Rule 21 Working Group 3

1. Rule 21 Working Group 3 SIWG CALL ISSUES 27 AND 28 APRIL 4, 2019 https://zoom.us/j/488565400 https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-3/

2. Agenda 1:00-1:10 Review 6 use-cases and questions (a)-(f) from past calls 1:10-1:45 Presentation/clarification of CALSSA 3/29 proposal • New proposal elements not included in previous discussions • Differences in use-cases from previous discussions 1:45-2:15 Review and comments on IOU 3/29 proposals • Proposed Rule 21 tariff changes and timelines • Roadmaps for additional work needed to incorporate use cases into tariff language • Additional technical work needed for each use case 2:15-2:30 Integration of all proposals • Roadmap and framework as final WG3 report https://gridworks.org/initiatives/rule-21-working-group-3/

3. Issues 27 and 28 Issue 27. What should be the operational requirements of smart inverters?  What rules and procedures should the Commission adopt for adjusting smart inverter functions via communication controls? Issue 28. How should the Commission coordinate with the Integrated Distributed Energy Resource proceeding to ensure operational requirements are aligned with any relevant valuation mechanisms?

4. Review of the Six Use-Cases and Questions (a)-(f) from Past Calls

5. IOU Issue 27 Proposals https://gridworks.org/initiatives/rule-21-working-group-3/

6. CALSSA Revised Proposal (1) What should be the operational requirements of smart inverters? • The operational requirements of smart inverters are contained in the existing language of Rule 21. If an IOU or customer wants to use settings other than the default settings, parties must mutually agree. • If the IOUs recommend new functions such as Watt-Var in order to implement tariff-based customer offerings to provide passive or active services to the distribution system, they must include laboratory modeling and field pilots to understand the impact and benefits on IOU infrastructure and on customers. • The SIWG will need to reconvene to support this research and potential Rule 21 updates. https://gridworks.org/initiatives/rule-21-working-group-3/

7. CALSSA Revised Proposal (2) What rules and procedures should the Commission adopt for adjusting smart inverter functions via communication controls? • In addition, pA customer must get utility approval for changes to settings of smart inverter functions. For use cases that enable a customer to install a system that would otherwise not be allowed, the request for approval can be in the interconnection application informed by the Integration Capacity Analysis. • arties can mutually agree to a mitigation path in response to the results of interconnection review. • If the utility offers the option to use alternative settings as a condition of interconnection approval, the customer can accept that option and the utility will include the alternate settings in the interconnection agreement. • The customer will be obligated to maintain those settings unless they receive later approval from the utility to change them. • After the customer has received approval for settings changes, the customer must document the settings for the utility. https://gridworks.org/initiatives/rule-21-working-group-3/

8. CALSSA Revised Proposal (3) For changes to the Volt-Var default settings, the following information must be communicated: • Reactive Power Injection (V1) Voltage Value: • Reactive Power Injection (Q1) Reactive Value: • Unity Power Factor (V2) Voltage Value: • Unity Power Factor (Q2) Reactive Value: • Unity Power Factor (V3) Voltage Value: • Unity Power Factor (Q3) Reactive Value: • Reactive Power Absorption (V4)Voltage Value: • Reactive Power Absorption (Q4) Reactive Value: • Open loop response time: For changes to the Volt-Watt default settings, the following information must be communicated: • End of Full Power Production Capabilities Zone (percent of nominal voltage): • Percent Reduction of Active Power Production Per One Percent Increase in nominal Voltage: • Beginning of No Real Power Production Zone (percent of nominal voltage): https://gridworks.org/initiatives/rule-21-working-group-3/

9. CALSSA Revised Proposal (4) The Commission should recognize the following use cases as important to harnessing the grid benefits of distributed resources and prioritize their development. Interconnection: • Scheduled Power • Dynamic Power Reduction • Operational Flexibility. Grid Services: • Capacity • Constant Voltage • Dynamic Voltage Boost • Voltage https://gridworks.org/initiatives/rule-21-working-group-3/

10. CALSSA Revised Proposal (5) Reactions to SCE Matrix of Use Cases • SCE has presented a matrix of six uses cases. The Commission should recognize that there are subsets of each of those use cases. For example, each of them can be either scheduled or dynamic. • Real-time communications can provide a higher confidence level of services provided, but less than real-time communications can also validate services provided. • The Commission should not make any firm determinations of inverter function settings until tariffs or programs are defined. Create Roadmap for DERMS Deployment • In order to fully utilize Phase 3 functions, utilities need to significantly expand their current DERMS capabilities. • Utilities should present DERMS roadmaps at a Commission workshop, followed by comments from parties. This should include the role of Rule 21 aggregators. https://gridworks.org/initiatives/rule-21-working-group-3/

