Limited Generation Profiles Workshop #2 7:56 am - 4:11 pm Tuesday, November 29, 2022 | (UTC-08:00) Pacific Time (US & Canada) pht2 Eamon Hoffman ET gary holdsworth sdg&e Prasanth Gopalakrishnan ASE/Kalkitech De Ocampo, Jorge Eva Wang TotalEnergies Saxton, Patrick Abtin Mehrshahi Antonio Nunez Melcher, Jerry John Berdner Enphase Roni Mejia - SCE Kimberley Chong SDG&E Sky Stanfield Stephan Barsun - Verdant Associates Francisco Hernandez (Consultant) @CPUC Saeed Jazebi 2094****59 Denise Chan PG&E Jason Bobruk Mandee Figueroa SCE Abe F SDG&E Yu Lister Alex Mwaura PG&E Stephan Barsun Tseng, Wayne Sherise Cory Mitsui Regnier, Justin David Schiada Christian Eder, Fronius USA Steve Sherr Jan Strack phuoc Josh McDonald SCE Adrianna Magallanes-Chacon SDG&E Will Wood Ralph Troute CALSTART Frances Cleveland Matt Belden SDGE Iman Matt Gonzales Sheikh Hassan Jacob Willman (Consultant) Frank Goodman Jordan Aliaga-Caro, Jose Yi Li SDG&E Dan Bedell - SDGE Dan Bedell Brian Lydic - IREC Roger Salas SCE Webb, Tyler Christian Eder Fardin Sarraf Wilfredo Guevara - SDG&E Belinda Vivas SCE 2153****14 Younes, Amin Albert Tapia WEBVTT 1 Aliaga-Caro, Jose 00:18:05.824 --> 00:18:20.554 Thank you everybody who has joined so far, um, workshop officially will commence at 90 a. M, so, uh, this time, uh, feel free to get yourself your water coffee, whatever unique. 2 Aliaga-Caro, Jose 00:18:22.894 --> 00:18:28.054 We're just giving enough time, uh, you know, we're giving people enough time to join the workshop. 3 Younes, Amin 00:18:42.484 --> 00:19:03.574 jose since uh since i'm here and you're here and i don't know if you're doing anything else but i'm curious how people get on the agenda for these types of workshops particularly i know that we have the e fifty two well might have the fifty two thirty workshops coming up at some point and if i wanted to talk at that provide a presentation how would i go 4 Younes, Amin 00:19:03.610 --> 00:19:04.385 About doing that. 5 Aliaga-Caro, Jose 00:19:04.805 --> 00:19:08.225 I will be solicit 15. 6 Aliaga-Caro, Jose 00:19:09.814 --> 00:19:25.714 Agenda topics, uh, and, uh, if, uh, basically we'll follow the same procedure as we did for this workshop, we will, uh, for 5,230, we will announce the workshop. 7 Aliaga-Caro, Jose 00:19:27.784 --> 00:19:47.434 And, uh, I mean, I, I believe you're on the service list. Yeah. So we'll announce the workshop. And, uh, I believe I, uh, also, uh, in the announcement, I, uh, circulated a form for people in particular that 1, to participate in the workshop. 8 Aliaga-Caro, Jose 00:19:49.685 --> 00:19:54.035 To fill out, including any agenda topics that they wanted to cover. 9 Regnier, Justin 00:19:55.985 --> 00:20:09.875 I think we're not actually using the service lists. There's a lot of legal minutia here, but the resolution itself is kind of its own many proceeding with its own record. And because. 10 Regnier, Justin 00:20:09.904 --> 00:20:29.434 It's adjacent too, but not involved in the proceeding itself. I don't think we notice via the service list, or we have done as noticed via the smarter murder working group. I mean, there's a, it's not exactly a 1 to 1 correspondence between people. That are on there. And on the service list, but it's pretty close. 11 Aliaga-Caro, Jose 00:20:29.824 --> 00:20:31.024 Yeah, well, uh, just. 12 Aliaga-Caro, Jose 00:20:31.174 --> 00:20:52.174 Uh, we did notice the initial, uh, kickoff workshop in the service list. So we, as you said, you know, as you said, not everybody in the smart, and we're working group is on the server list or vice versa. So, we did announce that initial kickoff into the service. 13 Aliaga-Caro, Jose 00:20:52.179 --> 00:21:02.674 787 07, so we'll be following that same procedure for the resolution. e5230 workshops. 14 Aliaga-Caro, Jose 00:21:06.305 --> 00:21:25.985 And then, you know, if I will be circulating, like I said, a form for participant for people that are interested in attending the workshop and participating, or even just listen only and then following workshops, basically, you know. 15 Aliaga-Caro, Jose 00:21:26.224 --> 00:21:40.744 Uh, invites are distributed to that list of respondents that way. We don't buy the service list with, you know, invites that people may not be interested in attending. 16 Aliaga-Caro, Jose 00:21:42.964 --> 00:21:49.924 So, and in that form, I mean, there is a section to submit topics for discussion. 17 Younes, Amin 00:21:52.834 --> 00:21:55.954 Got it, thank you. I'll look look for that when that comes out. 18 Aliaga-Caro, Jose 00:21:56.404 --> 00:21:57.274 Okay, yeah. 19 Aliaga-Caro, Jose 00:38:29.675 --> 00:38:36.785 Hey, we're 5 minutes before the hour. Uh, I'd like to check whether we have the, uh, presenters from the utilities here. 20 Aliaga-Caro, Jose 00:38:38.735 --> 00:38:41.045 Uh, do we have, uh, on the call. 21 Aliaga-Caro, Jose 00:38:56.074 --> 00:39:01.384 Uh, anybody from on the call, I believe you should be able to unmute yourself. 22 Aliaga-Caro, Jose 00:39:20.704 --> 00:39:27.304 All right, so let me do a, uh, test here. Can anybody unmute themselves and speak. 23 Yi Li SDG&E 00:39:28.984 --> 00:39:30.544 We'll say this is. 24 Yi Li SDG&E 00:39:31.719 --> 00:39:32.254 You hear me. 25 Aliaga-Caro, Jose 00:39:33.364 --> 00:39:39.874 Yes, thank you. I was afraid people were not able to unmute the upstairs. Right? Okay. 26 Yi Li SDG&E 00:39:40.414 --> 00:39:46.204 Yeah, I I see, Alex, I, he just mute it and maybe just grabbing a drink or something. 27 Aliaga-Caro, Jose 00:39:46.384 --> 00:39:52.864 Okay, yeah, yeah, I saw it, but like I said, I need a confirmation that someone could. 28 Aliaga-Caro, Jose 00:39:52.895 --> 00:39:54.785 Unmute themselves and speak. 29 Aliaga-Caro, Jose 00:39:57.424 --> 00:39:57.874 Thank you. 30 Aliaga-Caro, Jose 00:40:00.725 --> 00:40:09.095 So, okay, so while we wait a confirmed there on the call and do we have Edison on the call? 31 Roni Mejia - SCE 00:40:10.745 --> 00:40:13.025 Good morning who said this is right here. 32 Aliaga-Caro, Jose 00:40:13.355 --> 00:40:18.485 Ah, thank you Ronnie. Good to, uh, have you on all right. 33 Aliaga-Caro, Jose 00:40:21.424 --> 00:40:28.774 And, uh, I know I Rick is presenting later today, so I just want to make sure they're on the call right now. 34 Aliaga-Caro, Jose 00:40:32.794 --> 00:40:38.584 Do not see Iraq yet, but it's still 5 minutes to the hour. 35 Alex Mwaura PG&E 00:40:40.864 --> 00:40:41.854 Alex from PG E. 36 Aliaga-Caro, Jose 00:40:42.334 --> 00:40:47.524 Thank you, Alex, thank you for confirming. You're on the call. Perfect. 37 Aliaga-Caro, Jose 00:41:07.324 --> 00:41:12.844 So, uh, if you could bring up the, uh, energy division slides. 38 Aliaga-Caro, Jose 00:41:16.684 --> 00:41:25.444 Ah, thank you. Perfect. And we'll just keep it there until we officially start in about 4 minutes. 39 Aliaga-Caro, Jose 00:45:05.704 --> 00:45:10.144 Okay, well Thank you everybody for joining today's call. 40 Aliaga-Caro, Jose 00:45:11.734 --> 00:45:21.694 The 2nd, uh, limited generation profile workshop ordered per resolution E50 to 11 for him. Next slide. Please. 41 Aliaga-Caro, Jose 00:45:24.184 --> 00:45:37.414 So, some, uh, workshop and logistics safety reminder, of course, make note of your surroundings and roots and reach out. If you need help, either during the call or to an attendee. 42 Aliaga-Caro, Jose 00:45:38.614 --> 00:45:59.464 Just a reminder also that this meeting is being recorded a workshop recording and materials are posted at the CPC rule 21 limited generation profiles web page. I will go over that later on. If you were forwarded to invite and did not receive it directly. 43 Aliaga-Caro, Jose 00:45:59.494 --> 00:46:09.334 From energy division and would like to be added to the workshop distribution list. Please email Mary at Mary dot at CPC. That's. 44 Aliaga-Caro, Jose 00:46:09.339 --> 00:46:27.874 Dot Gov, workshop participants are encouraged to ask questions during the presentations we do have dedicated Q and a time slots for each presentation. But, you know, if there's something a dire feel free to raise your hand. 45 Aliaga-Caro, Jose 00:46:30.154 --> 00:46:50.224 Comments on the on the chat window or also. Welcome. But if you do have a question, I do encourage you to speak up has sometimes it is difficult to both follow the chat window and attentively. Listen in to what this presenters are speaking. 46 Aliaga-Caro, Jose 00:46:51.544 --> 00:46:52.114 Um. 47 Aliaga-Caro, Jose 00:46:53.584 --> 00:47:14.134 Please, uh, Additionally, keep yourself muted were not speaking and do not put the call on hold. You are able to unmute yourself by pressing that, uh, microphone button. If you come by phone, uh, use the mute button on your handset and unmute yourself to speak. 48 Aliaga-Caro, Jose 00:47:14.944 --> 00:47:19.114 Uh, if needed by the host press star 6 to unmute. 49 Aliaga-Caro, Jose 00:47:21.274 --> 00:47:22.924 Any questions so far. 50 Aliaga-Caro, Jose 00:47:26.794 --> 00:47:29.374 Okay, hearing now next slide. 51 Aliaga-Caro, Jose 00:47:31.445 --> 00:47:49.985 So, um, here is where you'll be able to find, uh, all the, uh, workshop materials and recordings uh, the 1st, uh, the works, the 1st workshop is already posted, uh, we will be posting it probably, uh, within a couple of days. 52 Aliaga-Caro, Jose 00:47:52.444 --> 00:47:57.964 So, uh, this workshop should probably be available by probably Thursday or Friday this week. 53 Aliaga-Caro, Jose 00:48:00.244 --> 00:48:01.084 Next slide. 54 Aliaga-Caro, Jose 00:48:04.655 --> 00:48:17.165 So, uh, today's agenda, uh, we're starting on with an introduction, uh, then we are moving on to, uh, the utilities, uh, presentations, um. 55 Aliaga-Caro, Jose 00:48:26.314 --> 00:48:45.844 Yeah, uh, so that covers items 1 and 2 uh, we'll be taking a short break around 1145 and then we'll continue the utilities presentation and then we'll be taking in our lap break around noon and. 56 Aliaga-Caro, Jose 00:48:45.849 --> 00:48:56.104 And the plan is that will also be presenting, uh, everybody should have received updated slides this morning. 57 Aliaga-Caro, Jose 00:48:57.814 --> 00:49:18.274 Uh, again, uh, I'd like to stress this as a tentative agenda based on the 7th on the November 7th workshop. Uh, you know, there were a lot of, uh, there was a lot of dynamic interactions. So we did go over. So, even though we are scheduled to terminate, uh, to end the. 58 Aliaga-Caro, Jose 00:49:18.304 --> 00:49:30.634 Shop at 330 today it may go up until probably 430. so we have allowed some buffer time next slide. Please. 59 Aliaga-Caro, Jose 00:49:34.354 --> 00:49:53.464 Uh, so, again, just a reminder, uh, workshop calls to arrive at some sort of consensus proposal for the specifics of whether, and how reductions to the customer's limited generation profile are determined. Uh, just as a reminder these were 15 and 16. 60 Aliaga-Caro, Jose 00:49:53.554 --> 00:49:56.584 From a decision in 2903 5. 61 Aliaga-Caro, Jose 00:49:57.994 --> 00:50:18.784 The utilities presentations contain their proposals and should not be taking has final solutions. Uh, we, uh, reiterate that stakeholder. So welcome to propose different processes. And we are encouraging that, uh, this, uh, workshop. 62 Aliaga-Caro, Jose 00:50:18.909 --> 00:50:38.944 Has, uh, means to discuss every available solution and again, just a reminder when it comes to discussions of the integration capacity analysis. Boot 21 is an end user. So changes to the are out of scope. 63 Aliaga-Caro, Jose 00:50:40.324 --> 00:51:01.204 So, any discussions regarding the icaay should center on how it is right now, and not on changes to it that is under another proceeding. The Heidi proceeding next slide. 64 Aliaga-Caro, Jose 00:51:03.964 --> 00:51:20.794 Uh, this is just, uh, background material on, uh, ongoing paragraph, 16 and 15 from, uh, and I know 35 I will not go through with them through them. Uh, everybody should be already familiar with them. 65 Aliaga-Caro, Jose 00:51:22.384 --> 00:51:25.804 And let's see. 66 Aliaga-Caro, Jose 00:51:30.844 --> 00:51:47.074 And having said that, I think we are perfect, uh, right on time to start the utilities, uh, discussion. So, uh, if we could bring up the, uh, PDF file from the utilities, please. 67 Aliaga-Caro, Jose 00:51:58.324 --> 00:52:06.274 All right, so, uh, who will be, uh, speaking 1st for the utilities who will be driving the conversation. 68 Roni Mejia - SCE 00:52:06.964 --> 00:52:15.304 Good morning so, um, I'll be, uh, starting 1st and then I'll be handing it over to Alex, uh, from PG E. and then, uh. 69 Roni Mejia - SCE 00:52:16.115 --> 00:52:21.485 Then Alex will be handing it over to E from after that. 70 Aliaga-Caro, Jose 00:52:21.725 --> 00:52:33.635 Okay, thank you. Ronnie. Um, please let our ity specialist know when to proceed to the next slide. Uh, and I will let you take it away. 71 Roni Mejia - SCE 00:52:34.775 --> 00:52:36.725 Awesome. Thank you. Thank you very much. 72 Roni Mejia - SCE 00:52:38.404 --> 00:52:46.414 Can you please go to the next slide so, uh, just briefly good morning everybody, uh, my name is running here from a. 73 Roni Mejia - SCE 00:52:46.984 --> 00:53:08.074 And, um, just a quick overview of the agenda that we plan to cover during our presentation, uh, brief overview of, uh, 15 and 16 and re resolution 5,211, which, I think, um, Jose has done a really good job at already touching onto. We're also. 74 Roni Mejia - SCE 00:53:08.109 --> 00:53:29.254 Talk about some of the, uh, the issues that are not in scope for 5,211, uh, some of the items that are included as part of 1930 or part of phase 2, and then we're going to dive into the topics, uh, that, uh, from the previous workshop. 75 Roni Mejia - SCE 00:53:29.284 --> 00:53:50.374 That either, we had a, uh, extensive discussions around and to some extent we have, uh, some general consensus and then we're going to touch on topics, uh, where we don't have consensus. And we're gonna, uh, dive deeper into those topics. And then, uh, some additional areas where. 76 Roni Mejia - SCE 00:53:50.435 --> 00:53:52.385 Additional discussions are. 77 Roni Mejia - SCE 00:53:54.664 --> 00:53:56.884 Are warranted so. 78 Aliaga-Caro, Jose 00:53:58.114 --> 00:54:07.774 Ronnie, uh, and before we continue, could we ask anybody speaking to turn your cameras on? And that was my bad. I should have started that off. 79 Roni Mejia - SCE 00:54:13.054 --> 00:54:15.514 Can everybody see my camera. 80 Roger Salas SCE 00:54:18.904 --> 00:54:19.204 Yes. 81 Aliaga-Caro, Jose 00:54:19.264 --> 00:54:19.924 Yes. 82 Roni Mejia - SCE 00:54:22.715 --> 00:54:27.575 All right cool. So so moving on to the next slide um, okay. 83 Roni Mejia - SCE 00:54:29.914 --> 00:54:51.004 All right, so so this 1 is just a level set, uh, slide. And, uh, as I said, I would say, has already mainly covered a lot of these elements here. And, uh, the, the, I wanna just briefly summarize that, uh, the, the objective of. 84 Roni Mejia - SCE 00:54:51.064 --> 00:55:12.184 Uh, of us, trying to comply with team is to define the circumstances, uh, that would lead to a reduction to an project. And then the process, uh, for determining that level of reduction in a nutshell. And I think, uh, as part of the. 85 Roni Mejia - SCE 00:55:12.485 --> 00:55:33.335 Workshop number 1, we, we dove into those, uh, subject matters and we will be furthering, uh, you know, those discussions as we go through the slides. And, um, and of course, uh, we are going to be, you know, talking about, uh, in the previous workshop. 86 Roni Mejia - SCE 00:55:33.454 --> 00:55:54.334 Talk about our business as usual practices. Um, and, uh, so highlighting that here and some of the future conditions that may arise, which we'll also define in the previous workshop and we're also going to be touching on it in this in this within our slides today. So. 87 Roni Mejia - SCE 00:55:54.545 --> 00:56:03.695 Have a more opportunities for discussions around those topics so if we can move on to the next slide. Okay. 88 Roni Mejia - SCE 00:56:06.484 --> 00:56:26.884 And as indicated in the agenda, why don't you highlight some of the, uh, items here that, uh, uh, the, uh, that are not in scope of resolution 5,211 uh, but other part of 50 to 30 or part of phase 2 and, uh, the bullet items, uh, that. 89 Roni Mejia - SCE 00:56:27.154 --> 00:56:48.004 Identified, uh, the fall under those, uh, either of those buckets it's either, uh, it's the format of the schedule, uh, for the ltp profiles the quarterly reporting aspect of it, uh, the export versus generation nameplate and then the cost impacts, uh, to address. 90 Roni Mejia - SCE 00:56:48.069 --> 00:57:00.934 Upgrades, which are part of phase 2. so what are the kind of summarize, summarize those areas? So that at least that we can, uh, stay on topic with regards to resolution 2011. 91 Aliaga-Caro, Jose 00:57:02.794 --> 00:57:09.184 So, uh, lo, Ronnie, um, before we continue, I did have a question. I know I know this is, uh. 92 Aliaga-Caro, Jose 00:57:09.244 --> 00:57:15.034 Jumping ahead, but could we talk about the quarterly reporting? Um. 93 Aliaga-Caro, Jose 00:57:16.294 --> 00:57:34.324 I just wanted to, uh, get that clear a little, uh, resolution, uh, 5,211 did allow, you know, preliminary discussions. And, like I said, this probably requires jumping a little bit ahead to slide. 94 Roni Mejia - SCE 00:57:34.744 --> 00:57:35.524 18. 95 Aliaga-Caro, Jose 00:57:36.154 --> 00:57:37.414 To slide 18. 96 Aliaga-Caro, Jose 00:57:37.534 --> 00:57:38.524 And so. 97 Roni Mejia - SCE 00:57:39.364 --> 00:57:48.004 Yeah, we, we did recognize that um, and so that's why we made sure to include it as part of, uh, the discussion. So. 98 Aliaga-Caro, Jose 00:57:48.544 --> 00:57:52.384 Yeah, could we, uh, jump to slide 18 and cover that now? Please. 99 Roni Mejia - SCE 00:57:52.714 --> 00:57:53.164 Sure. 100 Aliaga-Caro, Jose 00:57:54.424 --> 00:57:58.834 Just so, uh, yeah. Oh, go. 101 Roni Mejia - SCE 00:58:00.154 --> 00:58:15.484 Yeah, so so, I think, uh, this was a, you know, a topic of discussion that came up during the, uh, the workshop, uh, at the last workshop. And I think, uh, there's a few. I think folks who made mention of, uh, that in. 102 Roni Mejia - SCE 00:58:15.635 --> 00:58:36.635 You know, the, the asking for the quarterly report, uh, from the, uh, from the customers, um, that perhaps do not want or do, uh, do not have, um, uh, what is it, a telemetry and that perhaps we could leverage our data. 103 Roni Mejia - SCE 00:58:36.664 --> 00:58:57.634 To, uh, to monitor, or extract the information so that we can do, uh, kind of like a QA if you will our QC, uh, to make sure that the, uh, the profiles that have been defined in the application process are actually being followed. And, uh, we went back. 104 Roni Mejia - SCE 00:58:58.264 --> 00:59:14.704 Uh, each of the utilities to see whether or not, uh, our has the capability to do that and, um, based on our, our discussions internally, uh, we actually, uh, discussions that with our, uh. 105 Roni Mejia - SCE 00:59:14.734 --> 00:59:35.854 Experts we did find that we are actually have the ability to, uh, extract the information, uh, from, uh, my, uh, data to be able to monitor the, uh, those profiles. And, uh, and so, for for this, uh, specific. 106 Roni Mejia - SCE 00:59:35.884 --> 00:59:57.004 Reporting, uh, the, the are are comfortable with not requiring this, uh, this reporting anymore, because we will be leveraging, uh, the data. And, uh, and just to clarify here, this is for projects under would name play, uh, under 1 megawatt because. 107 Roni Mejia - SCE 00:59:57.274 --> 01:00:05.674 Above 1 megawatt telemetry, so ready required, uh, per rule 21. so that was not the subsequent question. So. 108 Roni Mejia - SCE 01:00:09.695 --> 01:00:12.815 So, any thoughts there, any questions for for us. 109 Aliaga-Caro, Jose 01:00:14.285 --> 01:00:22.325 Okay, uh, thank you Ronnie for that. So it looks like we have actually resolved a. 110 Aliaga-Caro, Jose 01:00:24.905 --> 01:00:30.365 1 of the issues from, uh, that was teed up for resolution 5,230, which. 111 Roni Mejia - SCE 01:00:30.365 --> 01:00:30.575 Was. 112 Roni Mejia - SCE 01:00:34.024 --> 01:00:37.054 Yeah, no, I, I think this is a perfect way to start. 113 Aliaga-Caro, Jose 01:00:39.514 --> 01:00:59.704 Yeah, all right there may be some terra language that needs to be developed, but I think we're, you know, I think we're now at a very good place that, you know, quarter we're reporting will not be required and, you know, data will be used for projects into 1 megawatt. 114 Aliaga-Caro, Jose 01:01:00.484 --> 01:01:11.344 And for, uh, project over 1 megawatt telemetry, because it's already required, anyways will be used. 115 Roni Mejia - SCE 01:01:11.944 --> 01:01:12.874 That's correct. 116 Aliaga-Caro, Jose 01:01:14.194 --> 01:01:16.444 So, I think Brian, did you have a, a. 117 Brian Lydic - IREC 01:01:19.624 --> 01:01:21.604 Hi, just wanted to check. 118 Brian Lydic - IREC 01:01:21.844 --> 01:01:38.614 With the systems that do have telemetry, I don't know that they're already monitoring export values, export power. And so would that be a change to your handbook that you need to make to require that of those systems? 119 Roni Mejia - SCE 01:01:44.165 --> 01:01:45.425 I, I'm not sure. 120 Roger Salas SCE 01:01:45.995 --> 01:02:01.085 I can answer that. I mean, that's that's a good point. And, and it is likely that you're not able to monitor, uh, the export with the telemetry as as correctly is, uh, then we may just have to. 121 Roger Salas SCE 01:02:01.114 --> 01:02:03.274 You say, my, even for the larger systems. 122 Brian Lydic - IREC 01:02:04.084 --> 01:02:04.384 Hmm. 123 Roger Salas SCE 01:02:05.584 --> 01:02:09.514 Let's say there are not really sure really impact. Uh, this is the change. 124 Brian Lydic - IREC 01:02:10.684 --> 01:02:11.314 Okay, thanks. 125 Alex Mwaura PG&E 01:02:13.715 --> 01:02:19.505 Uh, this is Alex from PG. E. so, Brian, I just want to make sure I understand your question. Are you saying that. 126 Alex Mwaura PG&E 01:02:21.094 --> 01:02:27.544 Are you asking if the utilities are willing to use in lieu of telemetry? Is that your customer. 127 Brian Lydic - IREC 01:02:29.704 --> 01:02:50.404 That wasn't my question, but that might be a solution to it. So, I guess my question is, are you already requiring export data through the telemetry requirements and if not, you know, how would you go about getting? Would you, would you be changing your telemetry requirements to require. 128 Brian Lydic - IREC 01:02:52.025 --> 01:02:55.775 Or, yeah, like Roger said, maybe you could use for those cases as well. 129 Alex Mwaura PG&E 01:02:56.525 --> 01:03:11.585 Yeah, so I think based on this slide for projects that are over 1, Meg, the list of PG need, the telemetry requirements would not change. So, you know, at this time we have a low cost telemetry that has. 130 Alex Mwaura PG&E 01:03:11.644 --> 01:03:21.334 A potential to measure output at the generation into connection and also at the T. um, but the. 131 Brian Lydic - IREC 01:03:21.334 --> 01:03:21.484 Is. 132 Alex Mwaura PG&E 01:03:21.484 --> 01:03:32.134 Not to replace telemetry with because 1 of the challenges is is right now the system that we use 1st of all, not a real time. 133 Alex Mwaura PG&E 01:03:32.765 --> 01:03:52.385 Secondly, we have to go fix that data versus where telemetry and, uh, solutions typically come through the scanner system and, uh, you know, readily available to operations and, uh, and distribution engineers. So, I list for PG E right now we're not going to replace telemetry requirements with solutions. 134 Brian Lydic - IREC 01:03:53.585 --> 01:03:53.885 Got. 135 Brian Lydic - IREC 01:03:53.974 --> 01:03:58.354 Yeah, so you've already got that capability through the telemetry. That's that's good to hear. 136 Alex Mwaura PG&E 01:03:58.474 --> 01:03:59.584 Yes, yes. 137 Roger Salas SCE 01:04:00.154 --> 01:04:15.034 And just to make it abundantly clear for, I see where we're not proposing to change any of the telemetry requirements. All I was saying, is that if for those systems, right what, if we are not able to make sure the BCC. 138 Roger Salas SCE 01:04:15.039 --> 01:04:17.854 As well as the, uh, as the. 139 Roger Salas SCE 01:04:18.124 --> 01:04:24.904 And PG need us, then we will complement the use. We will complain with the use. 140 Roger Salas SCE 01:04:25.925 --> 01:04:31.835 With how the adding additional requirements, but at the limit requirements requirements will remain the same. 141 Roni Mejia - SCE 01:04:35.645 --> 01:04:36.635 Thank you Roger. 142 Frances Cleveland 01:04:42.034 --> 01:05:00.154 Maybe just 1 additional, uh, question on that, which is, um, how, uh, what's the latency for getting the, um, data, uh, available. 143 Frances Cleveland 01:05:00.515 --> 01:05:06.335 Um, our minutes day, hours days, what sort of time frame are we talking about? 144 Roger Salas SCE 01:05:08.315 --> 01:05:21.305 I see it's 1 day late, uh, minimum. So that's my understanding. So so again, that's why we can probably use it for verification performance, uh, for an project, but we could not use it for real. 145 Roger Salas SCE 01:05:21.334 --> 01:05:24.034 Time operations, and that's why that the limit requirements for me to say. 146 Frances Cleveland 01:05:26.464 --> 01:05:26.854 Thank you. 147 Roni Mejia - SCE 01:05:37.744 --> 01:05:40.174 So, let's move on, uh, to the, uh. 148 Roni Mejia - SCE 01:05:44.284 --> 01:05:50.734 Slide 8 slide 6. I'm sorry. 149 Aliaga-Caro, Jose 01:05:52.774 --> 01:05:53.914 I think slide 5. 150 Roni Mejia - SCE 01:05:58.324 --> 01:05:58.774 Yeah. 151 Aliaga-Caro, Jose 01:05:59.794 --> 01:06:00.874 Oh, no sorry. 152 Roni Mejia - SCE 01:06:00.904 --> 01:06:17.524 Yes, yeah slide 5 Thank you. You heard me? Yeah, so so this is, uh, this is, uh, our, uh, our queue, uh, for starting on the, uh, on the subjects, uh, following up on the November. 153 Roni Mejia - SCE 01:06:17.914 --> 01:06:38.854 Workshop, so, let's go ahead and, um, dive in into the next slide. So, we, we created this slide because, uh, we, we wanted to make sure that, uh, 1, we wanted to get some feedback from from the stakeholders here and, uh, based on our understanding of the last, uh. 154 Roni Mejia - SCE 01:06:38.914 --> 01:07:00.004 Shop, uh, there was a lot of discussions about, uh, how an unforeseen reduction of load could potentially impact the, uh, conditions of the grid. Thereby causing a reduction in the hosting capacity. Thereby potentially impacting the, uh, profile of. 155 Roni Mejia - SCE 01:07:00.009 --> 01:07:21.154 Of the customer we also touched on, uh, the, um, the, that as we, because we don't have these types of projects currently, uh, interconnected into our system. Uh, we don't really, really have the, uh, real time. 156 Roni Mejia - SCE 01:07:21.185 --> 01:07:42.305 Operational experience or historical experience, and operating these types of projects and as we, uh, will be interconnecting, this type of project will be gaining a lot of experience and better and having better data right. To assess any impacts of, of, uh, that maybe this system conditions. 157 Roni Mejia - SCE 01:07:42.334 --> 01:07:46.024 They have, uh, on the projects or not. 158 Roni Mejia - SCE 01:07:48.364 --> 01:08:08.854 And, uh, another bullet item that, uh, that was discussed and brought up. And I think, uh, Brian, I think Brad may have brought this 1 up. And this had to do with, uh, clarification on, uh, when we will be reducing if, uh, if a retroactive reduction of an project will occur. 159 Roni Mejia - SCE 01:08:09.184 --> 01:08:30.094 Um, this will not happen from the, uh, nameplate rating of the project. But rather from the profile that had originally been, uh, I guess, uh, agreed upon, uh, during the, our inner connection, uh, the initial interconnection, uh, process. 160 Roni Mejia - SCE 01:08:30.454 --> 01:08:51.394 So wanted to kind of highlight this item here, because we thought it's, uh, it's important. Um, but with that, I'll go ahead and maybe open it up for feedback to see, uh, the, this does everyone agree that this, uh, at least in, in, uh, I guess, uh, in general that we. 161 Roni Mejia - SCE 01:08:51.514 --> 01:08:59.314 We understand that this these are true or or you think that maybe we misrepresented what what we have here in the slides. 162 Sky Stanfield 01:09:03.845 --> 01:09:18.154 Good morning. This is sky. I have just I wonder if you could explain the last Pro, the last bullet um, I don't necessarily disagree with that. I guess I'm trying to understand what I don't remember. What conversation led to that 1 or what what that means. Exactly. 