Rule 21 Working Group 2

CO N F E R E N C E C A L L

AU G U ST 1 , 2 0 1 8

4 1 5 - 4 2 9 - 8 1 6 0

R E M OT E AC C ES S : H T T P : / / W WW.U BERCO N F E R EN C E.COM / GRI DWOR KS /

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https://gridworks.org/initiatives/rule-21-working-group-2/

https://gridworks.org/initiatives/rule-21-working-group-2/

Agenda3:00 - 3:05: Intro and overview

3:05 - 3:35: Issue 10 scoping discussion

3:35 - 4:05: Issue 11 scoping discussion

4:05 - 4:15: Screen F1 follow up

4:15 - 4:40: Automation roadmap update

4:40 - 5:00: Artwel Electric presentation

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Issue 10 scoping discussionHow can the Commission coordinate the Integration Capacity Analysis and each Utility’s Rule 21 processes with the Rule 2, Rule 15, and Rule 16 processes in order to improve efficiency of the overall interconnection process? This is a coordination issue at this time. However, modifications to Rules 2, 15, or 16 will be addressed if necessary

- Previously discussed at IDF

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Overview of Rules 2, 15, 16 as they relate to Rule 21

DISTRIBUTION LINE EXTENSION: (Rule 15)New distribution facilities of a Utility that is a continuation of, or branch from,

the nearest available existing permanent Distribution Line (including any facility

rearrangements and relocations necessary to accommodate the extension) to the

point of connection of the last service. The Utility’s Line Extension includes

transmission underbuilds and converting an existing single phase line to three-

phase in order to furnish three-phase service to an Applicant, but excludes

transformers, meters and services..

Photo/Text Credit: Harold Hirsch PG&E

SERVICE EXTENSIONS: (from Rule 16)

The overhead and underground primary or secondary facilities (including but not

limited to Utility Owned Service Facilities and Applicant owned service facilities)

extending from the point of connection at the Distribution Line to the Service

Delivery Point. When an underground Service Extension is supplied from a Utility

designated overhead pole, the beginning point of connection to the Utility’s

Distribution Line shall be where the Service Extension is connected to the Utility’s

overhead Distribution Line conductors.

Photo/Text Credit: Harold Hirsch PG&E

Special Facilities (Rule 2)

Unless otherwise provided by the Utility’s filed tariff schedules, special facilities will be installed, owned and maintained or allocated by the Utility as an accommodation to the applicant only if acceptable for operation by the Utility and the reliability of service to the Utility’s other customers is not impaired.

Special Facilities may fall into 3 major buckets when triggered by Rule 21:

Facility Level Mitigations

Sole use facilities that are required for a single generation interconnection

i.e. Transformers

i.e. Telemetry

Distribution Level Mitigations

Modifications to the Distribution System (<60KV) required for a single or cluster of generator interconnections

i.e. New Substation Bank

i.e. Reconductoring

Network Level Mitigations

Modifications to the Transmission System (>60KV) required for a single or cluster of generator interconnections

i.e. Transmission Substation Mitigation

i.e. DTTs

Mitigation EPC

Process

Regardless of what tariff covers the

specific type of mitigations needed all

mitigations will go through the EPC process.

During the EPC Process for PG&E, Rule 21

projects specifically are handled by multiple

people/departments. An assigned Engineer, a

Service Planner, a Designer, and an EGI rep

are some examples of the hands touching

the project.

Each department also uses their own

unique reference numbers to track projects.

Communications between departments

and/or with applicants tends to be highly

inconsistent and timelines poorly predictable

at best.

The EPC process is fairly standard, however

not all utilities handle things quite the same

way…

Design and construction timelines:

SPECIAL FACILITY AGREEMENTS AND PAYMENT

PROCESSING

When Substation work is involved timelines

and communication become more strained

“I wanted to apologize to you for the delay in providing you additional update on this NEMEXP project that was assigned to me to assist in the implementation work. I have just submitted a follow up internally on the orders for the NU and DU [Retracted] Please note that to get to the implementation project manager assignment, we had to go through the following processes first:

Creation of Notification Numbers for each Substation that’ll be linked to Planning Order Numbers;

Creation of Planning Order Numbers for each Substation that’ll be linked to PM Order Numbers;

Creation of PM Order Numbers for each Substation to be tied to each job (NU, DU)

Routing in the system for assignment of Substation Maintenance & Construction engineer for each Substation

SM&C engineer each to coordinate with IT engineering and Substation Engineering

These are just at a high-level on what needs to occur first before the site can be assessed. Each step can take a week at the minimum because these are routed thru to different groups.”

An excerpt from communications on a project under 1MW which triggered Network and Distribution upgrades.

Issue 11 scoping discussionShould the Commission adopt a notification-based approach in lieu of an interconnection application for non-exporting storage systems that have a negligible impact on the distribution system? If so, what should the approach entail?

