Rule 21 Working Group 2 - Gridworks · Issue A Brief (CALSSA & IREC) Proposal: CALSSA and IREC...

Rule 21 Working Group 3

IN PERSON MEETING

10 AM – 3 PM

JANUARY 23, 2019

OAKLAND CENTRE

HTTPS://WWW.UBERCONFERENCE.COM/GRIDWORKS

https://gridworks.org/initiatives/rule-21-working-group-3/

https://www.uberconference.com/gridworks

2

Agenda

10:00-10:10 Agenda, regulatory updates

10:10-10:40 Issues A & B proponent presentations

10:40-11:30 Issues A & B utility comments / discussion

11:30-12:15 Issue 15 PG&E presentation / discussion

12:15-1:15 Lunch

1:15-2:00 Issue 16 resolution / finalization

2:00-2:20 Issue 12 updates

2:20-2:50 Issue 23 updates

2:50-3:00 Wrap-up


3

Regulatory Updates


4

Issues A & B Presentation

Issue A: What changes are needed to clarify the parameters for approval of system design to achieve non-export and limited export.

Issue B: How should utilities treat generating capacity for behind the meter paired solar and storage systems that are not certified non-export?


5

Issue A Brief (CALSSA & IREC)

Goal: provide a clear option that allows projects to qualify as non-exporting, limited export, or inadvertent export using storage control systems.

Background: Certification Requirements Decision (CRD) developed under 2020 NEC 705.13 is expected to receive final approval this month as an addendum to UL 1741. Would handle both non-export and limited export.


6

Issue A Brief (CALSSA & IREC)

Proposal:

CALSSA and IREC propose that Rule 21 recognize the new standard.

• If a system is certified to the standard as non-export with a response time within the defined boundaries of Rule 21, it should be eligible for inadvertent export.

• If a system is certified to the standard with a fixed maximum export higher than zero, it should qualify as limited export.


7

Issue B Brief (CALSSA & IREC)

Situation: A system that does not qualify for non-export or inadvertent export is currently studied in interconnection review under the scenario of “nameplate plus nameplate” for solar and battery.

On the whole this is not a realistic scenario. Customers may wish to set a controlled maximum export vale that is less than nameplate plus nameplate.


8

Issue B Brief (CALSSA & IREC)

Proposal:

1. Amend Rule 21 to accept a maximum export value (or limited export) for systems using equipment that is certified to the Power Control Systems CRD.

2. Within 60 calendar days of completion of Phase 2 of the Power Control Systems CRD, utilities must issue an advice letter incorporating scheduled changes to maximum export values for solar and storage systems.

3. Expressly identify that certified limited export projects will be studied according to the maximum export value for specified technical issues (i.e. not at nameplate value except for in cases of short-circuit duty contribution).


9

Issues A & B Gridworks Consultations

• Timing of our process: wait for CRD standard, or not, before developing WG3 proposal?

• Scope of CRD: will CRD Phase 1 address NEM, non-export, and inadvertent export? Or just limited export? Issue B requires CRD Phase 2

• Confidence (judgement call): interconnection safety of inverter functions, with or without CRD (no relay)

• Cost of relay: non-export covered now with relay

• End-to-end process: needs to be specified, including implementation and inspection. Do this in WG3?

• Existing language: for certified inverters Section Hhtakes care of protection equipment

• Dependency: on resolution of WG2 Issues 8 and 9


10

Issues A & B Utility Comments


11

Issues A & B Discussion


12

Issue 15

Should the Commission require itemized billing for distribution upgrades to enable customer comparison between estimated and billed costs and verification of the accuracy of billed costs?


13

Issue 15 Presentation & Discussion

PG&E “fixed cost” option:

• Interconnection upgrades & distribution upgrades that are greater than 1 MW

• SFA / no true ups, pay up-front, itemized like UCG

• With true up of actual costs, no way to itemize costs after work is done

• Requires IT work and funding


14


SCE “construction bid” model (per CALSSA):

• Change to bring their process in line with that of PG&E

• Customer cost based on estimate after final engineering, no reconciliation with actual costs.

• Final estimate/invoice itemized per UCG categories

• “SCE has been open to this proposal and they are running the traps internally”

• Lack of competition to provide checks and balances but still prefer this to a system where there is too much uncertainty on what costs turn out to be.