163 Roni Mejia - SCE 01:09:18.875 --> 01:09:23.825 Yes, I, if you remember, I think, uh, the I had a, what I was this. 164 Roni Mejia - SCE 01:09:23.974 --> 01:09:44.133 Playing a, uh, a, a, a slide, which had the, uh, uh, the a graph of the profile and, uh, it just so happened that in this specific graph. The nameplate rating of the of the generator was. 165 Roni Mejia - SCE 01:09:44.979 --> 01:10:06.034 1 was the initial profile, right? Because it just so happened that the, uh, the ACA, uh, the ACA values were right, right above that name nameplate rating and I think it was 2 megawatts a recall. And so when we were reducing where we were reducing the profile, that specific generator, it was being done from the. 166 Roni Mejia - SCE 01:10:06.215 --> 01:10:27.275 Rating, but because of the, it just so happened that that's how the example was there was some discussion about that. And then we said, well, think about it, if it wasn't the 3 megawatt nameplate rating generator, then the profile would have been, like, 2.5 or something like that. And I think that's where the discussion, uh, uh, kind of. 167 Roni Mejia - SCE 01:10:27.304 --> 01:10:27.754 From. 168 Roni Mejia - SCE 01:10:30.125 --> 01:10:36.485 I think the, the example maybe was, uh, could have been better that, uh, discussion. 169 Roni Mejia - SCE 01:10:40.024 --> 01:10:44.134 Yeah, I don't have a graph otherwise I would display it, but, uh. 170 Sky Stanfield 01:10:45.814 --> 01:10:48.664 Okay, thanks. 171 Roni Mejia - SCE 01:10:57.694 --> 01:10:58.774 Any other questions. 172 Roni Mejia - SCE 01:11:08.405 --> 01:11:16.325 All right, so I have no questions. So, um, I'll move on to the next slide and I'll go ahead and hand it over to Alex. 173 Alex Mwaura PG&E 01:11:22.774 --> 01:11:24.424 Hey, good morning. Everyone can you hear me? Okay. 174 Sky Stanfield 01:11:30.094 --> 01:11:30.334 I. 175 Roni Mejia - SCE 01:11:30.334 --> 01:11:31.204 You can hear you Alex. 176 Alex Mwaura PG&E 01:11:31.234 --> 01:11:47.644 Oh, perfect. All right, my name is Alex. I Jenny, and I'll be going over some slides so 1st of all I'd like to apologize in advance. I am having some bandwidth and camera issues, so I'm not going to be able to turn on my camera today. I'll try to resolve those. 177 Alex Mwaura PG&E 01:11:47.674 --> 01:12:08.794 For the next workshop and, uh, hopefully be uncovered then. So I'll be going over some non consensus topics. The 1st 1 has to do with this issue of reduction in level due to subs reduction. So it is the I use contention that the CPC decision does not. 178 Alex Mwaura PG&E 01:12:08.915 --> 01:12:29.915 Allow us to charge other customers on the distribution system. So, lots of ability for customers to be able to export about the level. Um, we also feel like the decision did allow the. I used to. 179 Alex Mwaura PG&E 01:12:29.974 --> 01:12:51.094 Be able to reduce the export value to the value to ensure safety and reliability without having to do great updates. Uh, although the decision allows for customers to provide a profile that, you know, based on the value. 180 Alex Mwaura PG&E 01:12:51.125 --> 01:12:55.955 We do not feel like it requires the I used to guarantee that profile. 181 Alex Mwaura PG&E 01:12:59.524 --> 01:13:03.634 We understand that the stakeholders view is that. 182 Alex Mwaura PG&E 01:13:05.404 --> 01:13:25.984 They should be a guarantee, but we believe that this is a non starter for the, the 2nd, non consistent consensus item has to do with the issue of 24 versus to 88 values. Um, we still I still feel like the decision is pretty clear in in. 183 Alex Mwaura PG&E 01:13:26.375 --> 01:13:47.465 It allows for all monthly values. So, you know, our intention is that customers will be able to go to the ACA maps and download the profiles and be able to generate a 1212, different value profiles. So, basically, 1 value per month, 12 values for the whole year. And provide that as part of the. 184 Alex Mwaura PG&E 01:13:47.499 --> 01:14:08.434 Project application, the card item has to do with the risk of cost of upgrades to return an project that has been reduced to the original approval limits. So the, I use, uh, views that customers are getting. 185 Alex Mwaura PG&E 01:14:08.854 --> 01:14:29.674 Commercial benefit of increased generation, when, you know, typically they will be limited to an value, but obviously you're able to generate at a higher values when the system is normal and therefore that, you know, they should hold the risk of the cost of upgrades. Although the limit to the value. 186 Alex Mwaura PG&E 01:14:32.645 --> 01:14:50.405 And 9 hours, stakeholders, obviously view that I use subsequently already the risk to support California energy goals. So I'll pause here for these non consensus items because I believe probably will have some discussion. I see. I mean, has his hand up. So. 187 Younes, Amin 01:14:51.244 --> 01:15:11.614 Yeah, hi, I'm a I mean, units from Cal advocates, I don't think that this accurately represents, um, what I've been saying, or what I said in the last meeting. Um, I guess I'll start by reiterating that catalog because has no established positions on this particular, uh, on any of these topics. 188 Younes, Amin 01:15:12.605 --> 01:15:33.215 I don't think that we generally hold particularly this last view. Uh, I don't think that we typically support the position that, um, ratepayers should be the ones paying for California is, uh, energy goals beyond, beyond with absolutely. 189 Younes, Amin 01:15:33.484 --> 01:15:54.394 And I don't think that anything that I said previously would align with what's written here for the position of advocates. I anything that I said was was kind of based on an interpretation of what I was hearing from energy division that it seemed like it was a fairly high bar to treat. 190 Younes, Amin 01:15:54.544 --> 01:16:15.484 Separately, and that, you know, that perhaps we haven't shown that yet. So it was more of a kind of kind of analysis of what the direction that we were interpreting the commission wanted to take on this, rather than then then get the position, but just. 191 Younes, Amin 01:16:15.575 --> 01:16:36.665 Iterate we do not take that deposition stated there as to the middle bullet on the 288 values. I actually don't think that's accurate either. I mean, based on my reading, I tend to agree with the interpretation of how that's written. I don't think that that actually matters very much because it's going to be. 192 Younes, Amin 01:16:36.724 --> 01:16:57.844 The commission to decide what they meant when they were hopefully when they respond to the comments on resolution 50 to 30 where the, I believe specifically asked for clarification of that issue. My take, at this point would be that if we're moving forward. 193 Younes, Amin 01:16:57.875 --> 01:17:13.985 At this point we should be moving forward is if we don't know how many values it's going to be. So we should leave flexibility in terms of how things are, are, you know, particularly how that file is formatted. So we can accommodate 288 values. If if we get that direction from the commission, or that. 194 Younes, Amin 01:17:15.274 --> 01:17:35.914 Uh, and then on the 1st, 1, I also don't really agree that that is the position that that I kind of took that that is a position that I think I wreck my interpretation that that's what I Rick was saying, and, you know, I don't have any evidence to disagree with what Iraq is saying, but I don't have any evidence either. 195 Younes, Amin 01:17:35.944 --> 01:17:57.064 To to say that I Rick was right and I don't we certainly don't speak for for interconnection customers or for the, for the developers on that topic. I would actually on that, that 1st topic, whether no guarantee of LGB profiles is a non starter. I would actually. 196 Younes, Amin 01:17:57.069 --> 01:18:18.034 Interested in, seeing some, some evidence from Iraq on that. Because I mean, I guess my personal impression is that any developer is taking on some risk by interconnecting a project. I don't necessarily believe that. They're just going to walk away. If there's a small amount of risk. If they can quantify it. 197 Younes, Amin 01:18:18.484 --> 01:18:21.394 Um, but I certainly understand that. 198 Younes, Amin 01:18:22.449 --> 01:18:38.434 That risk is going to push some developers right away. So I would be interested in any kind of quantification or any evidence that, um, of the exact of how much of a non starter that would be for developers and that is, uh, that's it for me. Right now. 199 Alex Mwaura PG&E 01:18:43.324 --> 01:18:44.314 Thanks for your thoughts. 200 Alex Mwaura PG&E 01:18:46.594 --> 01:18:47.464 For Justin. 201 Regnier, Justin 01:18:49.865 --> 01:18:52.745 Let me defer to Scott. This is more for. 202 Sky Stanfield 01:18:55.115 --> 01:19:16.025 I was just going to say, Justin, I was just going to say that in the presentation that we are going to give later. I can talk a little bit more to that, or I'm happy to talk to it. Now. I think those are our fair points that we need to discuss a little bit more in terms of what position is and then also what we've, the outreach we've been trying to do. 203 Sky Stanfield 01:19:16.054 --> 01:19:37.174 To come up with a proposal, I think, when the thing that is maybe a little bit subtle here is, I don't think that it's fair to say that the developers and again, I don't speak for developers either, but based on the conversations we've been having, and our basic gut sense on. 204 Sky Stanfield 01:19:37.235 --> 01:19:57.635 What would be is not that they can't take on any risk. It's that they can't take on unlimited risk and undefined risk. And that's the part. I think that's more problematic. And then, as I'll discuss later today, I think defining what it's it's hard to get to. 205 Sky Stanfield 01:19:58.474 --> 01:20:19.474 No way to cap I'm just going to use that as a broad term the risk. So that's what's driving that position but I'll talk. We can talk more about those issues, but I want to be clear that nobody is saying that developers can't take on any risk. The problem is, is that it's the problem for both the ratepayers and the customers here, is that the risk is. 206 Sky Stanfield 01:20:19.534 --> 01:20:21.784 And we don't have right. 207 Alex Mwaura PG&E 01:20:34.745 --> 01:20:36.515 Just ended you still have something to say. 208 Regnier, Justin 01:20:37.265 --> 01:20:51.905 I did, I think a lot of what I had in mind was has already been said, but let me fill in the holes. And in terms of what I had in mind, um, just in terms of that 1st, sub decision is not grant the utilities, the authority. 209 Regnier, Justin 01:20:53.045 --> 01:21:13.055 I think that's technically accurate, but in our last discussions in workshop number 1, particularly gary's conversation, uh, I think we established that, um, while the decision doesn't, you know, grant, utilities, the authority common practice. 210 Regnier, Justin 01:21:13.059 --> 01:21:34.024 to for any upgrade that is required to allow facilities to operate within their interconnection agreement would already be done by our use and rate based that these things are widely seen as prudent investments eligible for inclusion in the rate base and we just haven't set up a separate customer class 211 Regnier, Justin 01:21:34.234 --> 01:21:55.324 Um, in terms of the elements that's underlined there in the next bullet without grid upgrades. I would note that without a grid upgrades refers to upgrades or updates at the time of interconnection. Um, again referencing the I use discussion. So, you know, there is no such thing as permanent. 212 Regnier, Justin 01:21:55.384 --> 01:22:15.574 in the grid which is fair and the interconnection process is a point in time so it doesn't permanently constrain the status of the grid from then forward so i would note that the without grid updates um my interpretation and those is the the staff and this is the one that matters um is that 213 Regnier, Justin 01:22:16.535 --> 01:22:37.625 That's to do with grid updates at the time of interconnection because we're, we're talking about an interconnection process. I Deco skies. Sky means discussion that the non stakeholders view no guarantee of LGB profiles is a non starter is a little off. Um. 214 Regnier, Justin 01:22:37.660 --> 01:22:58.625 Take away from Eva and others discussion, was that no guarantee of a reliable financial return as a non starter, but they're willing to share some of the risk. And as long as the curtailment or the risk is as well bounded and bankable they're okay with it. And finally, I would just say that our last. 215 Regnier, Justin 01:22:59.164 --> 01:23:15.454 Discussions discuss both risk and benefit so the, the point that a higher utilization of existing infrastructure benefits, all rate pairs was made by several parties and I think Warren's consideration on this discussion. So that's all. I got. 216 Aliaga-Caro, Jose 01:23:22.834 --> 01:23:24.814 And Gary, you had your hand. 217 gary holdsworth sdg&e 01:23:28.175 --> 01:23:33.275 Uh, yes, and unfortunately, my video is not working today either. But can you hear me. 218 Aliaga-Caro, Jose 01:23:36.904 --> 01:23:37.864 Yes, we can get. 219 gary holdsworth sdg&e 01:23:38.554 --> 01:23:56.614 Um, trying to unpack a little bit of justin's last riff there there was a lot in there that either agreed with, or didn't agree with. But you made a statement, Justin I'm trying to for the record. You made a statement that made it sound. 220 gary holdsworth sdg&e 01:23:56.645 --> 01:24:04.445 The use our funding, I'll upgrades and that's not the case. Maybe I misunderstood what you said. 221 gary holdsworth sdg&e 01:24:07.805 --> 01:24:15.245 Cause the classic structure is the developer funds, the upgrades for distribution upgrades. 222 Regnier, Justin 01:24:15.605 --> 01:24:15.935 Right. 223 gary holdsworth sdg&e 01:24:16.055 --> 01:24:22.145 Talking about them that has the exception to that rule now under megawatt. 224 Regnier, Justin 01:24:23.015 --> 01:24:27.125 Thank you for for, um, bringing that clarification that. 225 Regnier, Justin 01:24:28.025 --> 01:24:48.755 My my statement was in reference to future upgrades, so, if there are upgrades subsequent interconnection on this, this goes to what this guy was talking about, the 2 different classes of risk, and the last workshop, the risk prior to interconnection and the risk after connection that if something is required to be done to the grid to allow customers. 226 Regnier, Justin 01:24:48.789 --> 01:24:57.094 To continue to operate within the bounds of their interconnection agreement, or their terms of service on load but that's something that the use. 227 Regnier, Justin 01:24:57.484 --> 01:25:06.064 Um, business as usual process is to do within their planning process and then include into rate base. 228 gary holdsworth sdg&e 01:25:06.304 --> 01:25:10.144 Within the planning process yes. Okay. I now I'm following, you. 229 gary holdsworth sdg&e 01:25:11.375 --> 01:25:12.905 Thank you for that clarification. 230 Alex Mwaura PG&E 01:25:23.194 --> 01:25:42.364 all right very good discussion um looking forward to sky's presentation and uh also sounds really good that i mean or bullet number two is consistent with the interpretation as far as the twenty four of us as two hundred and eight move to the next slide 231 Alex Mwaura PG&E 01:25:42.425 --> 01:25:42.845 Please. 232 Alex Mwaura PG&E 01:25:47.704 --> 01:26:06.334 So, this slide is just going over a summary of workshop topics. I'll go over this quickly topic. Number 1, is what may be needed for 1st, iteration of the process and what data experience is needed for future iterations to refine the process and meet its. 233 Alex Mwaura PG&E 01:26:06.424 --> 01:26:27.184 Of taking advantage of available grid, capacity topic, number 2 will address output and when reductions occur topic, number 3, the discussion of how the process for topic number 2 topic number 4 goes over the output reductions circumstances. 234 Alex Mwaura PG&E 01:26:27.845 --> 01:26:43.295 Topic number 5 will address the format of the schedule to be submitted to allow a 288 hour profile. That's allowing flexibility for more granularity topic. Number 6. we'll go over the quarterly reporting, which is. 235 Alex Mwaura PG&E 01:26:44.585 --> 01:26:55.625 Number 7 increased risks with projects and topic number 8, export buses, generation, template next slide. Please. 236 Alex Mwaura PG&E 01:27:00.185 --> 01:27:18.215 So, for topic number 1, uh, improvements to based on experience, I think the item in red is might be a question that we got from Jose, or from the, from the commission what may be needed for 1st, iteration of process and. 237 Alex Mwaura PG&E 01:27:18.249 --> 01:27:39.364 Data slash preference is needed for future iterations to refine the process and meet its goal of taking advantage of available grid capacity. So, the 1st thing we think needs to happen is we need to modify the rule 21 tariffs in accordance with regulatory authorization. 238 Alex Mwaura PG&E 01:27:39.544 --> 01:27:59.914 Jp, as far as data that we need for the 1st iteration, we believe that a minimum of 2 to 3 years will be sufficient or required to collect data. We need to allow for 12 month profile for customers. This will be. 239 Alex Mwaura PG&E 01:28:00.549 --> 01:28:08.554 Find different value per month. We also need an ability to be able to monitor export. 240 Alex Mwaura PG&E 01:28:11.314 --> 01:28:31.564 The monitoring will be at the point of common coupling with the grid and this was already covered before I use we're asking for either a quality report from the customers or telemetry and this issue has been laid to rest, or are able to leverage the. 241 Alex Mwaura PG&E 01:28:31.569 --> 01:28:44.734 This team and will be able to monitor using the already available systems, except for projects that are over 1 megawatt, which require telemetry based on the current rule. 2100. go ahead. 242 Sky Stanfield 01:28:49.234 --> 01:28:51.484 Alex, go ahead. And are you finished with that? 243 Alex Mwaura PG&E 01:28:51.694 --> 01:28:53.194 No, I'm not finished, but I okay you want me to. 244 Sky Stanfield 01:28:53.824 --> 01:28:54.844 Yeah, finish that person. 245 Alex Mwaura PG&E 01:28:54.904 --> 01:28:56.974 Okay, sure. Okay. Let's go back to that slide. 246 Alex Mwaura PG&E 01:29:02.524 --> 01:29:19.684 So, the next item is, uh, we, we'd like to CPC to allow the I used to be able to reduce the export value to the value. If, uh, 17 reliability concerns warranty. 247 Alex Mwaura PG&E 01:29:20.919 --> 01:29:42.064 And then we also want the opportunity to understand impacts during this 1st iteration the projects when the system do during normal and abnormal operating conditions as far as data experience that we'll need, we profile reduction capabilities. And. 248 Alex Mwaura PG&E 01:29:42.094 --> 01:29:50.494 Triggering events conditions, we also would like to know whether or not approved for. Are. 249 Alex Mwaura PG&E 01:29:50.644 --> 01:30:11.494 With their profile, and then we would like to understand how many times projects to us to reduce below the approved profile. And then also the subset of that we want to know how quickly customers can implement reductions to the approved. Great. 250 Sky Stanfield 01:30:15.485 --> 01:30:28.205 Okay, thanks, Alex. Um, so I guess I'm a little bit when we 1st started talking about doing sort of an iteration or a test period, or whatever we're going to call it. 251 Sky Stanfield 01:30:30.965 --> 01:30:50.975 1st of all the commissions order doesn't doesn't lay out a test period. And when I'm not entirely clear, I understand, is why the utilities based on your position that the customer should bear all the liability, wants it or is proposing a test period at all like, what's the benefit of the test period? The all the additional data that you're asking for. 252 Sky Stanfield 01:30:51.395 --> 01:31:12.215 You're going to have that data. You just talked about that the, and the telemetry. I'm not really clear what you guys are seeking to get out of a test period based upon the, your position that either way the customer should bear all the responsibility for the low the profile reduction. 253 Alex Mwaura PG&E 01:31:15.424 --> 01:31:32.854 So, I'll go 1st, then I'll ask my colleagues from the other utilities to chime in. So, 1 of the main things that I think this test period will inform is this issue of 12 months, 12 monthly. I mean, 12 is 1 per month for 12 per year versus 208. 254 Alex Mwaura PG&E 01:31:33.514 --> 01:31:54.604 Uh, if you remember during the last presentation, our contention was that if we go to 288, it introduces this additional risk. And 1 of the things I would probably would line in this 2 to 3 years of collecting data is whether, you know, that is in fact a true thing or not. And we would allow customers to have more granularity rather than. 255 Alex Mwaura PG&E 01:31:54.634 --> 01:31:58.864 Have 12 monthly values, or if anybody else wants to add any other items. 256 Sky Stanfield 01:31:58.894 --> 01:32:15.394 Let me, let me just jump in. So Here's why I'm asking that. I, that makes some sense to me, although I may disagree about whether we should wait to do the 288 but I understand why why you're proposing that. But what the problem to me, and you may. 257 Sky Stanfield 01:32:16.205 --> 01:32:36.125 People may disagree with me, but I think that it's hard to, without somebody saying, they would do it to disagree with it on this. It the problem, with this proposal is that nobody's going to build an project. You're not going to get 2 to 3 years of data. 258 Sky Stanfield 01:32:37.145 --> 01:32:58.025 A customer has to bear the full responsibility. Now. I like I said, I could be wrong. We haven't heard from any developer that they'd say we'll take on this risk and we'll build a project. Um, but it seems to me, like, it would be a huge amount of time and effort for all of us to write all the terrible language and go ahead. When our expectation is that the risk is so high. 259 Sky Stanfield 01:32:58.059 --> 01:33:18.814 Customer can't do it. So, this idea of saying, well, we're going to do a 2 to 3 test period, but the conditions won't allow anybody to actually test is the problem to me. And I feel like the utility proposal is not helping us, get to that point. Where we have anything to test and I agree and fully supportive of. 260 Sky Stanfield 01:33:19.384 --> 01:33:25.624 A test for a variety of reasons, but we have to make the starting condition such that we have something to test. 261 Roger Salas SCE 01:33:28.354 --> 01:33:29.014 Don't respond to that. 262 Roger Salas SCE 01:33:30.545 --> 01:33:51.545 I mean, yeah, I think that's that in itself is a good data point sky. I mean, you're assuming that nobody is going to participate well, that in itself would be a good data to have, you know, whether or not as a reality or not. And again, I think this procedurally speaking, it appears that if you have some. 263 Roger Salas SCE 01:33:51.785 --> 01:34:05.465 Or no data as indicated, then there may be a lot a little bit easier to sort of make a modification to the rules. If you want to call it that. 264 Sky Stanfield 01:34:07.594 --> 01:34:20.134 Position change Roger, if you say, okay, so nobody you want to spend all of our time. We have hundreds of hours for all of us to write the tariff language with the idea that maybe nobody will do it. And then, where are we in 2 years. 265 Sky Stanfield 01:34:22.804 --> 01:34:24.184 Because we won't have any. 266 Roger Salas SCE 01:34:24.604 --> 01:34:28.504 We've done that before Skype I mean, you, you may recall the customer. 267 Sky Stanfield 01:34:29.164 --> 01:34:30.124 That's what I'm trying to avoid. 268 Roger Salas SCE 01:34:33.994 --> 01:34:53.464 Right. You know you're right. I mean, but again, I mean, I see there this or or or or sort of, you know, going full on the way we proposing as well. I mean, we, we really cannot take. We really cannot do anything what you're asking us to do, which is take that additional risk on behalf of our customers. 269 Roger Salas SCE 01:34:55.385 --> 01:35:07.685 So, it's either get some data, you know, hopefully we get something, make a decision on that and determine the risks or not. And, you know, maybe we have some information. Maybe we don't but at least it's something better than nothing. 270 Sky Stanfield 01:35:09.035 --> 01:35:14.825 But it's not it is nothing, right? So, I mean, we'll see. Well, I don't know until we talked about. 271 Sky Stanfield 01:35:14.854 --> 01:35:33.484 With our presentation, but I think we've laid it out here that what this proposal is risks. Absolutely nothing happening and no learning happening for 2 to 3 year, period and I could be wrong. I know that. But, but all odds suggests that I'm probably not too wrong at least here. 272 Frances Cleveland 01:35:35.764 --> 01:35:55.714 Well, I'd like to explore the opposite direction. So if you have this sort of test period, do you expect that after, let's say the 1st, you've got a 12 month profile, uh, that you will change that profile based on. 273 Frances Cleveland 01:35:55.744 --> 01:36:16.534 Your experience, including making it less stringent, making it relaxed and then a part of it, you've got more now, the monitoring capabilities using data not not real time and that's fine. 274 Frances Cleveland 01:36:17.165 --> 01:36:38.015 But would this allow you then to say well, the, for this month is X, but we recognize that we actually don't need to have it that stringent and we could relax it to something else during that. 275 Frances Cleveland 01:36:38.974 --> 01:36:59.104 Given the idea that you could bring it back to the regular, not the lowest 1, but the regular, uh, value. So, what I'm trying to do is look on the good side, the benefits side so that maybe we can balance the risk against. 276 Frances Cleveland 01:36:59.194 --> 01:37:20.284 Potential benefits, if you could improve the profile at the end of, say, 12 months and or even during that 12 months, improve the profile by just allowing the customer to export more based. 277 Frances Cleveland 01:37:20.344 --> 01:37:23.614 On your current findings and the data. 278 Roger Salas SCE 01:37:28.594 --> 01:37:46.954 I, I would say that, you know, having some information as to whether the PCs is supporting properly and following the course properly and 12 months. If you find that to that. So current, then that definitely gives us more comfort to go higher granularity. But again. 279 Roger Salas SCE 01:37:47.164 --> 01:37:51.784 That's what a good day would give us. We'll give us some information on that. 280 Frances Cleveland 01:37:52.864 --> 01:38:06.244 So, would you be able to modify the interconnection agreement at that point in time? Or would that be part of the interconnection agreement to review the profile and make changes as necessary? 281 Roger Salas SCE 01:38:08.345 --> 01:38:11.405 Yeah, I don't know about that. I mean, what to think about that I'm not sure about. 282 Alex Mwaura PG&E 01:38:12.485 --> 01:38:29.405 Yeah, I, I, I think, uh, for the projects that are already connected already have an interconnection agreement. I don't think they can just, you know, go back and change the profile. I think it would have to be what we learn would be applied to future projects. Um, and also. 283 Alex Mwaura PG&E 01:38:29.824 --> 01:38:40.714 Just to make sure I understand your question and say, are you saying, are you asking whether would be able to in real time or cluster real change customer profiles. 284 Frances Cleveland 01:38:44.195 --> 01:39:04.655 Change the profile in other words, that would still be a limit on the books, but you could say for the next 2 weeks, because I, you know, you've got load forecast. You've got all of this other information and you can see what the customer the customer is doing. We'll let you go. 285 Frances Cleveland 01:39:04.684 --> 01:39:12.064 From 70% reduction to 80% reduction. In other words, relax the requirements. 286 Alex Mwaura PG&E 01:39:13.564 --> 01:39:14.674 Yeah, I think we have. 287 Alex Mwaura PG&E 01:39:17.614 --> 01:39:37.084 We have a slide that sort of touches I think, for if I'm understanding you correctly, you know, that sort of, uh, operational flexibility if you will would have to be coupled with additional tools, um, that the utility. 288 Alex Mwaura PG&E 01:39:37.234 --> 01:39:51.724 Uh, planning to have in the future, and maybe if we have that, you know, those kinds of tools, then we'll be able to have enough comfort level to do what you're suggesting. Um, I don't believe that, you know, what we learn from this. 289 Alex Mwaura PG&E 01:39:54.455 --> 01:40:01.565 Uh, would would be able to inform us to go to what you're suggesting, but I don't know if others feel the same way. 290 Roger Salas SCE 01:40:02.345 --> 01:40:15.155 If your customer wants to change that where they're operating, there's mechanisms in there that allows changes they what changes they can and cannot make. So as long as they're those are. 291 Roger Salas SCE 01:40:15.184 --> 01:40:25.744 Is that are allowable then? Then that's possible but I'm, I'm suspecting that that the changes that you're asking, for instance, with those would probably be the material and now allowed. 