Comments received: Tesla

- WG should identify which Initial Review screens would non-export systems likely pass

- WG should ID what constitutes a non-export system for purposes of a notification-only process

- Notification - eligibility requirements, contractual obligations, and compliance?

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Rule 21 Working Group 2: Issue 11

”Notification-based” Approach

Initial ScopeIssue 11:

Should the Commission adopt a notification-based approach in lieu of an interconnection application for non-exporting storage systems that have a negligible impact on the distribution system? If so, what should the approach entail?

• Definition of “notification-based”

• Definition of “non-exporting”

• Definition of “negligible impact”

Underlying Premise:

Can the interconnection process for storage systems meeting specific criteria be significantly streamlined, ultimately leading to a notification approach in lieu of interconnection review for a specified subset of projects?

BackgroundRule 21 WG discussed streamlining for non-exporting storage starting from a Commission Ruling in 2014

• Joint Motion filed in November 2015 – continue working to define criteria, then propose expedited process

• Utilities filed AL in October 2016, then supplemental AL in November 2016

• Commission approved Pilot period July 2017-June 2018

• Pilot results have not been published yet

• Two known takeaways: Frontloading GIA; Waiving inspection with photos

Why revisit this question?

• Learnings from the pilots

• Availability of ICA analysis and broader concept of pre-analyzed areas of the grid

• Considering notification approach for subset of systems

High Level ThinkingThree Major Stages of Interconnection Process

• Technical Review

• Contracting

• Inspection for PTO

Based on known grid conditions in the desired location and the technical specs of the proposed installation, each of the above process stages could be streamlined to minimize IOU work or for smaller systems become unnecessary for PTO.

Two possibilities:

1. ”Lightning Review”: All docs submitted up front, only IOU action is countersigning GIA

2. “Quick Notification”: All docs submitted within a few days after commercial operation

Lightning Review (strawman)Criteria:

• Non-exporting (inadvertent export is allowed?); Located on “Lightning eligible” circuit

• Storage nameplate < 75% of ICA value at location, < 85% of Screen F and Screen G thresholds*

• No changes to customer electrical panel or metering

Process:

• IOU publishes ICA value (including freshness), Screen F & G thresholds* and executable GIA form

• Applicant submits• All technical specs and building permit, including values retrieved from maps

• Application fee same as NEM fees• Completed & signed GIA• Photos of installation and results of any required tests

• IOU contracts group verifies completeness and criteria, including freshness of threshold values. Also verifies correct installation according to photos.

• IOU returns countersigned GIA within 15 business days This becomes the PTO authorization

* Can we set a system wide threshold for F and G? Proposing 500 KvA. Would obviate need to publish values

Quick Notification (strawman)Criteria:

• Non-exporting (inadvertent export is allowed?); (secondary network?)

• Storage nameplate <= 30 KW

Process:

• IOU publishes executable GIA form

• System operator may start parallel operation once installation is complete

• Within 5 business days from COD, System operator submits

• All technical specs, approved building permit

• Recording fee same as NEM application fees

• Completed & signed GIA

• Photos of installation

• IOU contracts group verifies completeness and criteria, including photos of installation.

• IOU contracts group records installation as “Reviewed” in interconnection records and notifies system operator within 15 business days

Screen F1 Follow Up “Is DER Short Circuit Contribution ≤ 1.2 p.u.?”

Tesla comment: Although Tesla does not oppose the addition of Screen F1 in concept, we are very concerned with the described execution, whereby a hard limit of 1.2pu would be established above which a project would be subject to supplemental review. Most inverters contribute between 1.1 and 1.5pu meaning that if the proposed F1 is implemented as described, it appears that many systems would be at significant risk of being pushed into supplemental review

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Recommendations toward Interconnection Automation: Objectives & Opportunities

Tam Hunt, Green Power Institute

Sahm White, Clean Coalition

Smarter Grid Solutions, Inc.

Objectives

• Our main objective is to reach working group consensus on the potential for practical automation and streamlining of interconnection

• This report and recommendations would be submitted to the Commission for use in guiding additional work in later phases of this proceeding, potentially toward adoption of a roadmap or related interconnection goals

• Concurrently, we urge IOUs to continue to identify and implement sensible automation and streamlining options in the near term, pending Commission guidance

The draft document is meant to be a summary of recommendations and possible options for the Rule 21 Working Group 2 to adopt as part of its consideration of automation and streamlining of the DER interconnection process. With the Working Group’s consideration, input, discussion, and adoption of these recommendations, it is GPI’s and the Clean Coalition’s intention that this document be used in support of actionable guidance or a “roadmap” for adoption by the Commission, after further deliberation in this proceeding

Summary of draft opportunitiesFocusing on larger NEM projects and smaller wholesale projects (~0.5-3 MW)