15


Action Items (from Jan 16 call):

• Suggested poll of industry preferences regarding the options presented by PG&E (Unfilled)

• A process of higher-level approvals is needed at IOUs, may take some weeks (IOUs)

• Revised timeline for finalizing Issue 15 to be established. (Gridworks)

• Still to discuss? Data break-out that allows differentiating equipment costs with some type of data manipulation (by utility or customer)


16

Lunch

17

Issue 16

Should the Commission encourage third party construction of upgrades to support more timely and cost-effective interconnection, and if so, how?


18

Issue 16 Discussion & Next Steps(from Jan 16 call)

• Issue proponents are not proposing changes to 3rd party requirements from current Rule 15/16, except the need was recognized for the WG to further discuss existing and energized facilities, considering legal, liability, outage scheduling, and supervision issues.

• The WG needs to continue to discuss the possibility of allowing 3rd party contracting on energized equipment or existing facilities upgrades. (All parties)

• For energized and existing facilities, some research by parties: “look at history of Rule 15 and 16, it has all been argued.” (Unfilled)

• Issue 16 proponents (GPI & Clean Coalition) will share revised Issue 16 proposal, based on 1/16 discussion, during the week of 1/21, and update further at 1/23 meeting.


Issue 16 DiscussionGPI and Clean Coalition 3rd

party contracting proposals

Tam Hunt and Rebecca Davis, Green Power Institute

Sahm White, Clean Coalition

Our proposed solutions

• We propose tariff changes as follows:• Strike language providing IOU discretion to disallow third parties

• IOUs to produce eligibility criteria for third parties (to be developed jointly with stakeholders in this working group)

• Add language allowing any eligible third party to apply to be added to the list, with a 45 calendar day deadline for a decision on each application

• Energy Division to review applications from third parties, based on eligibility criteria, and create a list of approved third parties, in consultation with each IOU. Approved list to be based on: a) contractors who already design and construct interconnection upgrades for IOUs, as well as b) new applicants who are found to meet the eligibility criteria

21

Issue 16 OneDrive Comments on GPI/Clean Coalition Proposal• David Cheng (TURN): The tariff should clarify that the third party, not

the utility, will be liable for damages caused by the third party’s work or equipment. Part of the eligibility criteria should also include sufficient financial showing or deposit to cover potential liability.

• Lee Trevino (PG&E): Third-party construction is common practice under Rule 15 as a “competitive bidding” option. Under this option, the applicant’s qualified contractor may install line extensions, including equipment, which would otherwise be installed by the utility. PG&E has well established processes and requirements as stated in filed Form 79-716, “General Terms and Conditions for Gas and Electric Extension and Service Construction by Applicant”. The general terms and conditions include detailed requirements for liability insurance and eligibility, which should address the comment by TURN above.

• As an alternate to the proposal by GPI and Clean Coalition, Rule 21 may refer to Rule 15 for Applicant Install tariff language, akin to the language in Rule 16.D.3.b, “Applicant may elect to use competitive bidding to install that portion of the new Service Extensions normally installed and owned by PG&E in accordance with the same provisions outlined in Rule 15.” With the emergence of Zero Net Energy and new projects that may fall under multiple tariffs (i.e., Rule 21, 15, and 16), keeping a single set of tariff requirements would be optimal.


22

Issue 12

How can the Commission improve certainty around timelines for distribution upgrade planning, cost estimation, and construction? Should the Commission consider adopting enforcement measures with respect to these timelines? If so, what should those measures be?

Issue D: When should the Commission consider results of an initial review or detailed study to be binding? Under what circumstances should the Commission allow the results to be changed?


23

Issue 12 Discussion & Next Steps(from Jan 16 call)

• The IOUs will provide their written comments on Issue 12, which have been under preparation for a number of weeks, by mid-to-late next week (1/23-1/25)

• IOU written comments together with proponent proposals will be integrated and structured into one document and available by 1/31 for structured discussion on 2/6 call. (Gridworks)

• Stakeholders are invited to propose tracking timelines and reporting metrics by 1/30 to be discussed on 2/6 call (All parties)

• An off-line consultation and resolution process should be conducted through 2/6 to attempt to develop consensus options related to goals and accountability. (Gridworkstogether with proponents)


Rule 21 Working Group 3

Issue 12 – TimelinesProposal Outline

January 7, 2019

Proposal Summary

1. Establish timeline for NGOM installation

2. Report timeline data

3. Increased notification of timeline exceedences

4. Consideration of penalties

NGOM Timeline

• Utility must issue agreement and invoice within 20 business days of receiving a signed interconnection agreement

• Utility must install NGOM within 20 business days after invoice is paid and documentation is provided that customer work is completed

Data Reporting

• Frequency – Monthly? Quarterly?