292 Frances Cleveland 01:40:27.274 --> 01:40:35.854 Well, that may be some of the things that need to be explored, what could be put into the interconnection agreements. 293 Frances Cleveland 01:40:36.724 --> 01:40:54.664 Typically, during a quote testing time, uh, that would allow, um, again, uh, changes in both directions and relaxing, uh, the, the profile as well as potentially increasing it. If there really is a problem. 294 Frances Cleveland 01:40:58.384 --> 01:41:06.874 So, I'll leave it at that, but I do believe that we need to see what kinds of flexibility there are in both directions. 295 Regnier, Justin 01:41:10.174 --> 01:41:19.234 So, there's been a bit of chat in the chat about developers opinions and I see that eva's hands up. And she has a developer. 296 Eva Wang TotalEnergies 01:41:22.055 --> 01:41:42.575 I want to bring back just kind of a little bit about the customer's perspective on this, because I was on the sales side before so looking at the test period and looking at who could be the potential customers that who you will want to participate in the profile right like not all. 297 Eva Wang TotalEnergies 01:41:42.579 --> 01:42:03.514 The customer wants you to do that, because they might have seen a lot of customers has sustainability goals that they want to export back to the grid and then offset their energy usage that that's a lot of our customer has that goes the customer. I can see. 298 Eva Wang TotalEnergies 01:42:04.174 --> 01:42:24.874 Uh, the pet or or some customers, they think they might not have to pay a lot of upgrades costs. So they want that flexibility. They rather paid upfront costs and then have the flexibility of importing or exporting as much as they want. Um, the only customer that will be good for our GP. 299 Eva Wang TotalEnergies 01:42:25.955 --> 01:42:39.095 Would be customers 1 doesn't have a strong sustainability goal and, um, what potentially phase? Um. 300 Eva Wang TotalEnergies 01:42:40.625 --> 01:43:01.505 Much higher upgrade than anticipated and could benefit from 1st of all, not paying the upgrades and exporting to the profile that that profile has to match. Well, not match their load. Profit has to. 301 Eva Wang TotalEnergies 01:43:01.564 --> 01:43:22.264 Go while with the load profiles, so they can get enough benefits from exporting back to the grade. So now it'll work. The credit they're getting by participating in. Our GP is not it's not significantly less compared to if they're just. 302 Eva Wang TotalEnergies 01:43:23.314 --> 01:43:43.774 Customer, so it's very specific and I was just worried about this testing period. The 1st of all, you know, maybe like 1 of the 10 customers we have might be a good customer for and you have to tell them, like, hey, we have this 2 year period. 303 Eva Wang TotalEnergies 01:43:43.864 --> 01:44:04.984 Testing period, and then after 2 to 3 years, you are still facing the risk of being limited to the lowest value. And that's a basically an acceptable risk to the customer. So, back to sky's point, like, you know, ways. 304 Eva Wang TotalEnergies 01:44:05.014 --> 01:44:21.094 All these hours, creating this complicated rules and profiles, and maybe not even a lot of customers who would want to participate in the end. So I don't think that's it. What everyone wants to see. 305 Eva Wang TotalEnergies 01:44:30.214 --> 01:44:34.144 Okay, it says a developers perspective, but more like customer perspective. 306 Regnier, Justin 01:44:45.424 --> 01:44:57.184 In our last workshop, it sounded like there was agreement if not consensus that the most likely customers for this would be Nam above megawatt because their upgrades wouldn't be rate based anyway. 307 Eva Wang TotalEnergies 01:44:57.904 --> 01:45:02.524 Yeah, yeah, it has to be about what megawatt, right? And I want to see, like. 308 Eva Wang TotalEnergies 01:45:02.824 --> 01:45:23.584 You know, it depends on what's the lowest value, right? If the lowest has value is like a 5 megawatt customer, right? If the lowest values 1 megawatt, then they're facing, potentially have to regulate, like, a 4 megawatt gap and then might not want to do that. Because that's too much of a risk, but. 309 Eva Wang TotalEnergies 01:45:24.364 --> 01:45:29.104 They're allowing to export 288 um. 310 Eva Wang TotalEnergies 01:45:29.589 --> 01:45:48.934 How profile and most of them are close to, like, 4 or 5, like, closer to their size system size. Maybe this was, hey, this is not a bad deal right? I don't have to pay upgrades, but then I can export basically to where I was anyway, compared to. 311 Regnier, Justin 01:45:49.714 --> 01:45:50.284 Profile. 312 Eva Wang TotalEnergies 01:45:50.824 --> 01:46:11.794 Um, but then, you know, just 1 month or 1, you know, a few hours I have to go down to 1. that's that's. Okay. So it's it really depends. And I'm just worried to find those customers. It's 1st of all a lot of work and it's gold and then 2nd, like, if we're putting the rest of being shut down. 313 Eva Wang TotalEnergies 01:46:11.915 --> 01:46:26.165 Like, in my example, 1 megawatt permanently, or you have to pay, like, 5Million dollars upgrade or, like, unlimited dollar amount of upgrade, then that's going to share the customer off from the beginning. 314 Regnier, Justin 01:46:27.604 --> 01:46:48.544 So, I heard you say, a couple of different things, and I'd like to drill down if we can a little bit. Um, 1, is that the, the risk of being pulled down to the minimum value is not acceptable on. But also in a subsequent conversation that if it's a few hours. 315 Regnier, Justin 01:46:48.549 --> 01:47:09.604 It's okay, and then, I think maybe I would ask your perspective as to whether whether the determinant that we should be looking at is not whether the customer gets pulled down to the minimum value ever or X number of hours. But what the impact on revenue. 316 Eva Wang TotalEnergies 01:47:10.504 --> 01:47:10.714 Yeah. 317 Regnier, Justin 01:47:10.744 --> 01:47:30.214 Because we know assuming, you know, this is until, and unless the commission moves on it but if you assume that the net billing tariff is going forward and the ACC is there. Then we know exactly what the value of export for each hour is going to be. And you could say that we already know that anyway through the. 318 Regnier, Justin 01:47:30.875 --> 01:47:51.995 The time of use tariffs, I mean, I think we've got the tools to be able to map from not so much a, a number of reduction and minimum hours, but an actual impact on revenue but before we go through all that difficulty, I'd like to double check with the developers and industry organization. 319 Regnier, Justin 01:47:52.000 --> 01:47:59.735 That really the variable that the customers care about is impact on revenue not hours of reduction. 320 Eva Wang TotalEnergies 01:48:00.455 --> 01:48:12.875 That's right. Uh, especially for customers, right? They sign a contract with developers. They pay a fee or, um, dollar per kilowatt. Uh, agreed upon Pre. Agreed upon. 321 Eva Wang TotalEnergies 01:48:13.714 --> 01:48:32.344 Dollar particular 1 hour, but for developers, what we really care like, for this deal to work with the customer, we need to rely on the kilowatt hours of credit working get. So it's all about revenues at the end of the day. Right? Even for negotiating that PPA. 322 Eva Wang TotalEnergies 01:48:32.915 --> 01:48:54.035 To determine what's a good to have between customers really? And developers we need to know, you know, whether we're facing a limited liability down the road. Um, or like, if you talk about a few hours, then sure we can eat that right? Like, that risk we can take, but if we were talking about 10 years, 15 years. 323 Eva Wang TotalEnergies 01:48:54.064 --> 01:48:57.304 Down the road, like, that's too much of risk. 324 Regnier, Justin 01:48:58.954 --> 01:48:59.194 So. 325 Eva Wang TotalEnergies 01:48:59.224 --> 01:49:08.284 Change is going to affect the so it's eventually going to put out to the customer and the will be too high. Then we will have a contract. 326 Regnier, Justin 01:49:09.544 --> 01:49:15.184 So, I want to make sure I don't derail Alex too much here, but let me maybe we can put a pin in this. So it's. 327 Regnier, Justin 01:49:15.214 --> 01:49:27.664 Sounds like the non starters are the long term uncertainty on the revenue impact. So, as long as there's a certainty over long term of the revenue impact, there's space within that to work. 328 Eva Wang TotalEnergies 01:49:29.674 --> 01:49:31.534 I think that's a fair statement. Yeah. 329 Regnier, Justin 01:49:32.704 --> 01:49:50.404 And I know, I mean, listing a little bit last workshop around what sort of analysis to run around different scenarios. It sounds like really if we're gonna run scenario analysis, we should look at what the, the positive. 330 Regnier, Justin 01:49:50.464 --> 01:50:11.584 Back to revenue would be for the extra production, unlimited generation profile and what sort of negative impact to revenue that might offset in the case that curtailment is necessary. Does that seem about okay, I'm seeing a head nod and I'm going to back off the topic because I see. Sky is. 331 Regnier, Justin 01:50:11.614 --> 01:50:14.704 Got her hand up and I know Alex has got lots of stuff to go through. 332 Sky Stanfield 01:50:17.974 --> 01:50:30.904 Well, thanks, Justin, I was just going to add that. It seems to me, like, the 11 other element that we're missing and that would be needed is again, the odds that that revenue would be impacted. 333 Sky Stanfield 01:50:33.064 --> 01:50:53.824 I, it seems to me, and again, I'm not a financing expert, but that's a critical thing to understand for the customer is, how likely is it that the revenue will be impacted and then, by how much we're getting at the like, how would you, you know, potentially modeling the amount of the of the impact, but not. 334 Sky Stanfield 01:50:53.915 --> 01:51:15.035 How likely it is that that would occur and maybe that's not relevant to the calculation but it seems to me, like, it's a critical piece of actually being able to assess it. Right? Unless you think every, all the is just extra revenue, and maybe the modeling would come out that way and it didn't matter whether you got to build it or not. But I don't think. 335 Sky Stanfield 01:51:15.244 --> 01:51:17.854 Quite at that, that level of pricing. 336 Regnier, Justin 01:51:20.254 --> 01:51:39.784 And I think really, the, the point that I've heard from the developers is that your costs get locked in by the infrastructure that you build. So you can run optimization through system advisor module or whatever software you're using to say, you know, we've, we've got this load. We want to battery that size. We want production at this size. 337 Regnier, Justin 01:51:41.104 --> 01:52:01.564 But at that point, you've made your choice and you have to live with the consequences. I think to the point is that we don't. We don't have you made the point last workshop that they have not run the analysis to know what the risks will be. And what I think I heard from the, and the last workshop is. 338 Regnier, Justin 01:52:01.594 --> 01:52:08.884 That the, they have no way of knowing it without actually doing it. Um. 339 Sky Stanfield 01:52:12.875 --> 01:52:16.955 Right, well there's the problem is, how do we do it to get the data. 340 Roger Salas SCE 01:52:17.705 --> 01:52:18.095 Do you mean you. 341 Sky Stanfield 01:52:18.485 --> 01:52:31.175 I'm trying to unpack is how do we actually get some test cases that could move ahead to get any data and I also, I have 1 part of our presentation is just to talk about. I still think we need a lot more sense from how we would even. 342 Sky Stanfield 01:52:31.204 --> 01:52:52.294 Figure it out with the data either today, or after a test period like, what would the data actually, tell us about the frequency of the events in the future? That I think it seems to be beyond my pay grade in terms of thinking about what we would actually learn, but we should definitely talk about it because it seems like there might be ways to figure that out but it's not clear to me what how. 343 Sky Stanfield 01:52:52.354 --> 01:52:53.614 Exactly, you can figure it out. 344 Alex Mwaura PG&E 01:52:55.924 --> 01:52:56.554 The 1 thing that. 345 Alex Mwaura PG&E 01:52:58.205 --> 01:53:19.115 1 thing I want to point out that I think we've kind of missed in this whole discussion is, I think the assumption is that the lowest value is much much lower than the highest value. And that's not always the case. There might be a Delta, but it may not be as significant as, you know, it's probably being. 346 Alex Mwaura PG&E 01:53:19.144 --> 01:53:34.894 Assumed in this discussion, so you can still have a customer that may be willing to do project. I guess it's not like every location is going to be 5 Mega, which is a maximum of 500. kilowatts is the minimum. 347 Sky Stanfield 01:53:34.954 --> 01:53:40.144 Right when the project can choose how much of that additional capacity they take to your point, Alex, you could decide. 348 Sky Stanfield 01:53:40.414 --> 01:53:50.554 Only 500 kilowatts of extra capacity or whatever, but you still have to make that extra 500 kilowatts make sense and. 349 Alex Mwaura PG&E 01:53:50.554 --> 01:53:51.064 Understood. 350 Sky Stanfield 01:53:51.964 --> 01:53:58.084 And and we'll we can get into it a little bit more of this later again. I think we should. Well, I'm not dictating what happens next. 351 Frances Cleveland 01:53:58.864 --> 01:53:59.134 Yeah. 352 Alex Mwaura PG&E 01:53:59.194 --> 01:53:59.554 Okay. 353 Frances Cleveland 01:54:00.574 --> 01:54:01.414 I just liked. 354 Frances Cleveland 01:54:01.444 --> 01:54:22.564 Again, say that if revenue the revenue stream is the critical value of a critical issue, then we have to look at the potential ability to increase that revenue by allow. 355 Frances Cleveland 01:54:23.194 --> 01:54:33.514 Um, customers to increase their export when it's, you know, above the, the normal profile of the. 356 Frances Cleveland 01:54:34.205 --> 01:54:54.995 Uh, just based on reality, um, you know, a, a few days I had a few weeks ahead, whatever it might be because I see values are, of course, you know, planned years ahead. So, there's very likely and worst case for the most. 357 Frances Cleveland 01:54:55.025 --> 01:55:16.145 Heart, so it's very likely to be additional room. This would be particularly beneficial if we had the 288 hourly values, rather than the monthly values. But I think this is where we really need to look at the benefits or the potential benefits side and the. 358 Frances Cleveland 01:55:16.149 --> 01:55:25.054 Ability to actually increase revenues as well as the potential for lowering the revenue stream. 359 Regnier, Justin 01:55:33.334 --> 01:55:54.214 I think I heard Roger respond to that, but that was, that was something that could be informed when we have better tools, such as terms in terms of the more near real time, or not near real time. Sorry, the mid mid kind of time frame, you know, days and weeks. I don't know. 360 Regnier, Justin 01:55:54.220 --> 01:56:00.815 If I see it can support that, but I'd defer to Roger for my understanding of what Roger said. 361 Roger Salas SCE 01:56:02.135 --> 01:56:15.305 I mean, that's part 1 of the future slides. So where, how can you increase granularity to take more advantage of the capacity in the LGB and yeah, you got it, right? 362 Roger Salas SCE 01:56:16.474 --> 01:56:35.884 They are adjusting, you know, more tools, including in terms of our ability to have more situation, awareness, um, determining, you know, that is safe to operate the grid and the real time operating conditions, ability to take actions, things like that. But we can defer the discussion to to the slide where we're essentially discussing. 363 Frances Cleveland 01:56:37.684 --> 01:56:57.664 But could there be a way of, um, making a, a difference and it may just be in the interconnection agreements but between the say, larger than 1 megawatt, where you have telemetry versus the, the smaller ones where you'd be using the data um. 364 Frances Cleveland 01:56:57.844 --> 01:57:07.054 Because I think that, you know, again there is a real benefit, uh, if, if you have more flexibility. 365 Roger Salas SCE 01:57:09.334 --> 01:57:18.754 Yeah, there, there's more to to the risk of having more problems in the grid. Okay, so that's it's always it's always nice to hear from the other side. 366 Roger Salas SCE 01:57:18.844 --> 01:57:30.784 Yeah, you have all these increased benefits, but at the end of the day with the utilities, how to figure out how to operate the grid with all these variations and that's what makes us nervous. 367 Alex Mwaura PG&E 01:57:33.004 --> 01:57:53.944 So, you know, when it comes to telemetry that gives us VSI visibility, but we'd have to be able to do something with that information. So, you know, that's where the dump system would come into play. We need to have be able to have control. So, if we see that, you know, all, we're doing all getting from the telemetry information from, you know, customer site. 368 Alex Mwaura PG&E 01:57:54.094 --> 01:58:01.354 The exploited amount, right? So we still need to be able to tie that to what's happening on the system and then be able to take an action. 369 Frances Cleveland 01:58:03.095 --> 01:58:23.615 Yeah, I certainly agree with that. What I'm trying to do is to use this quote, testing time if, if we all agree to it, um, to come up with scenarios that could be implemented in the future because we can't say that this, you know, this. 370 Frances Cleveland 01:58:23.679 --> 01:58:44.824 Process this process is, is going to be stagnant it's got to be dynamically, changing over time as more telemetry, more command capability, more terms capabilities come into place. So we have to think of it as a process not just as a static. Okay. Here. 371 Frances Cleveland 01:58:44.854 --> 01:58:49.984 What we're going to do for the next 10 years that's really not how it should work. 372 Roger Salas SCE 01:58:51.034 --> 01:59:05.944 Yeah, 1st, I agree with that. I mean, I think I agree with that. I mean, that's the reason why we'll work really hard to cobble that functionality in this morning borders. Right and all that communication capability. So, I mean, all those ability to change the settings, but it's really more. 373 Roger Salas SCE 01:59:06.004 --> 01:59:19.624 About timing when, when are we going to be able to build our systems and how the regulation you place and enable all of those things to come together so, I think what we're talking about here is timing is just. 374 Frances Cleveland 01:59:20.554 --> 01:59:27.124 I agree 100% and I think that's what's been essentially left off the table. We need to say this is. 375 Frances Cleveland 01:59:27.155 --> 01:59:48.275 An interim process for what we might do in the next year or 2, but we will plan ahead for more flexibility, more telemetry, more commands, more germs, analysis capabilities, et cetera. I think we have to see this as a process, not as a static. 376 Frances Cleveland 01:59:48.665 --> 01:59:50.255 You know, this is the way it is. 377 Alex Mwaura PG&E 01:59:55.655 --> 01:59:58.805 Sort of what we're going to say in the slides that I mentioned. 378 Alex Mwaura PG&E 02:00:05.795 --> 02:00:06.785 Any other questions. 379 Sky Stanfield 02:00:10.354 --> 02:00:27.964 I just have a comment on this conversation. Um, I don't think dermis even at the control level or and is going to change the fundamental thing that we're disagreeing about, which is, who has the liability and how do you or how do you. 380 Sky Stanfield 02:00:29.284 --> 02:00:50.284 Mitigate the risk. The problem here is the utilities aren't even if you have germs, you're still not intended to allow project to do what we're talking about, unless they bear the full responsibility. They don't see how dermis actually mitigates any of the, the customer's risk. So, I'm fully in agreement Francis thought like. 381 Sky Stanfield 02:00:50.344 --> 02:01:11.464 We want to build in the full sophistication of being able to enable these systems to operate in the manner. That's best. We forget. That is our principal goal here but James is not going to fix the, the basic issue. We're most disagreeing about at this initial stage, which is, how does a developer build a project. 382 Sky Stanfield 02:01:11.495 --> 02:01:19.625 If they have, no, if they have no guarantee that they'll be able to take advantage of any additional capacity. 383 Sky Stanfield 02:01:23.255 --> 02:01:24.365 Results any of them. 384 Roger Salas SCE 02:01:24.725 --> 02:01:43.595 I agree. That's great. I mean, basically won't allow to maximize the granularity and the profile, but, you know, it could be that those just reduces the profile because such as what the system can handle. Right and, and that may not be acceptable to. 385 Roger Salas SCE 02:01:44.254 --> 02:01:50.914 To be our operators and so, you know, there's, there's the issue again who pays for the updates that are needed. 386 Sky Stanfield 02:01:52.534 --> 02:02:13.504 For that is, is that the utilities of business model isn't driven to actually incentivize optimal use of the grid like, that's the fundamental issue. You're saying, what would be convenient, but we get a rate revenue return. If we upgrade the grid ourselves for rate pair needs, but not otherwise. So we're at this point where there's there is benefit, but the utility. 387 Sky Stanfield 02:02:13.715 --> 02:02:34.655 Instead of, and I'm not talking you Roger on that. That's just the facts. And so I think that's what the commission is gonna have to grapple with here. But I don't think getting any getting germs is really what we should be worrying about at this 1st, stage. We need to get a basic test case with a static profile that would actually allow projects to be built before we can get more. And then, I think to. 388 Sky Stanfield 02:02:34.685 --> 02:02:55.805 This is point, maybe if we do get to something that seems viable, the project will actually both be built that we could test for 2 to 3 years we should make sure we're collecting data that would enable that future conversation. But right now we're not at the point where I feel like we're going to get any data at all. So it seems a little bit beyond where we are. 389 Sky Stanfield 02:02:55.809 --> 02:02:56.524 Are at the moment. 390 Regnier, Justin 02:03:02.855 --> 02:03:03.305 From. 391 Regnier, Justin 02:03:07.414 --> 02:03:10.174 That all makes sense. Um. 392 Regnier, Justin 02:03:11.584 --> 02:03:32.434 So, there's, there's a bit of a split in the conversation I maybe want to call it out explicitly. So the, the question of how, and when curtailment happens is 1, that is separate from the question of who bears cost the question of who bears the cost. 393 Regnier, Justin 02:03:32.470 --> 02:03:53.615 Disguise point is integral to ensuring that there's actually enough uptake that this is a, an exercise that that yields useful information. I think our, our, our core necessity for this workshop, and for the advice letter subsequent is to get a well articulated set. 394 Regnier, Justin 02:03:53.644 --> 02:04:14.764 Of tariff language that addresses the weather and the how I do respect francis's perspective on the long term. But I, I know that we've got a finite amount of time and attention and effort and I want to make sure that we nail the things that we're that are our main objective before we get. 395 Regnier, Justin 02:04:14.769 --> 02:04:35.914 Too far into to optimization for future systems with that. I'm happy to turn it back over to Alex to continue on presenting the material that he has here, or have further conversation with the stakeholders based on. 396 Regnier, Justin 02:04:36.124 --> 02:04:40.714 On folks, preference, I'm going to go ahead and tag you Alex to run that. 397 Alex Mwaura PG&E 02:04:44.855 --> 02:04:51.665 All right, thank you, Justin. I don't see any more hands up, so I will go ahead and continue with the presentation next slide. Please. 398 Alex Mwaura PG&E 02:04:54.814 --> 02:05:02.914 So, topic, number 2 is output reduction element 1 for this question. 399 Alex Mwaura PG&E 02:05:04.444 --> 02:05:23.494 With the extent to which the LGB option allows for performance that avoids triggering upgrades within existing hosting capacity constraints. So they are you position is that as long as the exports at or below minimum level upgrades will be avoided. 400 Alex Mwaura PG&E 02:05:33.755 --> 02:05:34.775 Oh, Justin has it sound. 401 Regnier, Justin 02:05:36.305 --> 02:05:51.845 If we can go back 1, I think that there's, there's a bunch of asterisks which you probably had in mind when you wrote this but want to make sure that we're clear on it that the only rationale for reducing the export to minimum. 402 Regnier, Justin 02:05:52.624 --> 02:05:58.024 Level has to do with, uh, safety and reliability. 403 Alex Mwaura PG&E 02:06:03.094 --> 02:06:03.664 Yeah. 404 Regnier, Justin 02:06:06.065 --> 02:06:25.835 Okay, and I think in our prior discussion in workshop, 1, there was pretty clear agreement consensus from both and non parties that if a, that that mitigations would be undertaken even if upgrades are not too. 405 Regnier, Justin 02:06:26.104 --> 02:06:47.044 To restore as much of the hosting capacity as was available during the original interconnection agreement that was something that the sounded willing to embark upon. And these non stakeholders were in agreement that was reasonable. 406 Regnier, Justin 02:06:47.104 --> 02:06:54.514 That mitigation should be done to bring folks back to to their original condition, irrespective of upgrades. 407 Alex Mwaura PG&E 02:07:01.174 --> 02:07:04.714 I didn't you say it that 1 more time, Justin. 408 Regnier, Justin 02:07:05.674 --> 02:07:18.004 Yeah, so drawing the distinction between mitigations and upgrades mitigations being those things that are in the, as Gary was saying, the tons of thousands of range. And as Roger said, things that do not results in new hardware, being required. 409 Regnier, Justin 02:07:18.214 --> 02:07:37.564 So, adjustments and parameters, um, smart and murder, um, characteristics being modified to, for example, provide more bars. Um, you know, that mitigations should always be. 410 Regnier, Justin 02:07:39.665 --> 02:08:00.275 On the table, in terms of restoring the ability of the interconnection customer to operate within the parameters of their, um, interconnection agreement. But this this is this is discussing upgrades. But the mitigations are are a separate topic and that there's not really any contention that the, and. 411 Regnier, Justin 02:08:00.369 --> 02:08:05.914 Interconnection customer will work to get mitigations going to restore the original connection agreement. 412 Alex Mwaura PG&E 02:08:07.054 --> 02:08:07.294 Yeah. 413 Alex Mwaura PG&E 02:08:07.444 --> 02:08:19.054 I think so. I think mitigations and upgrades are interchangeable but what I think you're referencing is the low cost to us as high cost upgrades, slash mitigations. So. 414 Regnier, Justin 02:08:19.054 --> 02:08:19.234 Well. 415 Alex Mwaura PG&E 02:08:19.234 --> 02:08:21.964 The collection is right. Sorry? 416 Regnier, Justin 02:08:22.084 --> 02:08:28.564 No, my recollection is that we drew a distinction between the distinction was was well, now. 417 Regnier, Justin 02:08:28.594 --> 02:08:37.324 Roger up there, so I'll let him speak to his own his own words. But my understanding was that the, the difference was whether we installed new hardware or not. 418 Roger Salas SCE 02:08:37.444 --> 02:08:41.254 Yeah, yeah, I mean, I, you know, just for, you know. 419 Roger Salas SCE 02:08:41.375 --> 02:09:02.405 Uh, I guess speaking on behalf of, I think, upgrades upgrades to bring the project towards original something of last resort, meaning that we, we know we would do all we can to be able to. 420 Roger Salas SCE 02:09:02.465 --> 02:09:23.465 Being the approved IC values to the extent that we can, uh, Lucas mitigations no, cus mitigations you know, we, we have a few things under under our Toolbox that we can implement, um, so that we can restore the customer cell GP profile in cases. So say, you know, large. 