11. SCE Proposal—Tariff Changes and Timelines • Specific text provided for a new sub-section D.17 under Rule 21 Section D (General, Rules, Rights, and Obligations) that would specify the types of changes to the Rule 21 default settings, the processes, timelines, and any associated costs for necessary technical evaluations. • Propose that this new section be refined and integrated in Rule 21 within 6 months of the issuance of the final Working Group Three Decision via an Advice Letter. • Develop the conceptual requirements into final tariff language • 6 months from WG#2 final decision via the process described below • Developed by utilities and interested stakeholders • Presented to the joint R21 & SIWW for discussion/consensus • IOUs to file advise letter to update Rule 21. Tier level based on level of consensus, 6 months from WG#3 final decision https://gridworks.org/initiatives/rule-21-working-group-3/

12. PG&E Proposal—Tariff Changes and Timelines • PG&E generally agrees with the Smart Inverter use case priority proposed by SCE. PG&E agrees that issues related to equitable sharing of upgrade costs in the interconnection process need to be further explored and a framework needs to be implemented by the commission to address issues such as those highlighted by SCE. • PG&E also agrees with SCE that as long as SCE’s priority #1 (reliability) and priority #2 (alternative interconnection mitigation) conditions are not violated, DERs may also provide services to the distribution grid in accordance with a contractual obligation. These settings changes should be allowed by mutual agreement between the utility and DER provider, and may be specified in the interconnection agreement. • With regard to the #3 priority use case (grid services), PG&E would like to reinforce some of the key points that PG&E, SCE and SDG&E put forth in the October 2018 Joint IOU Smart Inverter White Paper. • A robust methodology for validating the DER’s grid impact must be established. Four components/principles need to be further explored, and further grid modernization efforts are needed to enable these. https://gridworks.org/initiatives/rule-21-working-group-3/

13. SDG&E Proposal—Tariff Changes and Timelines • SDG&E believes that the operational requirements of smart inverters have been defined through the SIWG process in Phases I-III and should be implemented accordingly, with modifications to comply with overarching national standards. • SDG&E believes it is premature to propose tariff changes at this time. • Autonomous functions in inverters are all that is required for the immediate future to facilitate fixing the problems created by distributed energy resources (DERS) systems as they are deployed. Proposing and implementing further operational requirement are premature • Addressing the questions identified in this issue will require a number of actions to occur, which are well beyond the purview of SDG&E: • Communication requirements must be codified. • Consensus on party roles must be reached. • Significant penetrations of smart inverters with IEEE 2030.5 protocol must be achieved. • Systems to control a large fleet of DER via DERMS must be deployed and functional. • SDG&E is unable to estimate when all these actions will be completed as developments required to complete them are the responsibility of third parties. https://gridworks.org/initiatives/rule-21-working-group-3/

14. SDG&E Proposal – Next Steps • SDG&E ProposedRoadmap: • IOU developscommunicationsinfrastructure to communicatewithbothinverters, energy management systems, and aggregators. • IOU developsrequired DERMS capabilities for Phase II communications and Phase III Functions 1 and 8 additional smart inverter requirements. • All partiesestablish and implementcommunicationsapplicationsthatcomplywithRule 21 for integratinginverters, EMS, and aggregatorswith DERMS. • IOU updatesinterconnection portals to collectnecessarycommunicationsinformation for newlyconnected smart inverters. • Standards bodiesapproveanyapplicablenational standards for smart inverters (functionality and communications). • NationallyRecognized Testing Laboratories (NRTL) establish end-to-end test environment for smart inverter communicationsbasedonnational standards. • IOUsobtainapproval from CPUC throughthe general rate case (GRC) process to implement DERMS and communicationsnetworks for smart inverters. • Developcompensationmechanismsbasedonoutcomeofotherproceedings (e.g. IDER, DRP, NEM). • Developapplicablecontracts. https://gridworks.org/initiatives/rule-21-working-group-3/

15. Issue 27-28 Next Steps –Final discussion in 4/17 meeting https://gridworks.org/initiatives/rule-21-working-group-3/

16. Final report schedule https://gridworks.org/initiatives/rule-21-working-group-3/

17. Final report process https://gridworks.org/initiatives/rule-21-working-group-3/