• Line up with existing quarterly reports?

• Summaries/Averages/Categories or database of anonymized records?

• Massachusetts example

• Can any info be produced retroactively?

• What data is being systematically compiled today?

Notification

• Two lines of manual entry• Cause for delay

• New expected completion date

• Notification steps for NGOM• NGOM Installation – Meter Engineering Queue

• NGOM Installation – Pending Local Planner Process (current)

• NGOM Installation – Invoice Released; Pending Payment

• NGOM Installation – Payment Received; Pending AHJ Release

• NGOM Installation – Payment Received; Pending MSR Creation

• NGOM Installation – Meter Request Released - Pending Installation (current)

• NGOM Installation Complete – Pending SCE Engineer Review (current)

• Design and construction

• 60 business days for each, consistent with Issue 10 proposal

Enforcement Mechanism

• Option 1: Set date for consideration of penalty structure after evaluation of data

• Option 2: Utilities need to demonstrate their interconnection performance was adequate to achieve full cost recovery in GRCs

Interconnection AccountabilityFramework + Goals

Sky Stanfield

Rule 21 Working Group 3January 10, 2018

Steps to Accountability1. Establishing appropriate reporting criteria and

mechanism to establish baseline;

2. Set clear goals for maintenance of compliance

and improvement in the areas where timelines

are being missed; and

3. After specified period, evaluate if reporting and

goal tracking were effective at sufficiently

improving and maintaining compliance with the

timelines. If not, establish a mechanism for

adopting a more direct financial incentive system.

What Will be Reported

– Identify timelines that will be tracked

• Major steps in process

• Include construction timelines

• Be clear regarding starting and end point for

each increment

– Report anonymized data for each project with

aggregated percentages

– Determine frequency of reporting (quarterly?)

Revisit Progress After 2 Years• After 2 years, or 8 reporting periods, the Commission shall

automatically schedule a workshop to discuss progress.

• A more direct financial accountability mechanism shall be adopted if

any utility has not reached 95-100% compliance with each timeline.

• Workshop should also evaluate whether:

– The reporting process itself is tracking the right information,

– If the reports are conveying an accurate picture of the

interconnection customer’s experience, and

– Consider any other appropriate tweaks that may be necessary to

help improve transparency and accountability.

• Adoption of a financial mechanism need not be considered if the

utilities have met their compliance goals, though this should be

revisited every three years to ensure compliance is maintained.

34

Issue 12 OneDrive Comments

• David Cheng (TURN): If a penalty is imposed for either option, it needs to be made clear that the penalty will be paid by shareholder dollars, not ratepayer dollars.

• Tam Hunt (GPI): GPI generally supports CALSSA’s proposal but would like to see more details. We agree that meeting timelines has been a serious problem in Rule 21/WDAT for many/most larger projects (small NEM projects seem to be doing well in terms of timelines), with a lack of accountability in the current rule structure. We also agree that more data is needed, with IREC’s 2018 data requests a good start for a more comprehensive approach, and we look forward to seeing the CPUC’s efforts on data gathering to fruition in 2019. GPI also agrees that an enforcement mechanism is required to ensure that all timelines are met. We also look forward to planned improvements in the interconnection portals….


35

Issue 12 OneDrive Comments

• Tam Hunt (GPI): GPI is also supportive of this approach but needs more information on how CALSSA and IREC proposals interact or if they’re meant to be mutually exclusive. We look forward to fleshing out the details of this proposal. We also urge the IOUs to work proactively with IREC and other stakeholders to ensure that their new interconnection portals and processes more generally (already planned) automatically track this data and report at least quarterly to the Commission and stakeholders on the tracking results. There is significant overlap, accordingly, between Issue 12 and 22 (interconnection portals) if we agree that Issue 22 doesn’t include only issues related to the frontend design, but also items like data tracking, timelines and reporting.