421 Roger Salas SCE 02:09:23.559 --> 02:09:44.494 Disappearing and so always saying is that we cannot always guarantee that 1 of those, you know, 1 of those options is going to solve the issue. And only and when that happens, then upgrade will be required. And if if customers wanted to to bring back to the original GP, so, yes, mitigation. So. 422 Roger Salas SCE 02:09:44.734 --> 02:09:56.494 No cast or Lucas will always be done 1st, uh, and, you know, likely, you know, that that will resolve that condition, but it can narrow. It cannot be guaranteed. That's the only issue that makes it. 423 Alex Mwaura PG&E 02:09:57.484 --> 02:10:05.584 So, I just again mitigations in the system could be anything that needs to mitigate whatever issue is. 424 Alex Mwaura PG&E 02:10:05.884 --> 02:10:27.004 Being caused on the distribution system that can be an upgrade. That is a physical, physical piece of equipment that's installed for an upgrade to existing piece of equipment or we keep being upgrade to settings to an existing piece of equipment. Um, but all those mitigations that are a result of an. 425 Alex Mwaura PG&E 02:10:27.035 --> 02:10:47.195 You on the distribution system, so this time, sometimes I interchangeable. They use it interchangeably, but you have generation system that's wanting to connect to a distribution system. It causes an issue that has to be mitigated. And then that issue, whatever mitigation could be, you know, again, a re, conductor installation of a new piece of equipment. 426 Alex Mwaura PG&E 02:10:48.395 --> 02:10:55.925 To an existing piece of equipment, which could be a setting change, which is usually very minimal cost, but all those, uh, you know, medications. 427 Alex Mwaura PG&E 02:11:00.755 --> 02:11:01.805 Just needs to have to handle. 428 Alex Mwaura PG&E 02:11:09.064 --> 02:11:11.644 All right, then more questions can move to the next slide. 429 Alex Mwaura PG&E 02:11:16.624 --> 02:11:34.144 So, this is related to topic number 2 element 2. and the question here is if future grid conditions, reduce the hosting capacity, the extent to which large may need to reduce generation to ensure safety and reliability without grid upgrades. 430 Alex Mwaura PG&E 02:11:35.434 --> 02:11:55.744 So the 1st item here has to do with the extent of reduction, uh, depending on the severity of the system condition. So what the operators will do is, they'll perform initial actions. This could be something that they, you know, I guess operational engineers, depending on what the titles are. The different utilities. 431 Alex Mwaura PG&E 02:11:55.864 --> 02:12:16.234 Do maybe a voltage LTC voltage regular or LTC controller settings change to me to get safety or reliability conditions and if they determine that, you know, those changes are not effective, then they will assess a reduction to experts. 432 Alex Mwaura PG&E 02:12:18.214 --> 02:12:37.534 And then a determination will be made that the export for projects need to be lower to the level. Um, original LGB export level can be restored. When reliability condition is mitigated. The 2nd item is. 433 Alex Mwaura PG&E 02:12:38.225 --> 02:12:59.135 All the scenarios below unlikely to account for projects, this will be scenarios that should be monitored for future discussions as experiencing the application is gained. So this is something that we can learn from the test cases that we talked about in the previous slide. And when system's condition. 434 Alex Mwaura PG&E 02:12:59.314 --> 02:13:20.434 System conditions have changed the export is causing an overvoltage on overload, condition, grid, operation operators, or operational engineers can observe potential grid safety issue and determine that export is causing the condition. We may be getting some premature equipment failure. 435 Alex Mwaura PG&E 02:13:21.664 --> 02:13:41.584 Determined through investigation, and we can determine through investigations that the export was the, cause of the equipment failure might be in advance equipment malfunctions such as customer about us tripping off line due to voltage issues or frequency issues on the grid. If the. 436 Alex Mwaura PG&E 02:13:41.589 --> 02:14:02.704 That's telemetry then distribution operations engineer can scrutinize more and based on non test or actual export clearance limits under loading distribution operator. Operational engineer can approve generation to stay online or directed to come offline. If generation has no telemetry. 437 Alex Mwaura PG&E 02:14:02.764 --> 02:14:10.354 And most likely the deal, you will direct generation to come offline and they may be other scenarios that are not covered on the slide. 438 Alex Mwaura PG&E 02:14:21.275 --> 02:14:22.085 Next slide please. 439 Sky Stanfield 02:14:23.915 --> 02:14:28.205 Alex, sorry, this is just a quick question on that last slide. Um. 440 Sky Stanfield 02:14:33.305 --> 02:14:44.375 None of the items in this under the 2nd, primary bullet are specific to customer risk right? Am I. 441 Alex Mwaura PG&E 02:14:46.325 --> 02:14:47.225 That is correct. Yeah. 442 Sky Stanfield 02:14:49.804 --> 02:14:54.844 Does it say, I mean, overall, does this just apply to any project that's already connected today? All of this. 443 Alex Mwaura PG&E 02:14:56.824 --> 02:15:17.464 This all of this is applicable to any generation project, any, any system can cause these issues. Um, but again we go back to the idea of that for existing systems. We don't have the mechanism to reduce their export values to a different amount. And we believe that the decision that allows to. 444 Alex Mwaura PG&E 02:15:17.470 --> 02:15:21.005 Jp does give us the ability to go to the. 445 Sky Stanfield 02:15:21.365 --> 02:15:38.615 So, you don't think that the commission was tying that ability to the risk created by the itself and just saying, now, we'll just create, like, a 2nd, class of projects that can be reduced. Like, I think that you guys are gonna stretching a little bit to say we can make reductions to an. 446 Sky Stanfield 02:15:38.644 --> 02:15:59.734 Projects that aren't driven by its profile, for example, inadvertent equipment malfunction and treat those projects are because that's not safety and reliability issue that's driven by the fact that it's operating as an any project can have an equipment, inadvertent equipment now function. And I'm not sure that the commission. 447 Sky Stanfield 02:15:59.769 --> 02:16:01.414 Envision that you were going to. 448 Sky Stanfield 02:16:02.704 --> 02:16:18.274 Create an additional set of restrictions that have nothing to do with the profile itself. It seems to me, like, the safety reliability issues were we were convinced conceiving. We're around the profile not equipment manufacturer. Malfunction that could happen to any project. 449 Alex Mwaura PG&E 02:16:18.874 --> 02:16:23.434 Yeah, but I I think, I think for so I, I think that the commission. 450 Alex Mwaura PG&E 02:16:24.724 --> 02:16:42.874 Um, understood that projects are going to be a larger export more than they would normally be allowed to export and because of this additional, you know, advantage or additional, you know, export capability. They realize that this could cause issues to the system. And then. 451 Sky Stanfield 02:16:45.695 --> 02:16:54.635 It is not the project's ability to produce to export more. That is causing that that that the risks you've identified here, there's nothing to do with that. 452 Alex Mwaura PG&E 02:16:54.665 --> 02:16:54.875 Yeah. 453 Sky Stanfield 02:16:55.445 --> 02:17:03.425 So, why would the commission want to penalize those even beyond the cheese, which is what you're suggesting here. 454 Alex Mwaura PG&E 02:17:03.965 --> 02:17:06.035 So, I think let me go back to that. 455 Alex Mwaura PG&E 02:17:06.039 --> 02:17:18.214 Bullet point, so it's the 2nd item and bullet number 2, which says grid operator observes the potential grid safety issue or? No, it's not that. 1. let me see. 456 Roger Salas SCE 02:17:18.814 --> 02:17:19.414 Alex. 457 Alex Mwaura PG&E 02:17:21.484 --> 02:17:27.183 Perfect so premature equipment fairly investigation. The time is that export was the cause of the. 458 Alex Mwaura PG&E 02:17:27.303 --> 02:17:35.524 Failure, so, if it's not determined that the is the 1 that's causing an issue. I don't believe that we will be asking the just the project. 459 Sky Stanfield 02:17:35.524 --> 02:17:35.853 I think. 460 Alex Mwaura PG&E 02:17:36.754 --> 02:17:37.414 We may have the. 461 Sky Stanfield 02:17:37.414 --> 02:17:48.334 Get more specific with what you've laid out here is not tied to the specific. That's my point. It's not tied to the and the. 462 Sky Stanfield 02:17:48.339 --> 02:18:09.334 Performance of the function and so these scenarios we need to make sure that we're not saying you propose an, and also a bunch of other things could happen to you. It wouldn't have nothing to do with the profile. We're already having a major risk issue, just with getting a customer to build that additional capacity. And now you're adding. 463 Sky Stanfield 02:18:09.544 --> 02:18:12.904 It wouldn't even exist if they just designed a regular project essentially. 464 Aliaga-Caro, Jose 02:18:13.473 --> 02:18:13.834 Yeah. 465 Sky Stanfield 02:18:14.254 --> 02:18:20.553 Maybe, that's what it sounds like. What you're thinking is that you need that maybe that is constrained, but that's not how these are reading right now. 466 Roger Salas SCE 02:18:21.814 --> 02:18:26.614 I think I think maybe maybe that's not maybe we, we didn't do a good job. 467 Roger Salas SCE 02:18:27.994 --> 02:18:48.933 Bringing this, but I think the 2nd bullet is just like, how do you, how do you even notice that there's a problem and yeah, you're right. This could be an, and project. Um, I think the big the big difference what we talked about before, is that is that for for a non project. 468 Roger Salas SCE 02:18:49.745 --> 02:19:10.115 Uh, you can still reduce it for things like our temporary emergency conditions, failures things that are going to be mitigated relatively quickly and we are responsible to do whatever is needed to, to basically bring it back right for, for non projects that same thing. 469 Roger Salas SCE 02:19:11.134 --> 02:19:18.574 I think that same philosophy still applies if we are required to basically reduce the output of and. 470 Roger Salas SCE 02:19:18.579 --> 02:19:39.723 Project below the ice minimum value, so that's so below the minimum value. It is the same for an project and analogy project in that. We, we are minimum kind of need to guarantee that minimum. I see value. Right? But really is. 471 Roger Salas SCE 02:19:39.728 --> 02:20:00.874 That is really our ability to reduce the profile to the minimum value that I think we're trying to say here that we can do that. And if that resolves the issue, so you have an overvoltage problems 1 example, and you're able to to mitigate that by reducing the profile not not to be not to go lower than the minimum. 472 Roger Salas SCE 02:20:00.880 --> 02:20:12.065 Oh, I see. Is your value then that's a condition that may potentially stay much more longer than then if they need to have to go below the value that makes any sense. 473 Roger Salas SCE 02:20:17.284 --> 02:20:18.274 Sorry, Scott, you're on mute. 474 Roger Salas SCE 02:20:21.934 --> 02:20:24.694 Still on mute I can I hear you. At least I can. 475 Sky Stanfield 02:20:24.994 --> 02:20:40.414 Sorry, I didn't it doesn't show up on my little thing so that I, I think I agree with the idea that if the overvoltage issue occurred doing during the, the additional profile hours. 476 Sky Stanfield 02:20:41.854 --> 02:20:49.744 The, so the cause was that you were producing power during those extra hours, I'll just call them. 477 Roger Salas SCE 02:20:49.894 --> 02:20:50.074 Right. 478 Sky Stanfield 02:20:50.104 --> 02:21:02.914 That that would be fine or that that's potentially what's allowed then. But I think that that this list of conditions doesn't. 479 Sky Stanfield 02:21:02.920 --> 02:21:03.635 Line with that. 480 Roger Salas SCE 02:21:03.695 --> 02:21:03.965 Yeah. 481 Sky Stanfield 02:21:03.995 --> 02:21:08.585 So some of them do, and some of them don't. And so my suggestion would be. 482 Sky Stanfield 02:21:10.025 --> 02:21:31.115 Maybe you guys could go back and think about these criteria a little bit more deeply. And especially, because I don't think a customer again with the idea of mitigating, getting a customer comfortable with the amount of risk. I don't think saying especially, I don't think you're going to feel nervous. Like, well, now I'm giving the data them all this and telemetry data and they're more likely to. 483 Sky Stanfield 02:21:31.324 --> 02:21:51.304 Even for conditions that would have occurred anyways, I want to avoid that, because I think we need to make it again. We made to make this feel like a normal interconnection level of risk extent. We can, and some of these make sense like I said, the overvoltage overload condition during those hours, but other ones don't seem as tied to me here. 484 Roger Salas SCE 02:21:52.834 --> 02:22:00.724 Well, I mean, I, I think this could again, this could occur to any, any generator out there, right? Whether it's on non. 485 Roger Salas SCE 02:22:00.729 --> 02:22:21.484 And 2nd bullet is just the 2nd bullet is just, you know, how do you even determine that whole problem out there right now the next thing that that is important is, okay, what actions can or cannot you cannot take obviously our number 1 action is going to be ensure that the system safe and so. 486 Roger Salas SCE 02:22:21.905 --> 02:22:42.695 Standard actions, immediate actions need to be taken, whether it's an, and to bring the system to normal conditions. Then that's only be taken immediately regardless as to whether it's an, and an now then what happens next is important is the evaluation if the evaluation. So, it shows that. 487 Roger Salas SCE 02:22:43.029 --> 02:23:04.174 We can remove those additional problems, but she's bringing the extra hours below the lower, but not below the minimum value. Then There'll be that that thing that's the area that we would say. Well, you know, we are allowed to do that, but if we needed to bring that value, even lower than the minimum value. 488 Roger Salas SCE 02:23:04.835 --> 02:23:12.215 Then we, we start to mitigate that condition real time, but then we have to do, uh, something to try to fix that as quickly as possible. 489 Sky Stanfield 02:23:12.875 --> 02:23:14.765 Yeah, that makes sense to me. 490 Alex Mwaura PG&E 02:23:23.255 --> 02:23:23.825 Adjusting. 491 Regnier, Justin 02:23:25.835 --> 02:23:43.655 So, I agree with both sky and Roger on this, I think sky raises a valid point and we can take an action item to pull the actual language out of the resolution. Because I do believe that there's language and addictive, not on the findings, the fact ordering paragraphs. 492 Regnier, Justin 02:23:45.365 --> 02:24:03.905 That clearly articulate that in it's gotta be based on specific issues. Um, so I think roger's heard that and the ideas have heard that, and they can go back and make sure that what goes into the advice letter corresponds with direction on the resolution. We're happy to provide that exact language if necessary. 493 Regnier, Justin 02:24:04.863 --> 02:24:25.683 I think, really where we're getting hung up here as to do with the long term policy on upgrade. I would throw out a couple things. There. 1, is that we've established that the business as usual process for interconnection customers. 494 Regnier, Justin 02:24:26.044 --> 02:24:46.864 To provide upgrades that bring them back into compliance with their interconnection agreement, full stop unless we have, you know, we've not established a separate customer class. We've not established that this would be, you know, an important expenditure of rate pair funds. So that's the. 495 Regnier, Justin 02:24:47.254 --> 02:25:00.814 The framework that we are in absolutely. Development that the upgrades would be provided, um, as they would to any other customer. 496 Regnier, Justin 02:25:04.084 --> 02:25:23.404 I don't think that the resolution of that question necessarily has to come before we talk about weather and how curtailment would occur where we're getting hung up is, you know, timeframe and costs for restoration of original hosting capacity. 497 Regnier, Justin 02:25:24.364 --> 02:25:44.884 Um, I think those are critical questions in terms of policy design and making sure that this has uptake that Scott and I just had mentioned. But I'm not sure. We absolutely need to solve those questions prior to having advice letter language for the tariff. That articulates. Exactly. Whether, and how it curtailment occurs. So those. 498 Roger Salas SCE 02:25:48.994 --> 02:26:08.884 Yeah, Justin, I guess, just to clarify at least for se and based on our view, is that the resolution, or the order clear says, I think, uh, you know, someone had it in 1 of the slides here that we know that we're allowed to reduce. 499 Roger Salas SCE 02:26:08.890 --> 02:26:13.115 The profile down to the lowest ACS. 500 Roger Salas SCE 02:26:13.119 --> 02:26:34.264 Value or safety reliability issues and and there was clear saying without doing system upgrades. So, for me, it would make no sense that we need to do the, the system upgrades after the fact. And so that we. 501 Roger Salas SCE 02:26:34.294 --> 02:26:45.184 Restore that profile and essentially put that as part of the in repairs when, when when originally should would have been part of the interconnection customer. 502 Regnier, Justin 02:26:46.924 --> 02:26:54.364 I hear what you're saying, but you're conflating 2 different sections of the document. Um, the without upgrade. 503 Regnier, Justin 02:26:55.420 --> 02:27:05.105 Cost is that time of interconnection and unfortunately we weren't as clear as we might have been in terms of the. 504 Regnier, Justin 02:27:08.944 --> 02:27:19.084 The long term use of the strategy of reducing limited generation profiles to the I'm sorry the. 505 Regnier, Justin 02:27:19.895 --> 02:27:31.745 Minimum level as an acceptable means to provide mitigation to safety and reliable reliability issues. Yeah. At present we don't. 506 Regnier, Justin 02:27:33.904 --> 02:27:51.874 We don't allow unsafe for unreliable conditions to persist on the grid. We fix them as a part of the planning process. So I don't I, I understand where you're coming from. But I think we're conflating a couple separate parts of the document. I don't think we've got the clarity that you have in mind. 507 Roger Salas SCE 02:27:53.584 --> 02:27:54.124 Sounds good. 508 Regnier, Justin 02:28:00.004 --> 02:28:00.964 Like, challenge goes hand. 509 Alex Mwaura PG&E 02:28:04.175 --> 02:28:04.475 Join. 510 John Berdner Enphase 02:28:04.505 --> 02:28:21.965 Thanks, Dustin and I, I just wanted to something that occurred to me is that, um, there are certain things where mitigations can occur and we're talking about costs for those. The 1. I think that is an outlier. Is. 511 John Berdner Enphase 02:28:22.984 --> 02:28:40.654 Loss of a major load there's not really an upgrade that can solve that. So how how would that be covered? It's a condition on the grid, but there's not really a way to do an upgrade. So maybe that should be looked at separate. 512 Regnier, Justin 02:28:45.424 --> 02:28:55.864 Well, I, I think we discussed that last time under brad's, 2 factories scenario, and came to the conclusion that it would be the responsibility to mitigate. Um. 513 Regnier, Justin 02:28:57.005 --> 02:28:57.335 Yeah. 514 John Berdner Enphase 02:29:00.155 --> 02:29:19.805 Yeah, I, uh, again, just sort of thinking about it, um, you know, the loss of load issue, um, can create a couple couple of conditions. And so, um, how, how do we know. 515 John Berdner Enphase 02:29:21.244 --> 02:29:30.244 What would the utilities mitigation be? Would they install more instrumentation? Or is it is. 516 John Berdner Enphase 02:29:31.114 --> 02:29:45.994 Issue on a specific line segment, or is it reverse flow concerns? And how would that be mitigated? The question of of what would be the mitigation is the 1 I struggled with. 517 Roger Salas SCE 02:29:47.374 --> 02:29:51.394 Yeah, gentlemen, it all depends. I mean, you know, the depends on the. 518 Roger Salas SCE 02:29:51.695 --> 02:30:12.815 Free the prince and the condition every time we do mitigations, whether it's for load anyway for generation, we always look at the most cost effective solution that can that can meet the need. Right? So, yeah, in some cases could be the pain. If it's a voltage problem potentially. 519 Roger Salas SCE 02:30:12.844 --> 02:30:33.964 We need for voltage regulation or additional voltage regulators or simply changing regular settings. Um, if it's a term overload, then, you know, potentially having to re, conductor certain sections. So, the circuit, but really depends. I mean, it's really hard to say yeah. For this condition, we're going to. 520 John Berdner Enphase 02:30:44.284 --> 02:30:45.244 Okay, thanks. 521 Alex Mwaura PG&E 02:30:51.964 --> 02:31:08.404 I don't see any other hands up so I just want to point out that on this slide for the 2nd item bullet number 2 and 3, both talking about an investigation that will determine whether the project is the cause of the issue. So. 522 Alex Mwaura PG&E 02:31:09.275 --> 02:31:30.365 Not just saying that just because there's an issue it's going to be automatically assigned to the project, but there's going to be some sort of, you know, investigation that will determine either way what's causing the issue. And also, it's not uncommon on the distribution system to have, you know, a single project in the line section and you may be having. 523 Alex Mwaura PG&E 02:31:31.204 --> 02:31:36.934 Issues in that specific line section, which, you know, if there's only 1 project is pretty clear what's causing that issue. So. 524 Alex Mwaura PG&E 02:31:39.274 --> 02:31:40.294 Next slide please. 525 Aliaga-Caro, Jose 02:31:44.164 --> 02:31:52.954 Um, so I'm wondering if maybe this Jose CPC, I'm wondering, uh, before we move on to the next slide, whether this would be a good time to take a break. 526 Alex Mwaura PG&E 02:31:54.664 --> 02:31:54.994 Sure. 527 Aliaga-Caro, Jose 02:31:56.524 --> 02:32:15.394 Okay, uh, let's do that. Uh, let's take a, that way. We're at least keeping a little bit in track, uh, in track with the agenda. So, uh, everybody, let's take a 15 minute break and that's, uh, reconvene at 11 o'clock and we'll continue then with. 528 Aliaga-Caro, Jose 02:32:15.634 --> 02:32:17.104 Utilities presentations. 529 Aliaga-Caro, Jose 02:32:27.064 --> 02:32:30.094 And overhead this would yeah, thank you. 530 Aliaga-Caro, Jose 02:42:17.134 --> 02:42:21.904 All right, we're almost at 11 o'clock. Just want to make sure the utilities are back. 531 Aliaga-Caro, Jose 02:42:25.144 --> 02:42:25.654 Ronnie. 532 Aliaga-Caro, Jose 02:42:39.544 --> 02:42:40.804 Roger Alex. 533 Roger Salas SCE 02:42:44.194 --> 02:42:44.494 Running. 534 Alex Mwaura PG&E 02:42:48.215 --> 02:42:49.835 Backwards as well, this is Alex. 535 Aliaga-Caro, Jose 02:42:50.645 --> 02:42:52.835 All right Thank you Alex. 536 Aliaga-Caro, Jose 02:42:56.975 --> 02:43:00.035 And who's going to be speaking on element? 3 is it so Rony? 537 Alex Mwaura PG&E 02:43:09.454 --> 02:43:12.094 It's tell me Jose have have a few more slides to. 538 Aliaga-Caro, Jose 02:43:13.084 --> 02:43:23.794 Okay okay Alex. All right. So we'll wait until 11 sharp, which is just a few seconds away and get started. 539 Aliaga-Caro, Jose 02:44:07.205 --> 02:44:12.605 All right I show 11 o'clock so, uh, we can resume uh, go ahead, Alex. 540 Alex Mwaura PG&E 02:44:18.274 --> 02:44:36.424 Okay, thank you Jose. So this is, uh, eliminate number 3 for topic 2. and this is going to go over the permanence of reduction of capacity and generation that is even other entity, text, future action that reduces hosting capacity for those, using the option. 541 Alex Mwaura PG&E 02:44:37.324 --> 02:44:58.294 Other entities the 1 causing the issue, and should ultimately be responsible for the cost of carrying the lack of hosting capacity, the ability of customers to dial back production to the grid hosting capacities and is a convenient and expedient short term fix this expediency alone is not justification for permanent reduction. 542 Alex Mwaura PG&E 02:44:58.324 --> 02:45:19.294 Of export power, as part of the discussions that I usually present on scenarios, the trigger analysis using cost acquisition principle. So the 1st bullet here is talking about reduction not to be below the lowest value could be temporary and the emergency conditions. 543 Alex Mwaura PG&E 02:45:19.744 --> 02:45:40.564 And potentially permanent for future grid conditions, and some of these conditions could be unforeseen significant load reductions a customer, closing a plant, creating a new feature grid condition. It could be customers installing large amounts of non expert projects, which causes significant reduction of needed load, creating a new. 544 Alex Mwaura PG&E 02:45:40.625 --> 02:45:53.975 Feature great condition, a permanent grid modification or future expansion of the grid requiring system outages, needed to complete large system. Upgrades could have long lead times. 545 Alex Mwaura PG&E 02:45:55.324 --> 02:46:15.514 for configuration and can create a long term condition different from the original grid condition that was used for the project i use also contend that there's no mechanism to hold customers that reduce the load response responsible for the cost of carrying the result in reduction in hosting capacity 546 Alex Mwaura PG&E 02:46:15.850 --> 02:46:31.535 Typically, if you have a large plant that closes down, they move to a different location. There's no way to go them and, you know, have them pay for the issue that they are causing. And 1 other item that's not really included on here is. 547 Alex Mwaura PG&E 02:46:33.004 --> 02:46:53.314 If we had a distribution system with no generation, and we had a customer nearby kit or move the plant somewhere else, you know, the issues that are caused by generation projects are not the same issues that will because I've seen 2 of them. Right? So, yeah, the customer is moving, but, you know, the reason why we're having these issues is because these. 548 Alex Mwaura PG&E 02:46:54.425 --> 02:46:58.055 Generation facility that's connected on that distribution system. 549 Alex Mwaura PG&E 02:47:04.535 --> 02:47:06.365 I see skydance hangs up. Go ahead, go. 550 Sky Stanfield 02:47:07.325 --> 02:47:22.115 Yeah, help me with the, the permanent grid modification and the future expansion of the grid. Help me understand how those are specific to the and not just the general. 551 Sky Stanfield 02:47:23.134 --> 02:47:29.824 Um, what, what are you saying that, that how would the cause those 2 scenarios. 552 Alex Mwaura PG&E 02:47:31.654 --> 02:47:39.274 I think those those about applicable projects, um, any, any generation project. 553 Alex Mwaura PG&E 02:47:40.624 --> 02:47:42.814 Cause these issues, um, again. 554 Sky Stanfield 02:47:43.444 --> 02:47:58.594 What are you saying, then, Alex, that you would treat the customer differently in that you would seek trigger, tell them to the value for those 2 conditions and if not, why are they on the list here? 555 Sky Stanfield 02:48:00.574 --> 02:48:07.744 For any project, but what you're saying is that you would reduce, because right. 556 Alex Mwaura PG&E 02:48:08.734 --> 02:48:21.334 So, I wouldn't say it that way, but the, the issue here we go back to the decision it allows the I use to reduce the projects to the. 557 Alex Mwaura PG&E 02:48:21.394 --> 02:48:22.624 I see. 558 Sky Stanfield 02:48:22.834 --> 02:48:42.484 If the ltp is causing the safety reliability issue, we just talked about this on the last slide is the position that even if it's not the profile that the commission is going to allow you to make productions, again, you're just making it even more risky. You guys, you need to draw a distinction between a safety and reliability issue that is caused by. 559 Sky Stanfield 02:48:42.514 --> 02:48:55.924 The profile versus a safety reliability issue that, as we all agree exist for every project today, there's a really critical distinction here. Otherwise you're just making these projects even have a higher risk, but no better. 560 Alex Mwaura PG&E 02:48:58.024 --> 02:49:15.904 See, what you're saying, but so if we use an example of 2 projects that are connected in the same line section, 1 is an project. The other 1 is not and there are issues obviously, we don't know which electrons are getting to causing that issue. Right, because all both these projects are able to export. So. 561 Sky Stanfield 02:49:15.904 --> 02:49:19.144 It would have to be tied to a temporal distinction. 562 Sky Stanfield 02:49:19.294 --> 02:49:19.894 Right with. 563 Yi Li SDG&E 02:49:21.544 --> 02:49:23.374 Uh, this is a. 564 Yi Li SDG&E 02:49:24.275 --> 02:49:44.525 As we're creating a slide, we're trying to tie back to the question advantage division is asking. So I think the bullet that you're pointing to sky you're correct. I think it's over is that we didn't mean to include the permanent grid modification as the condition. That will required on that to be customer to change out, but we have discussed. 