• Automating the application process and completeness review • Reduce time from 1-40 business days (BDs) to 1 day review for projects that don’t require corrections• Reduce turnaround time for corrections from 10 BDs per round of corrects 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 these screens in IR (no additional time required) for eligible

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

• Combining Initial Review and Supplemental Review • Only applies to projects that select this option, which will generally be large NEM and wholesale projects• Timelines and fees for the combined IR/SR to be determined as part of the working group

• 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• Automate population of template GIA with study results so that draft GIA can be generated in 1 day rather

than 15 BDs

• Work to identify additional automation and streamlining items

The number of distributed energy resources seeking interconnection with the distribution

system has increased exponentially over the last several years in New York State. This

has put increasing pressure on utilities to respond to interconnection requests in a timely

manner. Concurrently, interconnection requests are becoming more challenging and

nuanced as parts of the grid reach static hosting capacity limits

Challenge

Solution

Smarter Grid Solutions is working with Clean Power Research, CYME (Eaton), and

AVANGRID to map out the data transfers and protocols required to offer an IOAP in order

to expedite interconnection requests under the New York State Standardized

Interconnection Requirements and AVANGRID’s Flexible Interconnect Capacity Solution

(FICS) which leverages SGS’ Active Network Management solution. The proof of concept

not only provides an online portal to developers, but also provides AVANGRID with a

single resource from which to manage the interconnection queue.

Benefits

The IOAP will provide a single resource point for project information and automation of technical screens as well as other analysis related to interconnection alternatives (e.g., FICS) with the ultimate goal toward streamlining interconnection applications, better interconnection queue management, and providing developers with more certainty – helping New York to achieve its ambitious clean and distributed energy goals.

Integrated Online Application Portal (IOAP)

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Market

Generation income

Long term Ratepayer Advantages

• Lower rates due to capital investment

• Potential increased resiliency

DER developer(customer)

Limited upfront investment

Placement efficiency

Future Opportunity: Leverage

platform

Optimize capacity

Distributed GridDistributed Grid

Market

Upfront Upgrade Cost

Generation income

$ flow

DER developer(customer)

Interconnect

Traditional Interconnect

Flexible Interconnect Capacity Solutions (FICS) Flexible Interconnection

Preliminary Cost/Benefit Analysis (SGS)

Automation Action

Estimated process streamlining (days)

Utility savings (person days)

Type of investment needed (labor, license, other)

Relative cost / complexity

Relative benefit-cost ratio

Application Portal, Queue Mgmt, Queue publishing

5+ 5+ • SaaS license

• IT (labor)• Design of

UI (labor)

Medium High

Automating ICA and ICA updates

n/a 5+ • Power system analysis tool license (toolbox)

• Dist Planning (labor)

• IT (labor)

Medium to Hard

Medium

Preliminary Cost/Benefit Analysis (SGS)

Automation Action

Estimated process streamlining (days)

Utility savings (person days)

Type of investment needed (labor, license, other)

Relative cost / complexity

Relative benefit-cost ratio

Automating screens not in ICA

2-5 days 2-5 days • Dist Planning (labor)

• IT (labor)

Medium Medium

Restructuring IR and SR steps3

5+ 1-2 days • Process design (labor)

Easy but contingent of previous steps

High but depends on stakeholder

Front loading and automation of GIA

1-2 days n/a Process design (labor)

Easy once process management tool implemented

Medium

Thank you

• Tam Hunt, GPI

• Sahm White, Clean Coalition

• Chad Abbey and Christopher Williams, SGS

Rule 21- WG

Interconnection Automation Potential

Aug. 1, 2018

Context

CYME participates in all of these:

• Fast track screens with CYME DG Screening Tool

• Integration capacity with the ICA module

• Detailed interconnection studies using DER Impact evaluation

and others

Detailed Analysis

Current Automation

CYME Server

CYME

Gateway

Integration

Capacity

Analysis

Automation

Online Map

CYME DG

Screening

Tool

Interconnection

Request

CYME

Desktop

CYME

Model

Detailed Analysis

Potential Automation

CYME Server

CYME

Gateway

Integration

Capacity

Analysis

Automation

Online Map

CYME DG

Screening

Tool

Interconnection

Request

CYME

Model

PORTAL

w/ Utility Feeder

Developers

*Certified

CYME

Desktop

CYME

DesktopCYME

DesktopCYME

DesktopCYME

Desktop

Interconnection

Request Approved

& Associated Costs

CYME

Desktop

CYME

Desktop

CYME

Desktop

QUESTIONS, CONCERNS, THOUGHTS?

Aug. 1, 2018

ScheduleNext WG meetings:

- 8/1: Call

- 8/8: In-person (SCE)

- 8/21: Call

- 8/29: In-person (CPUC Golden Gate Room)

- 9/12: Call

- 9/19: In-person (CPUC Golden Gate Room)

- 10/3: call

- 10/10: In-person (Golden Gate Room)

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