36

Issue 23

Should the Commission consider issues related to the interconnection of electric vehicles and related charging infrastructure and devices and, if so, how?


Rule 21 WG #3 Issue #23

V2G Interconnection Issue Proposal Follow-Up

January 17, 2019

37

▪ Proposal Concepts:

− Establish applicability of Rule 21 only when bi-directional capabilities are activated and utilized

− Authorize V2G DC interconnections and make the appropriate modifications to the Rule 21 tariff and portal

− Direct a sub-group within Working Group #4 in this proceeding (R.17-07-007) to more deeply address V2G AC interconnection issues

− Clarify a pathway for parties to interconnect V2G AC systems on a timely basis for experimental and/or temporary use

38

Presentation Overview

▪ CESA recommends that applicability of the Rule 21 tariff specifically call out the non-applicability of V1G and V2G systems when V2G capabilities are activated

▪ CESA proposes the following redline changes:

4. Interaction with Other Tariffs for Storage or Vehicle-to-Grid Charging Load Treatment

For retail customers interconnecting energy storage devices pursuant to this Rule, the load aspects of the storage devices will be treated pursuant to Rules 2, 3, 15, and 16 just like other load, using the incremental net load for non-residential customers, if any, of the storage devices.

For retail customers activating vehicle-to-grid devices to interconnect to the distribution grid, the load aspects of the vehicle-to-grid devices will be treated pursuant to Rules 15 and 16 just like other load, using the incremental net load for customers, if any, of the vehicle-to-grid devices. This Rule only applies to vehicle-to-grid devices that operate as a Generating Facilities for retail customers seeking to activate vehicle-to-grid capabilities. Vehicle-to-grid devices should otherwise not be applicable to this Rule and should be only applicable to Rules 15 and 16.

39

Proposal #1: Applicability

▪ CESA raises the possibility of defining “vehicle-to-grid” and how to define “activation” of V2G capabilities, as it would clarify applicability questions for V2G systems – i.e., when V2G systems should be treated as Load Facilities versus Generating Facilities

▪ CESA proposes the following redline changes to Section C:

Vehicle-to-grid devices: Electric vehicles or electric vehicle supply equipment that have the capability of bi-directional electrical energy flow between the electric vehicles or electric vehicle supply equipment and the host customer load or grid

Activate; activation: The act or condition of Load Facilities modifying inverter or equivalent controls to operate and be treated as Generating Facilities

40

Proposal #1: Applicability

▪ Authorize V2G DC interconnections and make the appropriate modifications to the Rule 21 tariff and portal:

− Modify interconnection portal (Issue #22) to accommodate EVSEs in Rule 21 application

• This can be addressed in Issue #22

− Streamline study processes (Section N expedited process for non-export storage)

• No major changes needed, including on requiring UL-1741 certified smart inverter in Section N

• What is the status of continuing Section N processes?

• Additional policy questions that may not be addressed here but should be considered broadly:

Can threshold and multiple generator provision be reassessed given EV fleets?

Can we strike the provisions around control systems ensuring that there is no increase in a customer’s existing peak load demand?

What is the status of continuing Section N processes?

41

Proposal #2: V2G DC Interconnections

▪ CESA proposes the following redline modifications to the Rule 21 tariff Section D (General Rules, Rights, and Obligations):

14. Special Provisions Applicable to Non-Export Energy Storage Generating Facilities

Applicants with Non-Export Energy Storage Generating Facilities, including direct current vehicle-to-grid energy storage systems, that meet the criteria listed in Section N shall be eligible to elect to have their Interconnection Requests processed in an expedited timeframe, subject to the terms and conditions of Section N.

▪ Similarly, the opening applicability paragraph of Section N would need to be modified:

Upon implementation by Distribution Provider, Applicants with Interconnection Requests for Non-Export Energy Storage Generating Facilities, including direct current vehicle-to-grid energy storage systems, who meet the requirements outlined below are eligible for expedited interconnection, as provided herein, in accordance with the Fast Track Process technical review requirements of Section F.2. Applicants with Non-Export AC/DC Converters that meet the requirements outlined in Section O below are also eligible.