565 Yi Li SDG&E 02:49:44.614 --> 02:50:00.544 These scenarios in workshop number 1 that those, if we are doing a great modification, right? We are we know this. Well, ahead of time, we wouldn't really ask them to be customer to reduce. We'll handle that via, like, system upgrades and part of the design. 566 Sky Stanfield 02:50:01.894 --> 02:50:05.464 Is that same for the further? I'm not entirely sure. I understand the. 567 Sky Stanfield 02:50:05.705 --> 02:50:09.395 What the future expansion part is, but it's not the same. 568 Roger Salas SCE 02:50:09.425 --> 02:50:26.465 Yeah, I think the, the last 1 was more to talk about that there's, you know, the, the future lies and large expansion. At least the intent of it was, um, just because we have so many system outages out there or, you know, abnormalities. 569 Roger Salas SCE 02:50:27.154 --> 02:50:47.944 When you're doing a large system upgrade, there may be a need to sort of keep a system in a normal configuration for an extended period of time, you know, you know, months, at a time if you want to collect that. Right? Like, you know, for the winter time, while we do a large upgrade, we may have to reconfigure the system for months in order for us to the system updated. That's what. 570 Roger Salas SCE 02:50:48.004 --> 02:50:50.614 The last 1 was talking about that during that time we may have. 571 Roger Salas SCE 02:50:51.124 --> 02:50:55.414 Reduce the profile during that large expansion of time, right? 572 Sky Stanfield 02:50:55.744 --> 02:51:04.444 No, what would you do if I was a project today, if I was interconnected and you need to do that future expansion the grid how what would, what would you do now? 573 Roger Salas SCE 02:51:06.633 --> 02:51:24.543 Yeah, I mean, that's a good question again haven't gotten to that situation, but I can tell you something that we will not do, you know, if we were to be in that situation, we will not do upgrades to mitigate the fact that we want to be in a temporary condition. 574 Roger Salas SCE 02:51:24.640 --> 02:51:43.025 In order to perform this upgrade. Right. Uh, so so I don't know exactly what we do because we really haven't been in that situation, but I, I don't think that we would do upgrades to to fix the problem for a condition that is temporary in nature like, in months, for instance. 575 Sky Stanfield 02:51:45.305 --> 02:51:45.755 Okay, but. 576 Sky Stanfield 02:51:45.789 --> 02:51:51.904 Again, what I'm trying to get to here, Roger, is why are you saying that you would do that to an customer. 577 Roger Salas SCE 02:51:52.234 --> 02:51:56.464 We'd probably do it to both in this situation could be applicable to both. Right? 578 Sky Stanfield 02:51:56.854 --> 02:52:06.934 So, my request here, is that both with the last slide, though, I think we worked out where you met with the last slide a little bit more, but here we need to. I, I would like. 579 Sky Stanfield 02:52:06.939 --> 02:52:11.224 To see a proposal from the utilities that is a lot more specific. 580 Roger Salas SCE 02:52:11.284 --> 02:52:11.824 On. 581 Sky Stanfield 02:52:11.914 --> 02:52:28.084 What conditions and how you would treat a project an project, where are those conditions are driven by the, the, the profile we need to weed out and make sure the customers understand that they're not actually going to be even greater risk than they would be. If. 582 Sky Stanfield 02:52:28.114 --> 02:52:49.234 Just installed the because what this future expansion and permanent grid modification are is total curtailment, right? Or some version there in. So you're basically saying that even the value isn't captured and that that's untenable. That's not built by the commission, but by the commission order, but also in general, I think we. 583 Sky Stanfield 02:52:49.384 --> 02:53:01.714 You guys understand that, but I don't think we're seeing the language that reflects that understanding and we need to be really clear about what we're saying is going to happen to an customer because of their profile. 584 Roger Salas SCE 02:53:05.284 --> 02:53:07.684 Yeah, I think we can make that clear to me. So. 585 Roger Salas SCE 02:53:09.454 --> 02:53:16.984 Yeah, I think we, I think hopefully, I think with the discussion that we have, we're sort of understanding what we're talking about, which is sometimes this, this. 586 Sky Stanfield 02:53:17.314 --> 02:53:19.804 They're not been in the workshop, right? Yeah. 587 Regnier, Justin 02:53:26.675 --> 02:53:42.545 I guess the question I haven't dove tailing. Sky's point is the only option with currently interconnected static export value generators is to turn them entirely off or lead them entirely on. 588 Regnier, Justin 02:53:43.744 --> 02:53:59.104 On those last 2 bullets, do we have any history where you've had to entirely turn them off to deal with permanent grid modification or future expansion of the grid for, for large system upgrades? Or is this. 589 Regnier, Justin 02:54:01.864 --> 02:54:04.804 Is this just, um, hypothetical. 590 Roger Salas SCE 02:54:05.464 --> 02:54:22.294 No, I don't think monthly permanent. Um, but, uh, I'm sure I don't know. I don't I don't I don't have the data, but I'm sure that there's been situations where we have to cartel generators because we had to switch certain sections. So, circuits to do system upgrades. 591 Roger Salas SCE 02:54:22.744 --> 02:54:26.134 I just don't don't have the data to to show what that is. Um. 592 Regnier, Justin 02:54:26.524 --> 02:54:33.604 I think that's a critical piece of information. So maybe, let's make sure we get that data by the next workshop if we can because. 593 Yi Li SDG&E 02:54:33.634 --> 02:54:43.264 I think that was shared in workshop number 1. I remember that presentation, uh, coming from the reliability metrics, laying out the data. 594 Yi Li SDG&E 02:54:43.624 --> 02:54:52.114 How many times the 21 generator workers held part of a system reconfiguration or fence. 595 Yi Li SDG&E 02:54:54.874 --> 02:54:58.624 Remember that for this week I'm getting mixed up between the 2. 596 Roger Salas SCE 02:54:59.494 --> 02:55:15.874 Yeah, I think it's part of this week, there was a slide about about outages for generators and all those words temporary in nature. They're not permanent, but they have to do with things like a normal condition. 597 Regnier, Justin 02:55:16.025 --> 02:55:16.295 So. 598 Roger Salas SCE 02:55:17.195 --> 02:55:29.495 I don't remember if there was a line item for system upgrade, uh, even mean, you know, you know, determine how we get the data. I'm not sure how we would be able to retrieve the data, but, uh, something we can take a look into. 599 Regnier, Justin 02:55:31.025 --> 02:55:37.025 I mean, if you have an established history of shutting systems down for a day or 2. 600 Regnier, Justin 02:55:37.054 --> 02:55:58.174 When you absolutely have to to complete a large system upgrade, that's that's relevant information. If you've already presented it. If you've already got it and you want to reiterate it in the next workshop fine. But I think I think we should understand what the duration and frequency of that kind of a shut down. 601 Regnier, Justin 02:55:58.205 --> 02:56:02.135 Be, if you want to bring it on the table for this particular discussion. 602 Yi Li SDG&E 02:56:03.695 --> 02:56:19.265 Yeah, just so 1 thing we do want to point out is that, um, we, we are okay with sharing the historical data, but the same time, you know, historical doesn't always represent what's gonna happen in the future. So, we just want to make sure folks are aware of. 603 Yi Li SDG&E 02:56:19.354 --> 02:56:30.274 So you're not going to have the expectation that it hasn't happened previously too often it's never going to happen in the future. Just kind of won't caveat. I want to throw out. 604 Regnier, Justin 02:56:34.264 --> 02:56:40.894 I don't think anybody is under the impression that we can perfectly predict the future understanding best practices and. 605 Sky Stanfield 02:56:41.464 --> 02:56:53.104 But that's also why we need to find a way to cap risks because customers have no visibility into what how likely it is to happen in the future. Especially when utilities are added caveats like that. 606 Alex Mwaura PG&E 02:57:18.364 --> 02:57:20.734 All right 1 more question is this is this where you take over. 607 Yi Li SDG&E 02:57:23.074 --> 02:57:25.324 I think I have few more slides Alex. 608 Alex Mwaura PG&E 02:57:25.444 --> 02:57:25.894 Okay. 609 Alex Mwaura PG&E 02:57:27.065 --> 02:57:27.575 Next slide. 610 Alex Mwaura PG&E 02:57:34.804 --> 02:57:41.884 So this is a continuation of topic number 3, the process, the, how to reduce the customer's excuse me? 611 Alex Mwaura PG&E 02:57:46.385 --> 02:58:04.985 All right, so when are deemed necessary, I used envision utilizing contact information to inform them to inform the customers, or we need to change the operating profile. So, if a customer is enabled to make those changes, and customers will be required to disconnect from the system. 612 Alex Mwaura PG&E 02:58:05.134 --> 02:58:06.784 Such time that they can make the change. 613 Alex Mwaura PG&E 02:58:07.899 --> 02:58:29.044 And then will require confirmation that the changes have been performed. Some examples to consider I use we'll notify customers in writing as soon as safety and reliability issues result in the need to temporarily adjust does not include the emergency conditions. Because obviously, if it's an emergency condition, we have to take whatever action is needed to maintain. 614 Alex Mwaura PG&E 02:58:29.374 --> 02:58:50.194 Reliability, and they may not be enough time to notify customers temporary changes will now require a new interconnection agreement. We may have to update the update to the attachment may be needed update to the interconnection agreement may be needed by an attachment it will be. The customer's response. 615 Alex Mwaura PG&E 02:58:50.199 --> 02:59:11.164 Ability to engage authorized personnel to implement the changes within customer's power control system. And then I reserve the rights to request proof of the updated profile. Implementation process would be normalizing the appropriate Internet connection agreement as I mentioned before it may be an update to the. 616 Alex Mwaura PG&E 02:59:11.375 --> 02:59:17.675 Connection agreement by an attachment and then notifications for plant maintenance and system upgrades. 617 Alex Mwaura PG&E 02:59:20.373 --> 02:59:40.953 The requirements, notifications with planned maintenance system upgrades will be set in the interconnection agreements E, notification in advance. We would have to notify customers in advance that we're planning to make those changes all other drivers. Implementation would be required with subsequent. 618 Alex Mwaura PG&E 02:59:40.984 --> 02:59:42.724 The information provided to the customer. 619 Alex Mwaura PG&E 02:59:51.245 --> 02:59:51.965 Go for. 620 Sky Stanfield 02:59:52.685 --> 03:00:07.835 Hi, Alex. Um, okay, so a couple things here so on, um, when the notify the customers as soon as the safety reliability issue results, um. 621 Sky Stanfield 03:00:09.755 --> 03:00:30.305 Either to do a temporary or a longer term change I think we might want to get a little bit specific about what information the utility will provide to the customer that demonstrates along with the theme for the last 3 slides that the safety reliability issue is driven by the profile. 622 Sky Stanfield 03:00:30.723 --> 03:00:51.453 Um, otherwise again, the customer needs to be have some, some certainty in the commission important, most importantly, potentially also needs the certainty that the reductions that are being asked for are driven by the profile itself. So, I think figuring out how you're going to demonstrate that and document that that's. 623 Sky Stanfield 03:00:51.484 --> 03:01:12.304 What the driver is, and that would be helpful. Um, I don't know what that looks like. Exactly. So, it's something you guys might need to think about, but I think Eric would feel like it needs to be documented. That that is the reason why they your a** being asked to curtail. Um, and then. 624 Sky Stanfield 03:01:12.754 --> 03:01:33.754 Let's see, I guess the, the idea of this modification of the interconnection agreement is giving me some making me wonder, like, so say that the, the customer's profile is reduced has to be reduced because there was like a modest reduction in. 625 Sky Stanfield 03:01:34.235 --> 03:01:50.045 In the load on the circuit, but that we don't know if that modest reduction is going to be permanent or not say it happened for 1 season because of business was go undergoing renovations or something like that. I don't want to get too hypothetical here, but. 626 Sky Stanfield 03:01:51.845 --> 03:02:11.825 I'm wondering if W, at what point, we know that those reductions are do need to be permanent as opposed to something that will change over time. It seems to me, like, the only way we're going to know that they're permanent is when it's a major change and I don't know that I have a huge problem at least an initial. 627 Sky Stanfield 03:02:11.854 --> 03:02:22.864 Age of locking this in, but it does suggest that we're basically saying we're not giving any opportunity for the customer to get back to their original profile. Right? 628 Alex Mwaura PG&E 03:02:26.344 --> 03:02:45.244 I would say so, if we have a location or project that has a permanent reduction, and the reduction is, we realized in the, I don't see a mechanism through which they would be able to go back. Unless obviously, you know, if there's upgrades that happen on the grid, and somehow the customer, you know, knows about it. 629 Alex Mwaura PG&E 03:02:45.670 --> 03:02:57.755 I would sort of be the process, but I personally don't see, I don't see any way that they would be able to go back. So, if it's permanent, that would mean that that would be moving forward. That would be the new limit. 630 Sky Stanfield 03:02:58.205 --> 03:03:03.695 How do you so help me understand how do you draw the line between when you guys would decide something is permanent? 631 Alex Mwaura PG&E 03:03:05.195 --> 03:03:06.725 I think he has to go back to. 632 Alex Mwaura PG&E 03:03:06.904 --> 03:03:27.784 The chairman has to go back to the to the cost and if it's, you know, obviously a significant cost to the repairs, then to bring the customer back to their profile versus it's your limit, then that's something that I use obviously reserve the right to make that decision and opposition at this point, is that. 633 Alex Mwaura PG&E 03:03:27.970 --> 03:03:37.085 Will probably not do those upgrades and would rely on the, you know, what's allowed under the decision to go to be able to go back to the value. 634 Sky Stanfield 03:03:43.774 --> 03:04:00.304 Okay, I think this is something that's going to I just need to think more about because it does, I think again, as this additional layer risks WH, what we were talking about, if a customer knew that, okay, I might just be reduced for a few hours a year or whatever, but if you were saying. 635 Sky Stanfield 03:04:01.024 --> 03:04:21.484 As soon as we hit that potential for an upgrade costs that it's going to be a permanent reduction that adds quite a bit more financial risk to the customer. And I don't know the exact way to work around it but it does add some makes it even. I think even less likely someone's going to do this, if they're sure that the those reductions would be. 636 Sky Stanfield 03:04:21.574 --> 03:04:22.384 Permanent. 637 Alex Mwaura PG&E 03:04:33.845 --> 03:04:34.535 Great Justin. 638 Regnier, Justin 03:04:36.335 --> 03:04:52.565 So, I got a few thoughts here. My, my original was just a very simple on the last sub bullet of the 2nd bullet. I use reserve the rights to request proof of the updated profile, given the evolution. 639 Regnier, Justin 03:04:52.654 --> 03:05:13.714 Of using data and telemetry data to verify the profile. I would just throw out there that maybe attestation is a more appropriate word than proof here. So, reserve the right to request an attestation that the updated profile has been implemented, I think might be as far as we want to go there. If you've already got. 640 Regnier, Justin 03:05:13.745 --> 03:05:34.865 The ability to independently verify and maybe it's not even needed at this point. Um, we were talking about and Alex was was mentioning the determination may be made by balancing or by looking at the cost of the upgrade required. And then we just note that maybe we want to be. 641 Regnier, Justin 03:05:34.869 --> 03:05:56.014 Balancing the cost of the upgrade, and as we were talking with Eva, the revenue impacts to the customer this is a point that was made by Rogers and others in the last workshop that, you know, a very expensive upgrade for a very minimal increase in output is something that. 642 Regnier, Justin 03:05:56.074 --> 03:06:17.164 They're not seem to do so, maybe some process for balancing costs and benefit is warranted, um, in terms of what sky just mentioned and elements in the, the notifications. I don't know if it's feasible to put a maximum duration of reduction in there. Um. 643 Regnier, Justin 03:06:17.195 --> 03:06:38.285 It's worth considering if it's feasible, because that goes back to the certainty and finally, and if we've got kind of discretion on how we look at this, my gut response is, if we can not muck about with the interconnection agreement, if we can expand the interconnection. 644 Regnier, Justin 03:06:38.319 --> 03:06:59.434 Agreement language to encompass the foreseeable conditions. That would be preferable just because we've had common law, common contract law for a long time, and it seems to be working on. Right? And I just get a little leery at telling the interconnection customer that we can go back. And. 645 Regnier, Justin 03:06:59.494 --> 03:07:11.134 Unilaterally change legally binding contracts if we can get all the conditions into the contract and leave the contract in place. It seems like a safer approach. That's all I've got and I see sky comes back up. 646 Sky Stanfield 03:07:14.225 --> 03:07:16.025 I just haven't left it up. Sorry, Justin. 647 Alex Mwaura PG&E 03:07:20.554 --> 03:07:39.874 Thanks Justin. That's a good point. So yeah, so we may require and the proof could be an, a discussion from the customer saying, here's my new profile. Right? So, because the verification process is is based on historical steps. So we're verifying after the fact. So, what we would want to know. 648 Alex Mwaura PG&E 03:07:40.654 --> 03:07:53.794 You know, through some means, or nowadays that the profile is gonna be below whatever, whatever profile would, you know, the timing. Right? And then obviously we could go back and verify after the fact by. 649 Regnier, Justin 03:07:55.924 --> 03:08:05.584 So it's like a day after the fact, if we need more, if we need faster response, then we can, we can have that discussion. But I don't know if we've established that need. 650 Alex Mwaura PG&E 03:08:10.534 --> 03:08:11.464 Any other questions. 651 John Berdner Enphase 03:08:14.884 --> 03:08:33.904 Yeah, Alex, this is John. It's more of a comment, um, sky had said if it and I think it follows up on what Justin just said. Um, Scott had used the term if it's going to be a permanent condition and, you know, I think permanent. 652 John Berdner Enphase 03:08:34.234 --> 03:08:55.024 Obviously, there's no way to know whether a condition is permanent or not, particularly with departing load. So, could we perhaps get a little bit more clarity there? If you can estimate a schedule for mitigations. 653 John Berdner Enphase 03:08:55.114 --> 03:09:09.544 Or it's not possible to mitigate a schedule, not possible to create a schedule to mitigate the condition something along those lines because saying something permanent. I think nobody's crystal ball. 654 Alex Mwaura PG&E 03:09:16.565 --> 03:09:33.155 Yeah, that's a good point. Yes. Yes I guess what I was trying to say is that we wouldn't so let's say the scenario where, you know, a large customer decides to close the plant. Um, you know, could another customer come back in the future and take that location and, you know, bring back the load to the previous. 655 Alex Mwaura PG&E 03:09:33.215 --> 03:09:53.795 Probably, but again, just like, we would not know, we would not know when that's gonna happen. So may happen in months or years, or, you know, several years. So there's no knowing. Uh, and I don't know how we can. I'm not sure what we can discuss this further obviously, but I'm not sure how we would. 656 Alex Mwaura PG&E 03:09:54.333 --> 03:10:09.753 Who would even keep track of this issue and kind of mention we'll bring it up to the at some point and say, oh, now we have a new customer, the loads app. So, we can go back and readjust these customers, which I think is kind of what you're suggesting. 657 John Berdner Enphase 03:10:11.073 --> 03:10:15.453 Yeah, and I, I think there should be a determination. 658 John Berdner Enphase 03:10:15.514 --> 03:10:36.604 Been made if the date is doable or not doable and, you know, clearly there could be things that are not doable but in my mind, it's not permanent or not permanent. It's about whether a date that a mitigation could be. 659 John Berdner Enphase 03:10:37.204 --> 03:10:46.714 Is notable, or is not doable so somehow make that distinction because, like you said, it may not be. 660 Alex Mwaura PG&E 03:10:49.384 --> 03:10:51.844 That's fair we'll go back and discuss this. Thank you. 661 Regnier, Justin 03:10:58.444 --> 03:11:03.844 Maybe maybe a threshold for reassessment, rather than trying to get to perfect prediction. 662 Alex Mwaura PG&E 03:11:07.684 --> 03:11:07.924 Okay. 663 Alex Mwaura PG&E 03:11:10.294 --> 03:11:12.454 I don't see any more hands up. So next slide please. 664 Alex Mwaura PG&E 03:11:15.545 --> 03:11:35.255 This is a continuation of topic. Number 3 I use identify condition an acceptable voltage Tom overloads. So this could be violations that are detected on a planned basis or violations that are detected near, or in real near, or in real time near real time. In real time. 665 Alex Mwaura PG&E 03:11:36.334 --> 03:11:56.974 So is for unplanned outages or planned basis I should say I use perform planning analysis ahead of time including path flow analysis to identify, anticipate collisions and possible remedies. I use a evaluate potential. No cost options, such as switching. 666 Alex Mwaura PG&E 03:11:56.979 --> 03:11:57.964 Additional loading today. 667 Alex Mwaura PG&E 03:12:00.034 --> 03:12:06.844 When no, no cost options are valuable. I use provide customer in writing a reduced export level for each month. 668 Alex Mwaura PG&E 03:12:08.260 --> 03:12:29.375 New schedule, and then I also provided written description of the cause of the problem, and the reason for the export reduction and then for things that will happen near or in real time I use will investigate the issue to take immediate action, depending on the situation could be immediate action may include bubble direction. 669 Alex Mwaura PG&E 03:12:29.410 --> 03:12:43.775 To reduce export or remote customer disconnection in extreme cases, or if initial robot direction not followed, or further communication in the situation and mitigation plans will be coordinated between you and the customer as appropriate. 670 Alex Mwaura PG&E 03:12:49.684 --> 03:12:50.524 Any questions. 671 Alex Mwaura PG&E 03:13:00.004 --> 03:13:03.844 Okay, I'll go ahead and send it over to you to go over the next slides. Thank you. 672 Yi Li SDG&E 03:13:05.494 --> 03:13:18.754 Thanks Alex. Everyone here. Sorry. I'm kind of still struggling with a some sort of a preschool virus. Um, my voice is typically a little more cheerful. 673 Yi Li SDG&E 03:13:18.995 --> 03:13:22.565 Apologize for that next slide please. 674 Yi Li SDG&E 03:13:26.074 --> 03:13:45.544 Uh, so, this topic, we were hoping to, uh, provide some of the ltp reduction circumstances per request, uh, from the stakeholders and energy commission. So, I believe we have already talked about these in previous slides and some of the workshop 1 discussion but here, we're listing. 675 Yi Li SDG&E 03:13:45.934 --> 03:14:06.634 2 scenarios, the 1st scenarios is around the low reduction. So the underlying concern here for a little reduction is that when we have a large reduction in low emit limits available capacity and raises concern, but possible violations associate with system voltage. 676 Yi Li SDG&E 03:14:06.874 --> 03:14:27.814 Thermal limits, and the triggering condition could be a solution. No expert generation or just a big low reduction. For example, someone brought up during the workshop number. Why? When we have a plant closing kind of a large load given away on a circuit and the parameters. 677 Yi Li SDG&E 03:14:27.850 --> 03:14:48.965 Here that we laid out would be that for the, we will need to reevaluate the level of ltp, which, uh, reduced underlying concern to acceptable level and provide the customer and schedule based on the maximum allow expert from the to maintain the voltage or symbol limits where they will. 678 Yi Li SDG&E 03:14:49.594 --> 03:15:04.504 Well, they come in reading limits, uh, in the scenario reduction will last until the issues resolved, as we discussed in workshop, 1, the mitigation may be a non cost. 679 Yi Li SDG&E 03:15:04.535 --> 03:15:15.785 Which may occur very quickly, for example, some operational switching or a quick fix in the field typically less than a month or low cost solution. 680 Yi Li SDG&E 03:15:15.904 --> 03:15:36.694 Description of vitality, which we all have to evaluate and based on each individual case, moving onto the 2nd scenario, which is around emergency conditions and plan outages. The underlying concern here is emergency grid conditions as a result of. 681 Yi Li SDG&E 03:15:36.964 --> 03:15:42.484 Can just send just so you want, do you have a question on scenario? 1 you want to raise. 682 Regnier, Justin 03:15:44.884 --> 03:15:47.164 Yeah, but go ahead and finish too. Well, we can go back. 683 Yi Li SDG&E 03:15:47.584 --> 03:15:57.994 Oh, okay. So, um, the underlying concern is a motion secret condition, uh, as a result of fault condition or plan outages that. 684 Yi Li SDG&E 03:15:58.294 --> 03:16:19.234 Risk a possible issue with the voltages where it comes thermal limits. The triggering condition is kind of similar to the underlying concern here. And the primary is a customer will need to cartel to 0, export until further notified by reduction will only last for a tuition of the emergency or plant outage. 685 Yi Li SDG&E 03:16:19.264 --> 03:16:39.814 Is, uh, until you provides customer notification that it may resume normal operation just similar to what Alex is present on the last slide for these curtailment emergency curtailment will have to actually work with a customer to store the can be done as quickly as possible and. 686 Yi Li SDG&E 03:16:40.390 --> 03:16:42.545 1, only lasts for the tuition of the. 687 Roger Salas SCE 03:17:09.215 --> 03:17:10.865 Did we lose lead or. 688 Aliaga-Caro, Jose 03:17:12.665 --> 03:17:20.225 Okay, I think we did. All right I thought it was just I was just about to us, whether we're just me or everybody else. 689 Roger Salas SCE 03:17:23.824 --> 03:17:25.924 You know, a minute, I think we might have lost the. 690 Roger Salas SCE 03:17:54.755 --> 03:18:06.035 It looks like, uh, looks like she's having, uh, technical problems so let's just continue. I think she was in scenario 2, right? Uh, sure, exactly where she left off. Um. 691 Roger Salas SCE 03:18:07.833 --> 03:18:12.813 I mean, I think we already generally spoken about this term. Oh, it looks like you're back in. 692 Roger Salas SCE 03:18:16.564 --> 03:18:16.984 Go ahead. 693 Roger Salas SCE 03:18:21.304 --> 03:18:22.714 You're a mute I think. 694 Regnier, Justin 03:18:36.305 --> 03:18:37.715 Sorry, I believe you're on mute. 695 Regnier, Justin 03:18:49.414 --> 03:18:50.464 Maybe a double mute. 696 Aliaga-Caro, Jose 03:19:17.404 --> 03:19:19.084 Still mute it, but. 697 Aliaga-Caro, Jose 03:19:24.035 --> 03:19:24.485 Sky. 698 Regnier, Justin 03:19:25.325 --> 03:19:26.615 Delegate sorry. 699 Roger Salas SCE 03:19:27.335 --> 03:19:42.215 Yeah, okay. Um, so so, yeah, well, let's just continue. So, Scott, I think to your question yeah, this would be for scenario to again will be the same for L. G. P. and so it's an emergency. 700 Roger Salas SCE 03:19:42.279 --> 03:20:00.754 Conditions planned outages. Whatever may be. I think we discussed in several times already that that it's it's really for, um, it's applicable to both. And, uh, is that does that clarify your question? 