 20-22 BDs or inclusion of the SR screens in IR (no additional time required for IR) for eligible projects

• Screens N and O have been automated as part of ICA, leaving the catchall Screen P for engineering review

• Combining Initial Review and Supplemental Review [included above as a separate item]• Only applies to projects that select this option, which will generally be large NEM

(over 500 kW) and wholesale projects• Timelines and fees for the combined IR/SR to be determined as part of the

working group deliberations• Frontloading and automating the GIA drafting process

• Provide template GIA to customer after application deemed complete, in order to frontload customer review of GIA terms

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• Automated population of template GIA with IR/SR results so that draft GIA can be generated in 1 day rather than 15 BDs

• Work to identify additional automation and streamlining items

1038594.1 IREC.IC-CA 1038069.1

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