42


▪ Authorize V2G DC interconnections and make the appropriate modifications to the Rule 21 tariff and portal:

− Create expedited interconnection process similar to NEM generating facilities for the exporting use cases

▪ Alternatively, a new sub-section of Section N and Section B.5 could be created for V2G DC systems and broadly for V2G systems in general, thus teeing up future consideration of V2G AC interconnections:

− As opposed to lumping them in with BTM energy storage

43


▪ Direct a sub-group within Working Group #4 in this proceeding (R.17-07-007) to more deeply address V2G AC interconnection issues:

− More time is needed

− Are there ways to break this issue out for more immediate sub-group attention?

• Do we have to wait until WG #3 report is completed, commented on, and decided?

• Stakeholders are locked and ready to put in the time to develop proposal

− How can we initiate more deeper understanding of SAE J3072 (more applicable standard)?

− Can the definition of “smart inverter” be broadened to not be limited to a ‘box’ but allow smart inverter functionalities, including communication capabilities, encompass the combination of the EVSE and EV?

44

Proposal #3: V2G AC Interconnection Discussions

▪ Clarify a pathway for parties to interconnect V2G AC systems on a timely basis for experimental and/or temporary use:

− The IOUs should clarify a path for some temporary allowance for pilots and experimentation and not hinder pilot deployments due to interconnection issues

• Key learning opportunities would be deterred

• They may have de minimis impact and are overseen by CPUC/CEC

− Temporary exemption from Rule 21 smart inverter requirements at limited levels appears to be worthy of consideration at this time while being supplemented by SAE J3072 certification

• Key learning opportunities would be deterred

45

Proposal #4: V2G AC Interconnection Pilot Approval

46

Issue 23 Further Comments & Next Steps (from Jan 20 call)

• V2G capable but not activated then Rule 15 & 16• How to keep from going rogue?

• Authorize V2G DC case (export and non-export)• Section N applies to non-export case

• Status of confirming Section N, pilot process continuing• Economics and business model for export case?• Export case may not be a V2G-specific issue, refer to Issue 8(m)

discussion• Difference V2G inverter vs. PV inverter, do we have time to address

in WG

• Refer V2G AC case to WG4• “Define universe of questions” in WG3• Change scope of WG4 now• SI can never be just one physical “box”• Compliance with IEEE 1547 vs. UL 1741 • “Rule 21 was never meant for mobile platform”


47

Issue 23 – OneDrive Comments

• GPI on CESA proposal: GPI is supportive of allowing V2G interconnections under Rule 21. We are not clear why a subgroup should wait until WG4, however, as suggested in #3 above. If more time is needed it is GPI’s view that it would be better to seek an extension of WG3 rather than punting to WG4.

• GPI on CEC proposal: it’s not clear specifically how #2 and 3 differ. Is it suggested that developing electrical safety standards for mobile inverters will be the first step in developing interconnection rules for mobile inverters? Will development of similar safety standards be required as a prerequisite for #2?

• David Cheng (TURN) on Nuvve proposal: TURN believes that these issues are out of scope for this proceeding and should instead be considered in the EV proceeding(s)

• Tam Hunt (GPI) reply to TURN: These issues are in scope b/c they specifically relate to interconnection and were scoped in this proceeding. GPI agrees with the crossover between Issue 22 and 23 and therefore the need to coordinate.


48

Issue 23 CEC (Jan 10)

Identified 3 problems and issues:

1. Conformance of safety standards for V2G interconnections 2. Regulatory acceptance of UL and or SAE certifications 3. Certainty in technical specifications for co-investments in

V2G

Identified 3 topics that are in-scope:

1. Definition of inverter, and how it applies to and impacts EV design, operation or aggregation.

2. Interconnecting an inverter within a stationary DC EVSE that operates as a bidirectional generator.

3. Electrical safety standards for interconnecting a mobile bidirectional AC charger inverter onboard an EV


Nuvve Copyright 2018

CPUC Rule 21 Working Group 3, Issue 23January 10, 2019

Jaqueline Piero, Director of Policy

Nuvve

Nuvve Copyright 2018

Proposal for Discussion

1) Clarify in Rule 21 that load only / V1G inverter-based systems are excluded from Rule 21.