701 Sky Stanfield 03:20:00.934 --> 03:20:03.424 Yeah, I just wanted to make sure that we were clear the. 702 Sky Stanfield 03:20:03.455 --> 03:20:20.795 Customers weren't going to be called out, you know, when you guys are going to have depends on what the condition is. How many generators you may need to ask disconnect and so on I assume, but the LGB customers aren't going to be treated differently in those conditions on scenario. 1. they might be scenario 2. 703 Roger Salas SCE 03:20:21.095 --> 03:20:21.935 And never have you right? 704 Roger Salas SCE 03:20:23.255 --> 03:20:28.955 Sounds good or any. I think this was covered already any other questions on this slide. 705 Regnier, Justin 03:20:32.345 --> 03:20:52.745 I just had a little concern on scenario, 1, last sentence of the mitigation maybe and I are, you know, cost solution, which may occur quickly or are you low cost solution at discretion of the utility? My, and we can go back to the tape. But my recollection was that the yeah, I used. 706 Regnier, Justin 03:20:52.804 --> 03:21:09.004 We're just going to do low cost mitigations so I'm not I'm a little, not understanding why we're talking about it being at a, at the discretion of the utility sort of thing. 707 Regnier, Justin 03:21:13.204 --> 03:21:15.154 Has to go in the planning process, but yeah. 708 Roger Salas SCE 03:21:16.384 --> 03:21:32.254 Yeah, I mean, I think it goes all goes back to the discussion of what are we require when when and how are we when, how are we required to perform system upgrades to. 709 Roger Salas SCE 03:21:32.260 --> 03:21:51.845 Store the original, um, you know, assuming that we're not requiring. Let's just for a 2nd assume. That's that's the that's the, where we end up then that should not prohibit any utility to their own discretion and say, you know, why wouldn't we do this upgrade? Because it does have other benefits. That's what what you're saying. 710 Regnier, Justin 03:21:55.415 --> 03:22:03.515 For sure, um, yeah, 1, how, and if those are, that's that's useful framing. Yeah. Um. 711 Sky Stanfield 03:22:03.545 --> 03:22:14.405 Doesn't this also kind of go back to what we were just talking about on the last slide about? I guess I'm a little confused about when it's so it says that the. 712 Sky Stanfield 03:22:14.583 --> 03:22:18.783 Reduction with last until mitigation is resolved so. 713 Sky Stanfield 03:22:21.694 --> 03:22:41.194 If we're gonna require the update to the interconnection agreement, what you were suggesting is, is that it would be permanent right? Am I not my, I don't know if on the last slide you would distinguish between mitigations versus are you saying here that you wouldn't require an interconnection agreement change? 714 Sky Stanfield 03:22:41.405 --> 03:22:48.095 Where you were, it just took you time to implement the low cost mitigation is that the distinction. 715 Roger Salas SCE 03:22:49.805 --> 03:23:02.105 That may be the case, right? I mean, if, if we know that this, you know, an example, would be new change the regulator settings or. 716 Roger Salas SCE 03:23:02.614 --> 03:23:20.704 Or whatever is that we need to do that is low cost then there's no need to update the interconnection, uh, in the condition agreement for that. Right? It's something that's gonna be, hopefully short term, and we just need to get that done, um, as opposed to something that may take much longer, uh, years potentially. 717 Sky Stanfield 03:23:21.154 --> 03:23:23.614 Right. So really what what a scenario. 718 Sky Stanfield 03:23:23.649 --> 03:23:44.794 1 needs to be broken into 2 separate a different scenario, or a sub scenario. 1 is where there is a low cost mitigation, and 1 is where there is. No right. And what would happen in each 1 would trigger the need for. But we definitely need to build into the, even the 1st scenario where there is a mitigation to make sure the customer knows. 719 Sky Stanfield 03:23:44.824 --> 03:23:55.114 That there would be some temporary reduction of their profile while that mitigation was implemented. And then if there was no mitigation that it would be a permanent reduction. 720 Roger Salas SCE 03:23:57.514 --> 03:24:05.344 Yeah, I mean, I think we need we need to be a little more specific as to what permanent means in this in this scenario. So yeah. 721 Yi Li SDG&E 03:24:06.664 --> 03:24:10.834 Yeah, I, uh, can you guys hear me now? Just curious. 722 Sky Stanfield 03:24:11.854 --> 03:24:12.334 Yep. 723 Yi Li SDG&E 03:24:12.424 --> 03:24:17.284 Oh, perfect. Sorry about that. Just happened. Not sure what happened. 724 Yi Li SDG&E 03:24:18.665 --> 03:24:39.665 I don't think we're married to the idea of changing the at the stage right? Cause, you know, limited solution profile can also be see attachment or it can be a separate file. Just like the whole maintain charging schedule. We need to think more about, you know, how it's going to happen. 725 Yi Li SDG&E 03:24:40.174 --> 03:24:52.414 For emergency conditions, like Raja was saying, it's not going to be permanent. We may not need to change that schedule just for something that changed for, like, a few hours. 726 Sky Stanfield 03:24:53.224 --> 03:25:00.874 And under the emergency conditions, the should already covered that because that's a condition applies to any project. Now, is what we've been saying. 727 Sky Stanfield 03:25:00.939 --> 03:25:01.329 Right. 728 Sky Stanfield 03:25:02.885 --> 03:25:08.705 I should already have provisions and I haven't looked back to see what they do have, but that allow that emergency. 729 Yi Li SDG&E 03:25:11.075 --> 03:25:11.795 Oh, yeah. 730 Sky Stanfield 03:25:11.795 --> 03:25:12.215 Talking. 731 Yi Li SDG&E 03:25:12.215 --> 03:25:23.465 Different things, right we're talking about the provision to allow for the versus the actual, like, the different number right? Different sets of number. So when we say upgrading. 732 Yi Li SDG&E 03:25:23.499 --> 03:25:34.534 Hey, we're also referring to if we're going to have a different schedule, we need to have a record between now using the customer where the schedule is as currently stand. Right? 733 Yi Li SDG&E 03:25:43.953 --> 03:25:46.443 Uh, any further question on the slide. 734 Yi Li SDG&E 03:25:56.224 --> 03:25:58.174 All right, can we go to the next slide please. 735 Yi Li SDG&E 03:26:03.275 --> 03:26:21.305 So, the next slide is, we're starting start to get into some of the topics that were brought up in the last workshop, but I relatively kind of continue to consider to be out of scope for 5,211. so we wouldn't really, necessarily include these items in the. 736 Yi Li SDG&E 03:26:21.333 --> 03:26:41.883 Will be drafting a submitting in January, but, uh, we still want to have a discussion given stakeholders that have question and there has been comments and discussion around these topics. So, starting with the topic number 5 around the schedule. So we receive a question. Go ahead. 737 Regnier, Justin 03:26:46.055 --> 03:26:48.845 Sorry, I can just go at the end of it. Please. 738 Yi Li SDG&E 03:26:49.775 --> 03:26:54.695 I was just going to read the question from India division anyway, so go ahead. 739 Regnier, Justin 03:26:59.073 --> 03:27:03.873 Sorry, I just I wanted to follow up on the question that Alex had last time. Um. 740 Regnier, Justin 03:27:10.204 --> 03:27:26.164 So, we've got 2 professionals working here so the question Alex had had to do with getting back to us on costs, as opposed to time frame for implementation on different schedule options. I want to clarify that the cost questions in terms of. 741 Regnier, Justin 03:27:26.195 --> 03:27:47.315 Upgrades are looking to be addressed in phase 2 what we have in front of us here, the design of different policy options and understanding of the timelines required for their implementation, appreciate Alex's question and have some empathy. Because in the last workshop, I was sick and just couldn't quite. 742 Regnier, Justin 03:27:47.343 --> 03:27:50.403 Get the answer together in time, so I hope you're feeling better soon. 743 Yi Li SDG&E 03:27:56.345 --> 03:28:14.105 Thanks, Justin, um, getting back to, uh, the slide here uh, we, we see the question around addressing the format of the schedule to be submitted to allow a 288 hours profile. So it's a long flexible. 744 Yi Li SDG&E 03:28:14.109 --> 03:28:35.254 For more granularity, and we're also asked to address how this will simplify and streamline a customer's experience, as opposed to filling out manually the value in the portal. So, I believe we have had this discussion heavily in the last workshop, but just to reiterate that I will use views still that. 745 Yi Li SDG&E 03:28:35.259 --> 03:28:56.404 This is only requires 12 hours. We are pasting the decision language here, which is resolving the issue number 9 from the working group. 2 slash 3 accordingly. We adopt utilities counterproposal to resolve issue 9 with the modification to allow the frequency of changes to be mostly versus. 746 Yi Li SDG&E 03:28:56.435 --> 03:29:11.585 Seasonal, so, you know, as punched out here, this already takes advantage of the into cash and capacity analysis, allowing customer to establishing schedule. I'll put some lines issue. 9 proposal with the. 747 Yi Li SDG&E 03:29:12.845 --> 03:29:33.065 Further as described below allowing a customer to establishing mostly schedule output, limited strikes of balance between the proposed schedule, and the more conservative season schedule recommend in a counter proposal. So, friar's perspective there was enough discussion part of the working group tail and also subsequently. 748 Yi Li SDG&E 03:29:33.363 --> 03:29:54.213 Matching the decision that, uh, you know, it was adopted a, uh, sort of the middle ground between what was proposed by the, which is the seasonal schedule, versus what was initially proposed by the stakeholder, which is the hourly schedule. So, the decision clearly outlined that what's being adopted is the mostly schedule, which is the. 749 Yi Li SDG&E 03:29:54.245 --> 03:30:15.365 Of hours, instead of 288 hours as to the question on how customer is going to handle and submit the values we discussed this briefly in the last workshop as well on. Our initial thought is that customer will be. 750 Yi Li SDG&E 03:30:15.544 --> 03:30:36.514 I see profiles from the portal that each I'll use separately, maintain and determine and calculate the algae P values for each month. We provide a similar kind of example, to the rights. We don't believe it's going to be a really too much difference between style you and lastly, we believe the customer. 751 Yi Li SDG&E 03:30:36.519 --> 03:30:57.364 We'll be providing the in the portal based on utility portals capability. So, uh, each style use, depending on where we will be implementing this. Um, and kind of a, how long will be given to implement these capability uh, the ability for a customer to submit the portal will really be, depending on each. 752 Yi Li SDG&E 03:30:57.695 --> 03:31:08.075 Use capability I see a few hands up on. Was it Justin who raise your hands? 1st do you want to go? 1st? 753 Regnier, Justin 03:31:09.215 --> 03:31:10.085 Parties can go 1st. 754 Younes, Amin 03:31:13.834 --> 03:31:32.914 All right, I guess that's me. Um, so I, I guess my my point here is relatively minor, but I know that there's some disagreement over this interpretation and I think that it will be, I believe it's kind of in scope for the next set of workshops to debate this issue not this 1, um, whether whether it's. 755 Younes, Amin 03:31:32.920 --> 03:31:38.855 Complete versus hourly um, but I think that in the absence of having a. 756 Younes, Amin 03:31:40.265 --> 03:32:01.115 Kind of mentioned this earlier, but in the absence of having an agreement on that issue, we should move forward with a, with a data format that would enable either option to work. Should we decide which of the commission clarify? What exactly they meant by that? Um, by their statements, so, even though even though I actually. 757 Younes, Amin 03:32:01.119 --> 03:32:20.134 They tend to agree with the interpretation of the based on my reading of the of the language. I think it that is not the data format that I think we should go. I think we should go with the other data format that would allow hourly values. So that we don't preclude that option or make that too difficult down the road. If if that is the direction of the commission. 758 Yi Li SDG&E 03:32:22.534 --> 03:32:43.414 Uh, before moving on, just I just want to understanding your point a lot more. Are you saying that we would adopt the 12 limits? But the submission should be 280 values but basically, for that entire months, all these Valley needs to be below the limit as adopted by the decision is. 759 Yi Li SDG&E 03:32:43.445 --> 03:32:44.555 What you're recommending. 760 Younes, Amin 03:32:45.185 --> 03:32:59.795 I guess I'm saying that we should look the data format 88 points now, and then we can decide later whether or not the 1224 values in each month, has to be the same or not based on based on what the commission can, uh, put forth later. Does that make sense? 761 Aliaga-Caro, Jose 03:33:01.295 --> 03:33:04.565 Yeah, I think, I mean, uh, you were driving the point that I've been. 762 Aliaga-Caro, Jose 03:33:04.593 --> 03:33:25.563 Trying to drive along in this discussion, which is what John partner and Bryan have been, uh, you know, also trying to discuss is the 288 profile per, which the decision does a state that's required. And not just 12 values has shown here but. 763 Aliaga-Caro, Jose 03:33:25.745 --> 03:33:37.145 So, a standard format to submit those values, that is a, you know, the startup standard. 764 Aliaga-Caro, Jose 03:33:39.875 --> 03:33:51.005 And by format, I don't mean typing it into the, to the portals. I made an actual file that you generate, and, you know. 765 Aliaga-Caro, Jose 03:33:52.564 --> 03:34:10.294 Submit to the utilities, but it's the same file format across the 3 utilities and I do not know if John burner or Brian seal are on the call at the moment. But this is 1 of their, uh, their proposed topics. 766 John Berdner Enphase 03:34:15.665 --> 03:34:18.185 Yeah, Jose, John's on a call. 767 Aliaga-Caro, Jose 03:34:18.215 --> 03:34:19.325 Okay all right. 768 John Berdner Enphase 03:34:21.905 --> 03:34:26.345 Yeah, I mean, I think you, you've covered it. Um, well. 769 John Berdner Enphase 03:34:27.759 --> 03:34:38.434 We are looking at implementing a schedule based on 288 values and which we've talked was consistent with. 770 John Berdner Enphase 03:34:40.744 --> 03:35:01.414 Silence, but it seems that that unusual that you would have 288 values, which consisted of 12 sets of values, repeated 24 time. So the schedule that we're developing, the PCs work. 771 John Berdner Enphase 03:35:01.625 --> 03:35:22.745 Would support 288, unique values beyond that. I don't know what else you would you would like to say, like me to say the schedule certainly goes 1 implementation would be 24 hour a day for each. 772 John Berdner Enphase 03:35:22.774 --> 03:35:43.894 Define month schedule could be implemented that way, but the schedule that we're developing, and the PCs work is more flexible than can consider day a week as well as time of day. So, it's, it's quite a bit more flexible than what's being proposed in the. 773 Aliaga-Caro, Jose 03:35:47.855 --> 03:35:50.885 Yeah, uh, thank you, John. Uh, um. 774 Aliaga-Caro, Jose 03:35:51.394 --> 03:36:12.094 And this is, uh, per the, uh, I believe in the original guidance document, that energy division provided the utilities uh, you know, this is 1 of the issues we wanted to raise and I think this is the 1st time that it's been made clear, both by John. And by Maine. 775 Aliaga-Caro, Jose 03:36:12.455 --> 03:36:28.415 You know, the 288, uh, profile would allow more flexibility, uh, you know, shoot the commission, decide that, you know, we need more granularity either now, or in the future. 776 Roger Salas SCE 03:36:34.985 --> 03:36:51.575 And I think that's a different topic of yeah, me to what John is working on with the team is enough essentially a very flexible schedule that can be implemented. That doesn't necessarily mean that this decision. 777 Roger Salas SCE 03:36:51.603 --> 03:37:12.723 And directed as to implement a very flexible schedule. I mean, at least from our view is that the commission adapted the utilities counter proposal, which is a monthly value 1 value per month, whether it's 1 value per month, showing the table here or whether it's 1. 778 Roger Salas SCE 03:37:12.754 --> 03:37:33.214 Core values that are the same for that month. Um, that that, that I think that that can be discussed but, for our view is that the utility commission adopted our counterproposal that is 1 value, uh, with modification to be 1 value per month. If that if the commissioning cut intended to. 779 Roger Salas SCE 03:37:33.904 --> 03:37:55.024 Use to unique values, then they would have adopted the proposal because the 99999 now, your proposal is exactly that and adapt the non proposal. And so, for our view is the fact that they adopted the utility proposal indicates that is 1 value per month. 780 Roger Salas SCE 03:37:55.054 --> 03:37:56.284 These repeated values. 781 Alex Mwaura PG&E 03:37:58.504 --> 03:38:16.174 Yeah, I, I agree with Roger 100. I think that's a, that is the accurate, uh, interpretation and I also like to point out that, you know, just I've sent the issue with, you know, the system potential system issues with having, you know, more more than 24 values. 782 Alex Mwaura PG&E 03:38:16.205 --> 03:38:37.325 Like, as far as like, safety reliability issue, there's also this implementation, you know, it's much more complex to accept 208 values versus, you know, have a table with 2012 hours. Right. Because now, as we've talked about in the last discussion, it doesn't make sense to have, you know, potential. 783 Alex Mwaura PG&E 03:38:37.353 --> 03:38:58.443 Input to 88 values in a form, it would make sense for them to submit a file and then the utility systems, which you're trying to automate these processes and application process and steady process obviously because we want to make sure that we stay within the timelines by the carrier. 784 Alex Mwaura PG&E 03:38:58.504 --> 03:39:10.924 Doing these studies, and the more we can automate the process, the more likely we're able to stay within the timelines, the more accurate the studies are going to be it's going to be much more complex if we have to accept the file with 288 values versus, you know, 24 values. 785 Aliaga-Caro, Jose 03:39:14.194 --> 03:39:18.754 Thank you and sky and then just didn't have the risk. 786 Sky Stanfield 03:39:22.954 --> 03:39:28.384 Yeah, I just had like, maybe a simpler question. I'll say that I do agree that. 787 Sky Stanfield 03:39:29.524 --> 03:39:50.644 Working on a 288 hour profile simplifies future pause and it seems a little bit strategic for the utilities to say they won't talk about it now, but let's put that aside because I think you guys covered that amply. I just wanted to ask Yogi who's actually sitting here with me in person today, which is a setting. 788 Sky Stanfield 03:39:50.675 --> 03:40:11.795 About that yeah 1 of the main things that needs to happen is that there needs to be some consistency in the last 2 bullets identify that that there will be some variation, depending on the portal capabilities. I'm wondering if you guys have identified portal capability, differences that would drive a difference. 789 Sky Stanfield 03:40:11.824 --> 03:40:32.944 Or, if you're just trying to reserve some, some unknown differences, because I think the consistency is important, and we would want to learn a little bit more about why what the capability problems are. If we were going to have some inconsistent format for ease of tracking the data for the. 790 Sky Stanfield 03:40:32.974 --> 03:40:34.714 The customer submitting the portal, et cetera. 791 Roger Salas SCE 03:40:39.274 --> 03:40:55.474 Well, let's let's start with the fact that we have 3 different roles right? I mean, his utility has his own portal or, you know, connection and we likely have different requirements as to how to build those portals just from the I. T perspective. 792 Sky Stanfield 03:40:57.755 --> 03:41:18.065 I understand that that problem, I guess what I'm asking you is, as we've gone through a couple of these have you actually thought about whether there is a problem you guys don't tell me you aren't talking about these so I know you have 3 different portals. We're talking about submitting a CSV file, for example, that shows your schedule. Are you suggesting that there are 3 different that 1 of. 793 Sky Stanfield 03:41:18.093 --> 03:41:20.523 Systems isn't capable of that, or. 794 Roger Salas SCE 03:41:20.763 --> 03:41:21.393 No, I don't. 795 Sky Stanfield 03:41:21.393 --> 03:41:39.183 Reserving some future. It seems to me like you guys are about to propose to have to put in the advice or how you're going to implement this. Each of you should say how would I implement this. And then if there's a difference, we need to figure out if that's a capability difference or that we can get over or not. 796 Sky Stanfield 03:41:39.605 --> 03:42:00.365 But the, the W, what we would like, and we'd like to not have to fight about this in 4 more iterations of an advice letter. Is it be consistent? So, if you guys could think about it ahead of time at the site, is there some reason why the CSV file couldn't be accepted by all 3 of systems, as opposed to just leaving a door open to later a controversy that would. 797 Sky Stanfield 03:42:00.394 --> 03:42:00.904 Helpful. 798 Roger Salas SCE 03:42:01.504 --> 03:42:05.224 Okay, well we'll we'll, we'll pick that up make sure that we pick pick that up. 799 Alex Mwaura PG&E 03:42:06.424 --> 03:42:17.224 Yeah, I, I think what I can say right now is sky, is that, you know, it all depends on whether we we go with 288+it's 12. so if we, if we. 800 Sky Stanfield 03:42:18.964 --> 03:42:21.604 Say, why we're talking about a CSV file either way. 801 Alex Mwaura PG&E 03:42:21.604 --> 03:42:37.264 No, no, I'll tell you why, so the difference is, if we do, if we're able to accept 12 values, we do not need to accept the customers can punch this in, in this form that's shown on the right side of this. Right? It's 12 values. That would go in. 802 Alex Mwaura PG&E 03:42:39.154 --> 03:42:50.374 Pigeon is actually proposing a way to bring in the values in the form. So customers can in real time. See what they're proposing. As far as their profile is below that number. 803 Sky Stanfield 03:42:50.404 --> 03:42:59.374 Where are you just being obstinate and saying you, why don't you have to answer the question? Have you actually looked at whether a profile. 804 Sky Stanfield 03:42:59.615 --> 03:43:20.735 It was either 12 months or 288 hours is possible in your system or you just say, conveniently that it would be. You're not even saying, you know, that each of the systems can submit support a 12 a profile that you've put in here, which suggests to me that you guys don't actually know or you're trying to put it in an obstacle for strategic. 805 Alex Mwaura PG&E 03:43:20.974 --> 03:43:21.424 No. 806 Sky Stanfield 03:43:21.994 --> 03:43:22.534 I'm not saying, you. 807 Alex Mwaura PG&E 03:43:23.584 --> 03:43:41.884 Yeah, that's not what I'm saying. I'm so PG E, and I'm assuming for the other utilities, we were going down the path that we would be accepting 12 values, not a CSB file an actual profile, put into the application form. That's the part that we were. 808 Alex Mwaura PG&E 03:43:41.914 --> 03:43:55.864 If the decision is that we have to go to 288 versus 12, it obviously would not make sense to have a customer. Somebody sit there and punching to 80 values. So, in that case, we would have to accept the file. Now. 809 Sky Stanfield 03:43:56.164 --> 03:43:56.644 Accept. 810 Alex Mwaura PG&E 03:43:56.644 --> 03:43:57.244 A fire. 811 Sky Stanfield 03:43:57.244 --> 03:44:03.034 You're saying is you're going to make the commission go back and do a whole, another round of advice letters for you to figure out. 812 Sky Stanfield 03:44:03.039 --> 03:44:18.574 Whether you could accommodate the 208 because you're unwilling to provide that optionality now because you're trying to pinch the commission into your pathway. I mean, if there's not, it's not that complicated. Decide if a CSB file can be accommodated in your. 813 Alex Mwaura PG&E 03:44:18.724 --> 03:44:24.184 Csv file can be accommodated in more systems you can you can but the thing is, you can accept the file. 814 Alex Mwaura PG&E 03:44:24.274 --> 03:44:35.464 But what do you do with the file? Right? What do you do with those values? Because this has they have to go through a steady process right? So if you try to automate the process, then that file has to go PG users. 815 Alex Mwaura PG&E 03:44:35.855 --> 03:44:56.615 Somehow we have to integrate that from the application portal into our SAP system that accepts the project, and then go back to the same system that actually does analysis. It's a much more complex integration when you're talking about 200 values versus 12. now, the reason why we propose this, this form. 816 Alex Mwaura PG&E 03:44:56.914 --> 03:45:02.164 That's shown on the right which was included in the last advice letter that we filed. If you look at the. 817 Sky Stanfield 03:45:02.164 --> 03:45:03.754 It's a rejected by the way. 818 Sky Stanfield 03:45:05.163 --> 03:45:13.623 Come back here, because you guys were told that what you did the 1st round, which is what you're proposing again, wasn't adequate. So here. 819 Yi Li SDG&E 03:45:16.624 --> 03:45:17.974 True sky. 820 Alex Mwaura PG&E 03:45:18.034 --> 03:45:18.454 Yeah. 821 Yi Li SDG&E 03:45:19.084 --> 03:45:37.384 This in a vice letter, which is adopted with modification in the resolution 230, it's not rejected. So, I really feel like, um, I appreciate that. You don't make the assumption that that has not take this into consideration and really consider how we can implement this. 822 Yi Li SDG&E 03:45:38.044 --> 03:45:58.624 It's not just about uploading a file to a portal. Obviously any system can accept a file. It's about how we can interpret that and handle that student process is submitting 12 values. 3285isreally different. Also, each area has a different capacity. So, for perspective. 823 Yi Li SDG&E 03:45:58.685 --> 03:46:19.805 We, we may not have as many capacity of these applications compared to say, or PG. E. so we may be handling these application a little bit differently. Right? And if we're looking to implement this ltp in a timeline that's directed by the resolution, uh, which I think that's seeing everyone's best interest based on the. 824 Yi Li SDG&E 03:46:19.863 --> 03:46:40.893 And that's being made so far, we may be handling, we may be utilizing some Excel manual process in the beginning and looking to automate if we get more applications down the road. Um, because we'll need to be into implement ID changes. And again, it's, it's a different level of ity changes if we're implementing the 12 values in 208. 825 Yi Li SDG&E 03:46:41.015 --> 03:46:55.085 Wanted to just kind of making up ity costs and timeline just based on, you know, initial discussion we have to know for sure. And then engage ity vendors and get the exact cost estimate timeline to implement the changes. 826 Regnier, Justin 03:46:56.495 --> 03:46:58.895 So, I, I think I might have some constructive input. 827 Yi Li SDG&E 03:47:01.414 --> 03:47:02.314 Go ahead Justin. 828 Regnier, Justin 03:47:04.504 --> 03:47:21.844 To Gary, I think I think that that's a good recommendation for all parties, utilities, and otherwise that we keep the conversation positive and not pylon. Um, our differences in opinion in this particular topic have been well. 829 Regnier, Justin 03:47:21.850 --> 03:47:42.935 In the 1st workshops, I'm not going to go into them here. What I wanted to follow up on was the discussion that we had at the end of the last workshop in which both and PG E, um, discussed the possibility of within their portal bringing in the values. 830 Regnier, Justin 03:47:43.024 --> 03:48:04.144 By line segment, and that was kind of the genesis of the question that Alex had in terms of we're looking at costs and timeline or just timeline and would like to follow up on the inquiry on Timeline the 12 versus 288 punching in manually versus bring it in. 831 Regnier, Justin 03:48:04.150 --> 03:48:25.295 File or automated through the portal is maybe a, a bit of a red herring. I think that we can make the argument that automated input or automated file upload is 1 that meets the goals of this proceeding explicitly stated streamlined. 832 Regnier, Justin 03:48:25.324 --> 03:48:36.664 The interconnection process, whether it's 12 dollars or 208 values or some, some non 0 manager, whatever um, partly because. 833 Regnier, Justin 03:48:38.644 --> 03:48:59.134 People will do batch uploads of systems. This is something we've talked about on the residential sphere, although I understand that doesn't map 1 to 1. and there are efficiencies to be gained. A CSB is a very common file format as Alex has mentioned. Most systems can incorporate it. I just wanted to touch a little bit on our discussion. 834 Regnier, Justin 03:48:59.314 --> 03:49:20.254 I'm afraid we also have them in a workshop 1 where we're talking about the relative levels of complexity of comparing a, a static value against an curve versus a output curve against an curve and the point that we raised in that discussion right? 835 Regnier, Justin 03:49:20.314 --> 03:49:41.434 Embarrassed consideration here is that the user are ready, considering an output curve against the curve when they look at their typical PB profile. So I think if we're going to make the argument that that is a higher level of complexity. We'd want to hear more detail as to why bringing in a. 836 Regnier, Justin 03:49:42.454 --> 03:50:02.374 I see or bringing in limited generation profile probe that is, is, uh, a number of points and just for 1 to 1 comparison. Uh, you know, the 288 is what we would look at with the, the generalized. 837 Regnier, Justin 03:50:02.615 --> 03:50:23.615 Profile, why profile is more difficult to compare than a 288 PB profile? I think that's that is an open question, but if we're going to oppose having a file format input that we'd want to deal with and. 838 Regnier, Justin 03:50:23.739 --> 03:50:44.884 So the 2 elements 1 is, if we're going to oppose having a file format input, then we should talk about what additional complexity is is introduced above and beyond the PB profile versus profile case too, because we wanted to follow up and make explicit that we do want to understand what. 839 Regnier, Justin 03:50:44.914 --> 03:51:06.034 It would take in terms of timeline for the portal upgrades that were discussed last time. So, specifically the ability to bring values within the application portal when the customer inputs, the line segments CSP value. Those are, those are the 2 things I wanted. 840 Regnier, Justin 03:51:06.064 --> 03:51:16.054 Make sure we got in before the conversation moved on without, you know, getting back into all of our well documented points of disagreement on interpretation. 841 Yi Li SDG&E 03:51:28.295 --> 03:51:34.595 I think what you have actually have the next slide on doing some discussion of. 842 Yi Li SDG&E 03:51:35.915 --> 03:51:42.275 288 valleys, compare it suits all values. Do we want to go there? 843 Roger Salas SCE 03:51:48.814 --> 03:51:57.814 Mostly justin's asking for updates and what we might have indicated that we would do. Uh, is that is that correct? 844 Regnier, Justin 03:52:02.074 --> 03:52:02.554 Yes. 845 Roger Salas SCE 03:52:02.584 --> 03:52:02.794 Yeah. 846 Regnier, Justin 03:52:02.824 --> 03:52:05.224 That is correct and I don't know if that's something that I. 847 Regnier, Justin 03:52:05.434 --> 03:52:09.214 Jamie has also contemplated, I guess the 3rd thing that I would throw in there. 848 Regnier, Justin 03:52:10.925 --> 03:52:29.615 Is that commission has been very clear in their direction that the real 21, um, language and requirements should be uniform across I use in the absence and overriding condition that would force them to be desperate. So, to the extent that we are able to make it uniform, we obligated to make it uniform. 849 Roger Salas SCE 03:52:32.914 --> 03:52:53.194 Yeah, so for I don't think that I have the update. Um, Justin, um, I think I need to follow up. I know you know, my colleague who's not here today. He might have had that information. I don't. Um, but maybe maybe what I want to make. Sure. Is that that I understand. 850 Roger Salas SCE 03:52:53.224 --> 03:53:14.344 The questions clearly, because I'm not sure that I do. So so if others do understand the questions or the request clearly, maybe I can follow up with others, but I don't think I do 100%. So, maybe if you can repeat this for my, my, my. 851 Roger Salas SCE 03:53:14.350 --> 03:53:16.205 Understanding of what the request is. 852 Regnier, Justin 03:53:17.375 --> 03:53:32.855 Sure, um, 3 different elements and the lovely thing about recording it is we can all go back and make sure that we're being honest with ourselves. Um, so you, you can go back and run the tape on it before. And that should be consistent with what I just said. 853 Regnier, Justin 03:53:34.115 --> 03:53:54.905 Which is 1, if we're going to go the route where the are stating that it is an additional level of complexity to have an input file versus punching in the values individually, that we should have some substantiation of how the. 854 Regnier, Justin 03:53:55.239 --> 03:54:04.264 Complexity has increased by an input file that gives output compared to. 855 Regnier, Justin 03:54:05.284 --> 03:54:14.944 Versus the already existing case of using a input file that gives typical PV values compared against the values. 856 Roger Salas SCE 03:54:15.634 --> 03:54:24.334 Hey, Justin, can you verify when you say input the value input the value for what? Or to what? What do you mean by that? Can you clarify that? 857 Regnier, Justin 03:54:24.394 --> 03:54:26.254 Um, yeah, but you've got. 858 Regnier, Justin 03:54:26.284 --> 03:54:28.834 Illustration on the next slide so I'm going to go to slide 17. 859 Roger Salas SCE 03:54:28.954 --> 03:54:29.284 Can. 860 Alex Mwaura PG&E 03:54:30.574 --> 03:54:33.124 Justin, can I clarify what I said before. 861 Regnier, Justin 03:54:37.145 --> 03:54:39.005 Sure do you want to do it midstream? Or or should we. 862 Alex Mwaura PG&E 03:54:39.575 --> 03:54:41.135 Go for it yet. Okay. I'll wait. 863 Regnier, Justin 03:54:45.065 --> 03:55:03.065 So, right now, when you are looking to evaluate a system permissible size, you compare the yellow curve with the green curve, the 2 solid yellow, or the 2 solid curve, the solid green curve. 864 Regnier, Justin 03:55:04.353 --> 03:55:12.513 Solid yellow, and that is a 288 value versus 288 value comparisons. 865 Roger Salas SCE 03:55:13.383 --> 03:55:15.963 For the typical BB profile, right? 866 Regnier, Justin 03:55:16.353 --> 03:55:16.773 Backwards. 867 Roger Salas SCE 03:55:17.163 --> 03:55:25.353 Right so typical profile you look at that hour by hour and you compare the hour by hour and you say well, I said, and I said, that's. 868 Roger Salas SCE 03:55:25.534 --> 03:55:28.534 Cds margin what are the margin is? Yes. So. 869 Regnier, Justin 03:55:28.564 --> 03:55:45.154 Exactly. Right, exactly. Right. Uh, so we're, we're consistent on our understanding of that. What we're saying from the commissions perspective is what we're hearing from the is that using an input file to compare against the values. 870 Regnier, Justin 03:55:46.629 --> 03:55:49.924 Introduces an extra element of complexity. 871 Regnier, Justin 03:55:52.294 --> 03:56:13.414 And what we'd like to understand is how it's more complex. Yeah, yeah. We're going to compare a 288 value or whatever, value, limited generation, profile array. If you will against the array of value. 872 Regnier, Justin 03:56:13.505 --> 03:56:32.075 That are permissible so how is that more complicated than doing the exact same thing for the photo will take to entity value? So, that's what we'd like to understand if you're continuing to hold that using an input file, introduces a level of complexity that is unwarranted or unacceptable. 873 Roger Salas SCE 03:56:33.335 --> 03:56:34.415 In case the clock. 874 Roger Salas SCE 03:56:35.013 --> 03:56:55.473 That is for the analysis portion, as opposed to the application portion, you know, customer some, you know, submitting an application, you know, going online, submitting an application, uh, as opposed to picking that information. And then performing analysis using that information. 875 Regnier, Justin 03:56:57.035 --> 03:57:00.785 What I think I hear you're saying is it's a screens versus in a connection. 876 Roger Salas SCE 03:57:00.995 --> 03:57:16.835 Question no, no, no, no screens or more of a I mean, a customer can submit, obviously can submit a file in the interconnection application as a, as an attachment, you know hey, Here's my profiles and attachment. Right. Uh, CSB or otherwise. 877 Roger Salas SCE 03:57:17.704 --> 03:57:37.414 Um, as opposed to going into the application form, the, the, the actual application form, and in punching in 12 numbers right? Um, the analysis after the fact, we can take that CSB file and perform analysis. Just like what you're showing here. 878 Roger Salas SCE 03:57:38.044 --> 03:57:52.414 Or take the 12 values that the customer performance performing the same analysis there. So, I just want to make sure that we're talking about the analysis portion. Are we talking about the interconnection application portion? Because it's 2 different things? I think. 879 Regnier, Justin 03:57:53.404 --> 03:57:55.084 We're talking about analysis portion. 880 Roger Salas SCE 03:57:55.354 --> 03:57:59.164 The analysis perspective, Dallas is stuck in the Alex is talking about the. 881 Roger Salas SCE 03:57:59.225 --> 03:58:01.385 Application portion is that correct? Alex? 882 Alex Mwaura PG&E 03:58:04.385 --> 03:58:05.405 That is correct yes. 883 Regnier, Justin 03:58:06.185 --> 03:58:24.485 It is clearly more complicated to import a file than it is to import fields that are already in your portal. I think we can establish that. But W, I think we've also established that. That's not right. It's not a great hindrance. Because, as Alex mentioned really all systems. 884 Regnier, Justin 03:58:24.664 --> 03:58:25.684 Csv import. 885 Roger Salas SCE 03:58:26.554 --> 03:58:30.514 Okay, so so just to clarify the question, the question is for this 1st question is. 886 Roger Salas SCE 03:58:31.625 --> 03:58:52.745 If we get a profile 28 profiles, whether it's truly unique values, or whether it's, you know, 12 sets of 24 values, nevertheless, a profile. Are there any differences in the technical evaluation as compared to a typical PV? 887 Roger Salas SCE 03:58:52.749 --> 03:58:55.654 File, you know, essentially. 888 Regnier, Justin 03:58:55.714 --> 03:59:13.894 So, what what I'm hearing is objection to using a standardized file, are 2 things 1 is the complexity that is introduced by pulling a file, as opposed to just interrogating the fields that are already in your portal. And I think we've put that to bed with Alex. And statement, I. 889 Regnier, Justin 03:59:13.900 --> 03:59:22.115 The common understanding, the CSB file is easy to import on just about any system. So we've taken that application complexity as a hurdle away. 890 Alex Mwaura PG&E 03:59:22.955 --> 03:59:23.165 Yeah. 891 Regnier, Justin 03:59:23.375 --> 03:59:23.675 What we're. 892 Alex Mwaura PG&E 03:59:23.675 --> 03:59:35.015 Is 1 other aspect there's another aspect, Justin so I was pointing out before 1 of the things that we're trying to look into potentially doing is on that application form. That was. 893 Alex Mwaura PG&E 03:59:35.049 --> 03:59:40.684 Being displayed on the previous slide is actually pulling in the is. 894 Alex Mwaura PG&E 03:59:40.714 --> 04:00:01.684 Values for the month, so that we can actually just compare the values right there with what the customer's putting in. If you go with the 28 values, a file has to be uploaded. And then somehow there has to be an integration with the system to pull in the 208 values to be compared with. Right? So, that's the. 895 Alex Mwaura PG&E 04:00:01.895 --> 04:00:03.875 Another aspect of the complexity, so. 896 Regnier, Justin 04:00:04.865 --> 04:00:22.355 I think both are required, though, if we're going to go that route so I, I appreciate the the discussion of pulling in the values to the portal and that's that is the thing that I'm explicitly asking for feedback in terms of timeline. Um, so that is 1 element. 897 Regnier, Justin 04:00:23.194 --> 04:00:36.964 But it may be that the applicant doesn't want to follow the entirely it maybe that they want to have a lower output limit in certain time periods, or some other permutation. So there's gotta be. 898 Alex Mwaura PG&E 04:00:37.594 --> 04:00:38.224 For them to do. 899 Regnier, Justin 04:00:39.184 --> 04:00:40.174 Yeah, so they gotta be. 900 Alex Mwaura PG&E 04:00:41.374 --> 04:00:42.094 The maximum. 901 Regnier, Justin 04:00:43.354 --> 04:00:43.744 Right. 902 Alex Mwaura PG&E 04:00:43.774 --> 04:00:44.014 Yeah. 903 Regnier, Justin 04:00:44.164 --> 04:01:01.984 So that if the customer, I mean, I think could be lovely if we had just a quick click through where you say, okay, here's the profile. Those are the maximum values. We accept that. Great. But that doesn't allow them to edit it. And I think that's where an actual consistent file format becomes useful. 904 Alex Mwaura PG&E 04:01:02.494 --> 04:01:05.284 No, it would allow them to edit it because they actually. 905 Alex Mwaura PG&E 04:01:05.344 --> 04:01:10.774 Their profile values, right? So they're making a determination of what the values would be. And. 906 Alex Mwaura PG&E 04:01:11.134 --> 04:01:26.164 I think they're doing the only advantage is they're able to compare with the value to make sure, you know, let's say this new values, a megawatt and they decided they wanted to go to 800 or 900. that would be. Okay, but they can go into any lower than that. It can go to 500 or 700, for example. 907 Regnier, Justin 04:01:27.064 --> 04:01:40.834 Okay, but then we get into the streamlining and a connection consideration of manual entry versus automated file input, whether that's 12 or 288 or 2056 values. I don't know. 908 Regnier, Justin 04:01:43.354 --> 04:01:47.254 The concept is, is the same whether the, even if the magnitude is different. 909 Roger Salas SCE 04:01:50.014 --> 04:02:10.144 Okay, so so, so maybe I heard 2 different things there. So again, I want to make sure I'm clear. So we, we, we talked about the evaluation and whether the valuation is different from a profile versus the typical PB profile. Okay. So we have that 1 that. 910 Roger Salas SCE 04:02:10.745 --> 04:02:31.295 That we want to evaluate the other item that I heard in this discussion was that Justin, the commissions that is expecting or not measures are required, but at least expecting, or or desires that that in our interpretation application portals we bring in the LGB. 911 Roger Salas SCE 04:02:31.954 --> 04:02:52.384 The, the, the, the, I guess the maximum profile allocation, so, for instance, customer wants to interconnect at a given location, they find where the, our electrical identifier. 912 Roger Salas SCE 04:02:52.449 --> 04:03:13.474 And the map they punch in that electrical node and then when the punch that value, then that the application form comes up with a whatever it's a, what a box that says, say here here here are the 12 values. 913 Roger Salas SCE 04:03:14.105 --> 04:03:23.375 Maximum that you can interconnect that this location with the LGB profile. Is that why you're asking? I want to make sure I understand. 914 Regnier, Justin 04:03:25.114 --> 04:03:42.874 My understanding is that already has this functionality coded, but not implemented to be able to pull in the values within the portal. My request is an estimation of the time that it would require to have that functionality with all 3. 915 Roger Salas SCE 04:03:43.024 --> 04:03:43.834 Okay. 916 Regnier, Justin 04:03:43.834 --> 04:03:45.964 Not directing. 917 Regnier, Justin 04:03:46.029 --> 04:04:07.174 i'm ministerial and i'm a commission employee not the commission so i'm not directing that you implement this functionality but it seems that it would be useful to understand the level of effort and level of time that would be involved and if we hear from stakeholders that justin's just wandering off in a field somewhere and that would 918 Regnier, Justin 04:04:07.205 --> 04:04:15.605 Useful at all then maybe we don't need to do it, but it seemed to have come up in the course of discussion and understanding the trade offs seems to be a useful thing. 919 Roger Salas SCE 04:04:15.995 --> 04:04:19.385 Okay, but but my description was, what, what are you looking for it? 920 Regnier, Justin 04:04:22.384 --> 04:04:30.274 I'm not going to say that your description is what we're looking for, because we are still debating the number of values that come up and you. 921 Roger Salas SCE 04:04:31.414 --> 04:04:42.424 Regardless of what, regardless of whether it's 12 to 88, uh, whatever you're asking is for our customer to be able to go to the. 922 Roger Salas SCE 04:04:42.430 --> 04:04:44.885 Patient form for. 923 Roger Salas SCE 04:04:45.574 --> 04:05:06.394 For the customer to punch in the, uh, the electrical node where the generation's going to be connected and for the, uh, the, the interconnection tool to go and basically pull the value values cumbersome over to a, whether store values or values, whatever. 924 Roger Salas SCE 04:05:06.400 --> 04:05:08.405 That may be, but that's kind of the concept you're asking. 925 Regnier, Justin 04:05:09.215 --> 04:05:27.545 I'm asking for an estimation of the time that it would take to implement that functionality equivalent to what PG E has done and also for need to understand what that level of effort would look like. Um, and, you know, if parties want to wave me off and say that, they don't think. 926 Regnier, Justin 04:05:27.574 --> 04:05:36.484 Be useful, we can have that waved off and not worry about it, but it was a follow up item from workshop 1. so I wanted to make sure to close the loop. 927 Roger Salas SCE 04:05:37.114 --> 04:05:38.824 And we'll make sure it goes the loop. 928 Regnier, Justin 04:05:40.804 --> 04:05:43.384 Jenny, have you contemplated the sort of a functionality. 929 Yi Li SDG&E 04:05:44.644 --> 04:05:48.694 So, we're wearing a slightly different situation, so to be transparent. 930 Yi Li SDG&E 04:05:48.814 --> 04:05:54.334 We don't really get that many applications, like our and PG and. 931 Yi Li SDG&E 04:05:54.695 --> 04:06:15.485 So, for us, when we typically the way we handle these attachments, like CSV files and get attached and submitted to our, uh, into cash and portal and then our intake group, uh, in our customer generation group will send those files over to our engineers for further analysis. So. 932 Yi Li SDG&E 04:06:15.514 --> 04:06:36.574 We don't really have a plan to automate the process and unless we, you know, there's an increasing application, we feel like we really have to do that to increase the efficiency. So, we're kind of in a tough spot, you know, to come up with the estimate. Because, you know, we're really far away from that. 933 Yi Li SDG&E 04:06:36.844 --> 04:06:38.464 May not be necessary for us. 934 Yi Li SDG&E 04:06:45.814 --> 04:06:48.754 Alex, do you did you have a hand up. 935 Alex Mwaura PG&E 04:06:48.754 --> 04:07:02.014 Did I did I just wanted to clarify that for PG E. we, we have an integration with the IC database. This is how we analyze projects that use to. 936 Alex Mwaura PG&E 04:07:02.043 --> 04:07:23.103 So projects that are using for script using, or but we have not completed the changes necessary to implement what I was describing before. So, this idea of, you know, changing the portal to be able to accept the profile. 937 Alex Mwaura PG&E 04:07:23.170 --> 04:07:40.115 Also, to be able to query the ACA database and display these 12 values that the customer can compare to this is something that is a want, but we're still having discussions with it on how this can be implemented, but it's not been it has not been done yet, so. 938 Alex Mwaura PG&E 04:07:41.614 --> 04:07:51.274 And obviously, this issue of 288 is sort of, you know, putting a pause on it because we don't know which way, you know, we're gonna go. Um. 939 Aliaga-Caro, Jose 04:07:55.294 --> 04:07:55.894 Okay, so. 940 John Berdner Enphase 04:07:56.164 --> 04:07:56.494 This. 941 Aliaga-Caro, Jose 04:07:56.494 --> 04:07:57.124 Uh, you know. 942 John Berdner Enphase 04:07:57.124 --> 04:08:00.454 This is John from the I've had my hand up for a while. 943 Aliaga-Caro, Jose 04:08:00.604 --> 04:08:01.894 Okay, go ahead. 944 John Berdner Enphase 04:08:02.824 --> 04:08:13.354 Yeah, we just I wanted to point out I think there are 2 different issues, and we may be conflating that. 21 is what is the risk of using. 945 John Berdner Enphase 04:08:13.930 --> 04:08:35.075 For example, an hourly profile, something more temporal granularity and I understand that the user saying we don't want to do that. Yeah. The 2nd issue is around the portal and how to enter information into it and that ties back into. 946 John Berdner Enphase 04:08:35.103 --> 04:08:50.013 Prior commission orders, I believe orders is the right time with Chad a schedule will consist of 288 dollars. So, you know, you could get a schedule. 947 John Berdner Enphase 04:08:52.804 --> 04:09:13.024 Rows of 24 values are all identical. Um, I could put forth 12 values for that line segment and providing that 24 identical values were 90% or less of that initial IC value. That would be. 948 John Berdner Enphase 04:09:13.235 --> 04:09:34.235 client so the issue is i believe the order sets of schedule will consist of two hundred and eighty eight dollars we could agree that at least initially there'll be two twelve set to twenty four identical browsers and that would not require modification 949 John Berdner Enphase 04:09:34.324 --> 04:09:42.154 the exact same order but would address the utilities concerns over more granular schedules today 950 John Berdner Enphase 04:09:43.054 --> 04:10:02.104 so one is about data entry how to do it what is the format of an electronically transmitted file versus a manually created file and the second issue is around the complexity of the high of using a more granular schedule so i think there are two different issues 951 Yi Li SDG&E 04:10:12.334 --> 04:10:18.754 Thanks for that clarification, John. Yeah, I agree. These are 2 separate issues. I see your chat messages. 952 Yi Li SDG&E 04:10:21.003 --> 04:10:24.693 Is there anyone who want to comment on that before we move on. 953 Aliaga-Caro, Jose 04:10:29.585 --> 04:10:39.185 So, um, I suggest, let's finish this, like, 617, I think, and Dan, let's break for lunch. 954 Aliaga-Caro, Jose 04:10:41.343 --> 04:10:55.353 And then we'll finish up the utilities presentation and then move on to the direct presentation. So, let's finish up this, uh, topic 5 and we'll break for lunch. 955 Yi Li SDG&E 04:11:00.334 --> 04:11:18.634 Sure, on to, uh, John's points, uh, there's 2 separation here and this particular slide is mostly addressing utilities concern or integrating utility concerns around using 280 distinct value versus 12 values. 956 Yi Li SDG&E 04:11:18.844 --> 04:11:39.784 I think we have made those statements in a previous working group discussions hence why we filed the proposal in, uh, and, you know, also what was being adopted by the decision as a country proposal. Uh, we believe that, um, you know, going from 12 value to 280 a valley really increased. 957 Yi Li SDG&E 04:11:39.789 --> 04:11:46.834 The capacity of implementing, uh, going for the annual minimal. 958 Yi Li SDG&E 04:11:46.840 --> 04:12:03.485 To mostly already kind of decrease the safety margin seems to generator will be allowed to operate at the higher level during most Moses and increasing that for the 280 a further decrease the safety margin. And also Israel. 959 Yi Li SDG&E 04:12:03.814 --> 04:12:24.904 You know, I think we collectively agreed that during the workshop 1 that would currently have really limited experience and infrastructure to work with this type of generator control from a utility perspective where I'm starting as to, whether the will meet the expectation and truly avoid a need for a utility system to. 960 Yi Li SDG&E 04:12:24.935 --> 04:12:46.055 By side controllers, as you all know that we're furthering, agreeing to relying on meters to perform that validation after the fact. And as we discussed early today at the beginning of this conversation, although we are going to try to rely on my data to capture the expert. 961 Yi Li SDG&E 04:12:46.058 --> 04:13:07.113 But those are typically delayed and does not really represent the real time operation behavior and further beyond that, as we listed here on the slides currently. None of that I've used really having infrastructure needed to manage the generation and reducers. I'll put in real time. 962 Yi Li SDG&E 04:13:07.235 --> 04:13:28.355 We don't really have the necessary visibility to recognizing graduation happen in real time. And whether, and how we will find out when the generation output needs to be reduced, and whether they could effectively communicate the chance to the DVR and whether the would responding a timing accurate manner, I think we. 963 Yi Li SDG&E 04:13:28.359 --> 04:13:49.444 Received clarification requests from the division around what infrastructure we're referring to here we're kind of referring to sort of a, all associate infrastructure such as, you know, uh, basically the infrastructure that allows for us to have a high visibility, more real time, visibility and controlling. 964 Yi Li SDG&E 04:13:49.894 --> 04:14:09.934 Which is not really only a physical infrastructure requirement also requires, you know, recognition allowance for us to do that. Cause right now we don't really have any ability to, um, have to have visibility to Dr system under 1 megawatts and let alone have any control over these systems. 965 Yi Li SDG&E 04:14:11.105 --> 04:14:31.625 And last, but not least, uh, we do want to point out the modeling challenges associates, uh, with going from 288 limits. Uh, we're still each I always still having discussion with our respective groups on how to implement these changes. Uh, we have listed a few, um, thoughts in. 966 Yi Li SDG&E 04:14:31.808 --> 04:14:52.953 By file, which is currently we are ordered to have more discussion on the restaurant 503 going from handling in how query generation application get model. It is more complicated than how we used to handle the application based on the template. We have to figure out how to adjust our models. 967 Yi Li SDG&E 04:14:53.045 --> 04:15:13.925 To accurately reflect the application, not yet. See profile approved given. Now, they have a dynamic profile versus a nameplate. Because initially we will just remove that, you know, namely value from the remaining to update that. So, the next customer in line will get the accurate representation of how much remaining capacity. 968 Yi Li SDG&E 04:15:14.194 --> 04:15:35.194 In on the system, but with, we do have to implement a little bit different process and how we model these systems and going from Intel value limits to 200 limits. Just makes it overly complicated. And that's something that we want to highlights as 1 consideration for a while. We do not want to go for more granularity. 969 Yi Li SDG&E 04:15:35.404 --> 04:15:40.444 P schedule any comments questions. 970 Sky Stanfield 04:15:43.473 --> 04:16:03.453 This guy, I'm not going to comment now on all these different points. I think that's helpful to lay out these position. And it'll be not surprising that we don't necessarily agree both of the complexity or that. The complexity is insurmountable. But I want to ask just a hypothetical question to help me understand. 971 Sky Stanfield 04:16:03.460 --> 04:16:20.855 How you guys envision the risks of profiles of different sorts? So what if instead of what if the commission instead of allowing a 12 month profile had allowed a schedule that was. 972 Sky Stanfield 04:16:23.199 --> 04:16:44.344 12 hours in a day or 12 increments in a day or 6 increments or 4 increments in a day versus a 12 month profile would that does a profile based on a daily? Does it limited generation profile based on the daily profile? Create more risk than a. 973 Sky Stanfield 04:16:44.375 --> 04:16:49.805 Profiled based upon a monthly profile, does that make sense? 974 Yi Li SDG&E 04:16:51.425 --> 04:17:07.505 I think so, let me try to answer that I can let me know if I'm missing understand your question. So, on what you think of, like, kind of the profile yeah, I think we have a picture here on the right which is sort of the more granular proposal. Initially part of the working group, too. 975 Sky Stanfield 04:17:07.505 --> 04:17:07.955 Mm, hmm. 976 Yi Li SDG&E 04:17:08.403 --> 04:17:29.433 Although currently part of the analysis, we do provide the 576 profiles, but kind of get you understand now, there's a lot of assumption that goes into coming up with IC limits right? We are rely on forecasting and also rely on, you know, a lot of historical data in order to provide. 