2) Clarify the requirements of Rule 21 apply for EVSE configured for bidirectional operation, including those for Smart Inverters with language similar to the following:

• “Electric Vehicle Supply Equipment (EVSE) that conforms to section Hh and is certified to have been tested in accordance with UL 1741-SA and passed may otherwise interconnect under Rule 21.”

3) Coordinate with Issue 22 (IOU interconnection application portal improvements) to accommodate interconnection of V2G systems otherwise approved to interconnect, minimally with a single check box on the online Interconnection Application Form.

4) Recommend the Commission address other issues related to V2G, particularly the interconnection and operations of AC EVSE and vehicle on-board inverters configured for bidirectional operation (V2GAC), as well as specifically identify the appropriate forum where additional time can be allocated to create the record and address these complex issues.

Utilizing Vehicle Resources for Balancing the Grid

Satoru Shinzaki

Honda R&D Americas, Inc.

Torrance, California

Jessalyn Ishigo, Annika Nordlund-Swenson

American Honda Motor Co., Inc.

Torrance, California

12

Configuration Advantages Disadvantages

System w/ on-board converter

(AC out from vehicle)

• Lower overall cost

• Normal charge

connector can be

used

→ More frequent

participation is

expected

• Getting inverter

recognized

(Roaming grid-tied

inverters are new

concept.

UL stds such as

1741, are not

suitable for auto

applications)

System w/ off-board converter

(DC out from vehicle)

• Small or no change

on vehicle side

• Clear path to get

inverter certified

• High inverter cost

• Bigger charge

connector

→ Less suitable for

home use

Two Solutions – Honda’s View

Grid

AC

DC

Bi-directional

converter

EVSEAC DC

DCAC

AC

52

Either way, both solutions need to be safe!

Off-board

inverter

AC

DC

12Appropriateness of UL for Auto Devices

Concept of ensuring safety: Very different between UL and auto field

UL: To ensure longevity with structural ruggedness and enough spacing

Auto: To ensure longevity under stringent usage conditions with various methods• Accelerated and/or abuse tests

• Advanced materials

• Multi-step protections

• Weather, vibration cycles

UL 1741

compliant

charger

*same

performance

Volume=100 Volume=180

*Honda’s estimation

for avoiding unnecessary weight and volume

Automakers are attempting to accommodate all functionalities in vehicles

→ Functional safety to be ensured by meeting

IEEE 1547 requirements, including anti-islanding

54

Schedule – Working GroupDate Meeting Issue Discuss Issue Finalize Location

Jan 23 In person A & B 16 Oakland Centre (1000 Broadway)

Feb 6 Call

Feb 13 In person 20 & 22 12 & 23 CPUC – Golden Gate Room

Feb 27 Call

Mar 6 In person 24 A & B CPUC – Golden Gate Room

Mar 20 Call

Mar 27 In person 20 & 22 CPUC – Courtyard Room

Apr 10 Call

Apr 17 In person 24 & 27 & 28 CPUC – Courtyard Room

May 1 Call

May 8 In person Final report CPUC – Golden Gate Room

May 22 Call

May 29 In person Final report CPUC – Courtyard Room

Jun 12 Call

Jun 24 Report due

55

Schedule – SIWG Issue 27/28 Calls

For Issues 27 and 28, there is a separate set ofphone discussions with all SIWG members invited, which will lead to discussion during the in-person meeting on April 17:

Jan 31 1-2:30pm PST

Feb 21 1-2:30pm PST

Mar 14 1-2:30pm PST

Apr 4 1-2:30pm PST

The first call already took place December 19; notes and issue framing from that call forthcoming by January 4.

56

Wrap Up

• non-IOU party volunteer for the Feb 1 status update


57

Wrap Up

Next calls and meetings:

• Jan 31 – Issue 27/28 SIWG call• Feb 6 – Conference call (Issue A, B, D, 12, 15)• Feb 13 – In-person meeting (CPUC) • Feb 27 – Conference call• Mar 6 – In-person meeting (CPUC)


Rule 21 Working Group 2 - Gridworks · Issue A Brief (CALSSA & IREC) Proposal: CALSSA and IREC...

Documents

Transcript of Rule 21 Working Group 2 - Gridworks · Issue A Brief (CALSSA & IREC) Proposal: CALSSA and IREC...