977 Yi Li SDG&E 04:17:29.495 --> 04:17:33.875 Value at a granular level, so when it comes to. 978 Sky Stanfield 04:17:33.875 --> 04:17:34.295 Going on. 979 Yi Li SDG&E 04:17:34.295 --> 04:17:43.565 Uh, like, say a minimal I see. And then to a daily and. 980 Yi Li SDG&E 04:17:44.553 --> 04:18:03.453 The further granular you go do more kind of risk and become, because you're getting more relied on that forecasting down to each granular level. Right? So, just kind of I'm just kind of coming out, like, speaking out loud here uh, cause I'm really hungry right now. So, I'm not really. 981 Sky Stanfield 04:18:07.115 --> 04:18:25.865 Clarify something, so what I mean, by the so there's 24 hours of the daily profile I don't mean an actual day. I mean, the day, the way that you guys are modeling it, which we got clarified, which isn't based on any assumption of any actual dates, the worst case scenario in every 1 of the 24 hour. 982 Sky Stanfield 04:18:25.984 --> 04:18:47.014 Right so what I'm asking is is a profile that's based on that more risky to you even if it was, for example, chunk. So we say somebody could design the profile in for our chunks over a 24 hour period. Is that more risky than a profile? That's based upon the 12 month scenario. 983 Sky Stanfield 04:18:47.073 --> 04:18:54.573 And I understand what I'm trying to understand is, I don't think that there I'm trying to understand where the variability in the forecasting hits. The hardest essentially. 984 Yi Li SDG&E 04:18:56.313 --> 04:18:58.953 Yeah, I think that question for too, for me. 985 Sky Stanfield 04:19:01.144 --> 04:19:02.014 We need to have. 986 Yi Li SDG&E 04:19:02.674 --> 04:19:14.884 To get our, and maybe come back and to see if, you know, my colleagues here can help out with this question uh, if not, you know, worst case, we can take it back and come back to you in the next workshop. 987 Roger Salas SCE 04:19:16.744 --> 04:19:22.054 Well, we have, we might come in and that would be that, you know, it is natural that as the, the more. 988 Roger Salas SCE 04:19:22.323 --> 04:19:43.353 You get the, the risk is going to increase that what you forecasted that's going to happen will not happen. Now at what point does it become problematic? You know, that's a difficult answer to have. Right it's like, you know, at this point. 989 Roger Salas SCE 04:19:43.445 --> 04:19:48.275 I think will feel more comfortable with with the 1 value per month. 990 Sky Stanfield 04:19:48.335 --> 04:20:04.565 Is it just that you feel what I'm trying to get at Roger? Is it isn't just that you feel that you'd rather have 12 our 12 points versus 288 points or is it? Because I guess cause I can envision what I'm trying to make sure. I understand. 991 Sky Stanfield 04:20:04.568 --> 04:20:25.653 And this is partly so what we all need to understand in terms of what how much value there is for the customer in this thing is, is it actually more valuable for a customer to be able to promote provide a daily profile that would be consistent across the entire year, or a monthly profile obviously, what we'd like is a monthly profile that varies by day, or maybe set the. 992 Sky Stanfield 04:20:26.285 --> 04:20:46.865 But what I'm trying to make sure I understand in terms of what the utilities real concern here is, is is it just the number of touch points essentially, either 12 versus 288 or does it matter what those touch points are tied to the monthly versus the daily profile, I think they're all based on the same set of assumption. So it shouldn't really matter, but. 993 Sky Stanfield 04:20:46.869 --> 04:20:50.284 I may not be thinking about that correctly. 994 Roger Salas SCE 04:20:51.694 --> 04:21:05.794 I mean, I think the touch points and the fact that each touchpoint, it's making the assumption of that given given value on that day, based on a forecast. 995 Roger Salas SCE 04:21:08.073 --> 04:21:29.163 Naturally, the, the closer that you get to why you think it was going to happen that particular hour the higher chances is that something may happen in the forecast that may actually be wrong. Right? So, I think it's more about the, the number of touches that we have in each month. 996 Roger Salas SCE 04:21:29.795 --> 04:21:50.315 In the fact that each hour is being is based on a different, uh, different forecast for that particular hour is what, what, what makes us nervous without having any experience um, so it's, I'm not sure if that answer your question, but really, you know, it's all of these all of these calculated. 997 Roger Salas SCE 04:21:51.753 --> 04:22:11.403 Are based on simulation, based on forecasting of load profiles, based on what happened before. Well, you know, as we all know, you know, past performance is not a feature or a guarantee of the future. So so the more that you try to simulate, what happened in the past, the more. 998 Roger Salas SCE 04:22:11.470 --> 04:22:13.055 Probability says that you want to be wrong. 999 Sky Stanfield 04:22:13.865 --> 04:22:21.605 I'm just trying to understand whether that probability increases more at the, the daily basis versus the monthly basis. Um. 1000 Regnier, Justin 04:22:28.085 --> 04:22:28.655 Lunch. 1001 Aliaga-Caro, Jose 04:22:30.035 --> 04:22:31.145 Yes. 1002 Sky Stanfield 04:22:31.145 --> 04:22:31.445 A. 1003 Aliaga-Caro, Jose 04:22:31.445 --> 04:22:37.355 A good time to break for lunch. Uh, let's break until 130. 1004 Aliaga-Caro, Jose 04:22:40.175 --> 04:23:00.815 And then we'll finish up, I believe the utilities have 2 slides to go and we'll finish that up and then pick it up with, uh, presentation. So, uh, yeah, if you could bring up or, hey, could you change those? Oh, nice. I like. 1005 Aliaga-Caro, Jose 04:23:00.818 --> 04:23:01.208 That. 1006 Aliaga-Caro, Jose 04:23:02.884 --> 04:23:07.084 Could you bring up the, uh, break slide for lunch? 1007 Aliaga-Caro, Jose 04:23:20.853 --> 04:23:24.363 And that's perfect. Yeah, we'll leave it there. So we'll resume at 130. 1008 Aliaga-Caro, Jose 04:23:30.244 --> 04:23:33.094 All right, so you all in a bit. 1009 Yi Li SDG&E 04:23:35.644 --> 04:23:36.064 You guys. 1010 Yi Li SDG&E 04:23:36.873 --> 04:23:37.593 Right. 1011 Aliaga-Caro, Jose 05:13:59.134 --> 05:14:01.294 All right. Hello everyone, um. 1012 Aliaga-Caro, Jose 05:14:03.574 --> 05:14:19.596 Nearing 1, it is 130. so, um, I think we're ready to, uh, resume the utilities presentations. Uh, can I get a roll call to make sure utilities are, uh, present. 1013 Aliaga-Caro, Jose 05:14:24.876 --> 05:14:26.044 Perfect, thank you. 1014 Roni Mejia - SCE 05:14:27.392 --> 05:14:28.142 From I see. 1015 Aliaga-Caro, Jose 05:14:29.132 --> 05:14:33.184 Thank you Ronnie, anybody else Alex. 1016 Aliaga-Caro, Jose 05:14:47.464 --> 05:14:48.454 Roger. 1017 Roger Salas SCE 05:14:49.774 --> 05:14:50.314 Here. 1018 Aliaga-Caro, Jose 05:14:50.614 --> 05:15:08.134 Okay all right. Perfect. So, we, before we, uh, continue to topic 6, uh, or, hey, can we go back 1 slide and, uh, and I just wanted to make sure we closed off any discussion items on this slide and this. 1019 Aliaga-Caro, Jose 05:15:08.434 --> 05:15:09.004 Topic. 1020 Aliaga-Caro, Jose 05:15:11.702 --> 05:15:15.902 So, uh, I is, uh, sky. Are you back. 1021 Sky Stanfield 05:15:17.222 --> 05:15:18.302 Yeah, I'm here. 1022 Aliaga-Caro, Jose 05:15:18.662 --> 05:15:31.442 Okay, since you were the last, uh, person to speak about this slide, I just wanted to make sure that we had a, you know, a finished up discussion of topic 5 before moving on to topics. 1023 Sky Stanfield 05:15:35.044 --> 05:15:53.314 Yeah, I don't think I have more questions on this again. It's more of a statement of the utilities concerns than, um, something where I think we're going to reach agreement on at this point. But I understand what their concerns are based on. Hypothetically. 1024 Aliaga-Caro, Jose 05:15:59.044 --> 05:16:02.464 all right then it sounds like we can continue on to topic six 1025 Aliaga-Caro, Jose 05:16:05.344 --> 05:16:07.174 So, uh, who's covering this. 1026 Yi Li SDG&E 05:16:08.074 --> 05:16:09.304 Still me thanks. Thanks. 1027 Aliaga-Caro, Jose 05:16:09.304 --> 05:16:14.104 Okay, although I think we may Ronnie, uh, may have already covered this already. 1028 Yi Li SDG&E 05:16:14.764 --> 05:16:18.454 Yeah, I was disappointed about that, but yeah, we can move on. 1029 Aliaga-Caro, Jose 05:16:19.084 --> 05:16:23.764 Okay, well you you, if you have anything else to add, you know, feel free. 1030 Yi Li SDG&E 05:16:24.304 --> 05:16:25.714 No, no, I think we can move. 1031 Aliaga-Caro, Jose 05:16:26.492 --> 05:16:26.944 Okay. 1032 Yi Li SDG&E 05:16:29.674 --> 05:16:49.684 Cool. Uh, so the next topic is a slide that we put together, um, based on some of the discussion in the last workshop, uh, regarding, you know, getting asked about the risk with projects as to why the utilities are concerned about project. 1033 Yi Li SDG&E 05:16:49.746 --> 05:17:10.866 Necessarily treat them differently versus customers. We just want to kind of provide a quick comparison as how we currently understand. This is not obviously not final given. We're still working on how is gonna get implemented right now as currently standing row, 21 on the process for knowledge. 1034 Yi Li SDG&E 05:17:10.894 --> 05:17:30.364 Is that when during the screening process, when we evaluate the project outputs is that we'll be comparing the generator generating facility aggregate gross the complete ratings to the 90% of the lowest value and the. 1035 Yi Li SDG&E 05:17:31.324 --> 05:17:51.634 And also, we'll also do a comparison between the aggregate gross nameplate rating to the 90% the lowest value in the operating flux profile. So, in comparison to that, the new potential process that will be having for the projects is that. 1036 Yi Li SDG&E 05:17:51.876 --> 05:18:12.904 The customers output will only be compared to the 90% of the lowest value. So we kind of trying to giving to message here 1 is to really remind folks to, you know, consider they are a significant amount of benefits to. 1037 Yi Li SDG&E 05:18:12.936 --> 05:18:34.054 Customers for using versus the current process at the same time, you know, what comes with that there are some risks that are not presented if a customer is following the normal process, for example, on 1 thing that is pretty clear basis. Comparison. Is that customer they're operating on a high capacity. 1038 Yi Li SDG&E 05:18:34.114 --> 05:18:55.204 An, which may result in reversal on the little side of the bus that currently does kicking consideration but does not take into consideration. Also, in general refers to, on false regulators and switching devices is not considering these icl limits and this type of decrease operating flexibility. 1039 Yi Li SDG&E 05:18:55.208 --> 05:19:16.354 It really means that they're more likely to have issues during a system of reconfiguration has why we stated before that there was increased risk with projects. And another thing that, you know, we've been talking about this a lot in the previous conversation is that, you know, operating at a higher capacity for element. Most of the year there's just more like. 1040 Yi Li SDG&E 05:19:16.384 --> 05:19:37.504 To have on the distribution Transformer and low side. Right? Because as we all know, that analysis doesn't really take any secondary, you know, limits into consideration when it comes to value. Um, I, I wasn't there for the process, but I think what initially came out part of the proceeding. Uh, it started as a. 1041 Yi Li SDG&E 05:19:37.536 --> 05:19:58.654 Tool to help the developer to find the optimal location to install this regeneration. Uh, over the past years we have been working closely, you know, all of us on the call to hoping to use it to streamlining the connection. Um, process has, you know, uh, most recent use cases is. 1042 Yi Li SDG&E 05:19:58.714 --> 05:20:19.804 Use it to a part of the screen, and instead of what was previously in screen, ham basically use it to replace, uh, screening or get integrated into some of the screening process. But we do want to, you know, just as a general reminder that it's, it's not at the end of day, it's still a computed value based on a lot of forecasting elements and estimate. 1043 Yi Li SDG&E 05:20:20.014 --> 05:20:40.924 And also simplified modeling process so, um, using, uh, more granular limits, uh, in general creative risk of having issue on the distribution systems without going through the full study process, um, last but not least, I think there's a question from say previously on, um, since we're only talking about. 1044 Yi Li SDG&E 05:20:40.984 --> 05:21:02.074 Screen, I'm in this particular slide, what did you want to point to that presentation now we presented, I think believe part of the November 10th meeting, uh, there are also going to be a screen and screen oh. In some aspects screen key may be impacted to study projects, using exporting sort of a nameplate. 1045 Yi Li SDG&E 05:21:02.494 --> 05:21:07.834 Um, obviously those are need to be hashed out in the next steps a workshop for 530. 1046 Yi Li SDG&E 05:21:09.964 --> 05:21:13.596 Skype, go ahead. Can you can unmute yourself and ask your question. 1047 Sky Stanfield 05:21:14.854 --> 05:21:20.674 Thank you, let me start with that last comment and work backward. So. 1048 Sky Stanfield 05:21:23.944 --> 05:21:42.634 I thought that in our last conversation, we had agreed that it was the export capacity and not the name plate. That would be you were basically gonna follow rule 21 for any screens where the nameplate would be used. And then only in the screens where. 1049 Sky Stanfield 05:21:43.024 --> 05:22:04.114 Export capacity is, is identified per, et cetera and then full 1 through 4 and that what I want to make sure you're saying. Are you saying that you're going to treat customers differently than a limited export non customer. 1050 Sky Stanfield 05:22:04.176 --> 05:22:05.224 What you're suggesting. 1051 Yi Li SDG&E 05:22:07.294 --> 05:22:25.294 I think, um, feel free any other colleagues jump correct me? I believe so there are gonna be some screening that are different for customer using export versus same place. We do have a slight issue with that, which is what's been covered under the next slide under topic. 8. 1052 Yi Li SDG&E 05:22:25.324 --> 05:22:46.264 Certain customer that has the own sites bold. We have to take those a little, um, you know, study them a little more closely versus a generation application. That's pure generation. That doesn't have, um, you know, onsite load, but based on what we previously discussed and what's in the decision I think we're leaning towards. 1053 Yi Li SDG&E 05:22:46.474 --> 05:22:57.964 The export for the all should be customer, even though if you go back to the decision, there's a lot of sentences that uses export in our generation output interchangeably. 1054 Yi Li SDG&E 05:22:58.384 --> 05:23:07.594 To be to be completely transparent. Like, I'm relatively new tools now I was trying to read the decision. It was a bit harder for me to digest and understand. So we. 1055 Yi Li SDG&E 05:23:07.624 --> 05:23:14.824 We talk a lot internally trying to figure out exactly what we meant but, you know, I'm not changing our previous. 1056 Sky Stanfield 05:23:14.824 --> 05:23:15.244 Yes. 1057 Yi Li SDG&E 05:23:15.724 --> 05:23:16.804 That's what I'm trying to say. 1058 Sky Stanfield 05:23:17.584 --> 05:23:28.744 Okay, so I, I think if I understood 1st of all, I know there's a little term terminology goes back and forth and that's what I'm trying to clarify as well. But what I think I heard you say to paraphrases. 1059 Sky Stanfield 05:23:28.774 --> 05:23:49.864 That you guys are thinking, you want to apply the supplemental review screens differently for an customer compared to just a limited export customer, not using a profile, but if that's correct I didn't hear why, what what, what would be the thinking about that they would need to look at the profile, obviously. 1060 Sky Stanfield 05:23:49.926 --> 05:24:00.214 Versus there's the a single export amount, but I don't is there some reason why if you could explain more what you mean? So that we know what you're saying you're going to do differently that would be helpful. 1061 Yi Li SDG&E 05:24:01.686 --> 05:24:11.044 Yeah, I'm not really getting to exactly which screen I don't have all of that in front of me. Uh, but in in a in a high level, they are changes. 1062 Yi Li SDG&E 05:24:11.048 --> 05:24:32.194 Using to implement that we don't currently do for the limited profile, limited, export customer. We haven't. Uh, I think we submit it in the device letter, which is the 1 that got approved with modification under resolution 530 kind of what screen are going to be impacted part of the. 1063 Yi Li SDG&E 05:24:32.200 --> 05:24:41.734 Screen, but I think there is for the discussion that I warranted both internally, and with stakeholder on exactly what those screen look like. 1064 Aliaga-Caro, Jose 05:24:43.624 --> 05:25:04.624 Are the associate, uh, there are some outstanding screens, but I do, I was looking over the, uh, November, 10, smarter working group slides, and they did commit to screen and M, and oh, and aspects of P would be studied. 1065 Aliaga-Caro, Jose 05:25:04.954 --> 05:25:07.684 Jp. 1066 Sky Stanfield 05:25:08.314 --> 05:25:25.744 Right, well that and that makes sense to me, I'm trying to understand as I think what you're saying is they would apply it differently than just the flat export and I'm trying to make sure I understand. They would need to apply the profile. But are the thresholds. And everything the same, like, I guess, I'm not sure if I'm understanding. 1067 Sky Stanfield 05:25:25.780 --> 05:25:31.804 Then looking at the profiles and alignment, what would be different. 1068 Roger Salas SCE 05:25:32.374 --> 05:25:38.434 He may be good to go to the next slide. If he has some of that expense, you can always come back to this, but maybe go to. 1069 Sky Stanfield 05:25:38.434 --> 05:25:38.974 Right. 1070 Roger Salas SCE 05:25:39.034 --> 05:25:43.144 That's a little bit more information. I think it's the next slide. 1071 Yi Li SDG&E 05:25:45.692 --> 05:25:47.852 Yeah, good recommendation. Can we go to the next slide? 1072 Yi Li SDG&E 05:25:50.284 --> 05:26:03.874 I, I do agree with you sky. I think terminology is is really important to get on the same page here. I, I think that what would benefit us and benefit the stakeholders too. Um, so our next slide. 1073 Yi Li SDG&E 05:26:06.634 --> 05:26:26.314 We provide a kind of a simplified diagram of obviously, so don't read too much into this. This is, uh, just for a discussion only so on this circuit. We're assuming there's 2 Transformers and, uh, 2 customers, uh, load, which is what the L is indicating for. And the meter is really. 1074 Yi Li SDG&E 05:26:26.410 --> 05:26:33.366 Referring to you that you showed you mean her, and also considered as point of coupling between the utility and the customer system. 1075 Yi Li SDG&E 05:26:36.724 --> 05:26:57.424 Sorry, I'm, uh, all of a sudden start to cough, um, apologize for that and we also marked, uh, what we believe would be the PCs located, which is really, uh, at the generation outputs. Right? So, um, again, this is just a hypothetical example. We are assuming there is a battery. 1076 Yi Li SDG&E 05:26:57.484 --> 05:27:18.006 And there's also a solar system, and please don't look at this, um, take this for any electrical consideration. I'm not really referring to this as AC, couple of system RTC, couple system. What? Not just a symbol sort of symbol representation of a generation system that has multiple assets behind the 1 PCs. So. 1077 Yi Li SDG&E 05:27:18.934 --> 05:27:39.694 What, as we were trying to, um, discuss these internally as to okay if profile, right 1st of all limited generation profile. That's that's what sold me off initially right? Cause when you think of generation profile, we would assume initially it's referring to the aggregated output. 1078 Yi Li SDG&E 05:27:39.754 --> 05:28:00.874 Of, you know, the generation system right. Does not include any of the low reduction that the customer also have on site, but as we're reading through the decision. Uh, and also what's in, you know, there are 205,230 that a commission is asking the utility to clarify if the is. 1079 Yi Li SDG&E 05:28:00.878 --> 05:28:21.934 Bring to the export or the outputs. Um, we believe that the intention was to use the export, which, in this case would be the reading at meter, which equivalent to the total generation on site minus the load on site. Right? That makes sense. 1080 Yi Li SDG&E 05:28:22.054 --> 05:28:22.984 So far. 1081 Yi Li SDG&E 05:28:25.474 --> 05:28:25.834 Okay. 1082 Sky Stanfield 05:28:26.524 --> 05:28:42.604 Wait hold on, it would be the limited generation, the limited generation on site. So what the export amount that the utility that the customer is saying, they will export to using a PCs or other controls not the nameplate amount. 1083 Yi Li SDG&E 05:28:42.994 --> 05:28:45.844 Yeah, not the name play, right? So it would be. 1084 Yi Li SDG&E 05:28:46.802 --> 05:29:07.052 Export, but, you know, given we are only measuring the meter, right that's the value that we're comparing if we're thinking to what, you know, a customer will be submitting. Right? Let's just sync. Hypothetically, there's a table with 12 values that value will be equivalent to what the customer. 1085 Yi Li SDG&E 05:29:07.504 --> 05:29:18.212 Is proposing their system to have, uh, at the point of this meter right? Which reflects, um, you know, the generation minus the. 1086 Yi Li SDG&E 05:29:21.632 --> 05:29:22.742 So, in this scenario. 1087 Sky Stanfield 05:29:22.954 --> 05:29:42.392 1 thing, that's how we've defined it for limited generation profiles or limited generation without a profile. It's not. It's just they set an expert capacity limit using the PCs, for example, and I don't think that there my recollection is there isn't anything in the rule that says that they need. 1088 Sky Stanfield 05:29:42.398 --> 05:29:46.204 Back out the load usage is that what you're saying? 1089 Yi Li SDG&E 05:29:47.104 --> 05:30:03.542 Yeah, that's that's sort of the issue we're having. Right so when I was reading the resolution 50, 30, I, I understand Justin that it's, it's not approved. Uh, but the language did say that, you know, commission believes the. 1090 Yi Li SDG&E 05:30:03.548 --> 05:30:24.664 Pe is referring to the export at the meter, not export at the generation PCs. Obviously the PCs in the scenario needs to have a at the low side to measure the actual boat and use the schedule to regularly. 1091 Yi Li SDG&E 05:30:24.724 --> 05:30:45.844 What the export at the meter will be back to the utility system right? I think that's and someone who's more familiar with that can correct me. I'm mistating that, but, um, the reason we bring this up is that, let's say we are using the export at the meter um, as the reference point for the. 1092 Yi Li SDG&E 05:30:46.624 --> 05:31:06.934 We do have an issue when we compare that directly to the icaay. Right? Cause at the end of the day is estimating amount of generation. It's allowed to host at that 3 phase no. Without triggering any limitation or trigger any violation on electrical system. So. 1093 Yi Li SDG&E 05:31:07.082 --> 05:31:28.142 In that model, right? In that electrical model, this particular customer's mode is already modeled in the system. So, as we're measuring the export at the meter and compare that to the value at the point of the 3 phase note that no onsite low technical gets double counted. 1094 Yi Li SDG&E 05:31:28.892 --> 05:31:49.052 So, again, this wouldn't be a problem if someone is just applied for regeneration, there's no onsite mode, right? They're establishing a new generation system. It's a simple comparison. Right? The generation, um, at each of these 12 value needs to be lower than the limit at each of those 12 values right? 1095 Yi Li SDG&E 05:31:49.414 --> 05:31:54.424 Yeah, it's more complicated when those onsite mode, because that gets Tom double counted. 1096 Sky Stanfield 05:31:55.864 --> 05:32:08.794 Help me understand though again why this is a special circumstance for the versus any limited generation customer with onsite load what is it about? 1097 Yi Li SDG&E 05:32:09.034 --> 05:32:09.934 What's the limit? 1098 Yi Li SDG&E 05:32:10.864 --> 05:32:14.884 Customer, you're referring to you're referring to the current limited export customer. 1099 Sky Stanfield 05:32:15.214 --> 05:32:16.984 Yeah, sorry limited export customer. 1100 Yi Li SDG&E 05:32:17.434 --> 05:32:18.934 Can we go back 1 slide. 1101 Yi Li SDG&E 05:32:24.212 --> 05:32:38.462 So, in the current screening process, where the limit is used to evaluate the application for the currently, uh, limited export customer, it's their generation nameplate. 1102 Sky Stanfield 05:32:38.462 --> 05:32:42.874 It's not though that's not right so, 1 of the big problems and. 1103 Sky Stanfield 05:32:42.934 --> 05:32:49.924 Adamantly did not want to have happen, but for the utilities requests in each of. 1104 Sky Stanfield 05:32:49.930 --> 05:33:09.696 And for it identifies how those screens are applied, and those screens, if you are doing a limited export system, that qualifies under 1 of those PCs options, it identifies that you will, depending on the option selected, be screened using your export capacity. And not your name plate rate. 1105 Yi Li SDG&E 05:33:10.506 --> 05:33:11.074 So. 1106 Yi Li SDG&E 05:33:11.078 --> 05:33:27.784 I have to go back to my team on that, but that's the case. We'll have the same exact issue for those. That's a problematic as well in the scenario that I just named. Right? Because when you're comparing the export to the value. 1107 Sky Stanfield 05:33:27.962 --> 05:33:28.594 Mm, hmm. 1108 Yi Li SDG&E 05:33:28.684 --> 05:33:31.624 Oh, that's on site is getting double counted. 1109 Yi Li SDG&E 05:33:35.642 --> 05:33:37.082 If we want to walk that through. 1110 Alex Mwaura PG&E 05:33:38.912 --> 05:33:39.242 If I. 1111 Alex Mwaura PG&E 05:33:39.304 --> 05:33:42.604 If I may chime in, so I think the issue excuse me. 1112 Alex Mwaura PG&E 05:33:45.456 --> 05:34:06.064 What's being shown on the screen is specific to screen M, I think sky what you're mentioning may be true for other screens right? But for screen name for projects that are using nameplate because this is 3 options for screen name. Right? Is the typical PV profile option is. 1113 Alex Mwaura PG&E 05:34:06.068 --> 05:34:24.392 That option, and then, when I say is not available, we should go back to the 15%. So, for projects that are non typical PV, this is a loan for it. We would make sure that the project name plate is below 90% of and 90% of. 1114 Alex Mwaura PG&E 05:34:25.864 --> 05:34:31.082 But for like, screening for screen D, for example, that will be based on the export. 1115 Sky Stanfield 05:34:33.694 --> 05:34:45.542 All of our time negotiating, we spent, like, 6 months negotiating that if you're using the whole point of all of that. But difficult negotiation was so that if you were using a for that, you're you would have. 1116 Sky Stanfield 05:34:45.724 --> 05:35:06.694 I screen them and screen and the transformer, I think screen as well using the limited export amount. I'm not saying that again I'm hoping Brian can help me out with this issue of the load, but I'm not saying that you haven't identified an issue potentially. But what I, what I think we're doing is. 1117 Sky Stanfield 05:35:06.724 --> 05:35:27.844 Characterizing what would happen for a limited generation profile project incorrectly the whole point of all those months of work on the limited generation profile was to make sure the screen end was not applied or screen M as in Mary. And M, and as a Nancy not applied using the nameplate rating what would. 1118 Sky Stanfield 05:35:27.850 --> 05:35:40.474 Be the point of limiting your export if that was not done and that was why we spent all working through all the utility concerns around the different PCs configurations in response time. 1119 Sky Stanfield 05:35:42.334 --> 05:35:45.844 It sounds to me, like, this is sort of a separate issue from the although it means. 1120 Sky Stanfield 05:35:45.904 --> 05:35:48.814 An issue that needs to be discussed. 1121 Roger Salas SCE 05:35:49.114 --> 05:36:03.094 Yes, and I think when you're talking about though, I think is not necessarily with screen em, all of the discussions that we had was related ready to screen I, you know, the various options of, you know, so so, maybe we just need to go back to what we actually. 1122 Roger Salas SCE 05:36:03.124 --> 05:36:12.274 Putting the 4 screen, em, itself and all those discussions that we have, where related to screen em. 1123 Sky Stanfield 05:36:13.054 --> 05:36:15.514 I think you need, do you have real 21 in front of, you? 1124 Alex Mwaura PG&E 05:36:20.074 --> 05:36:20.464 I. 1125 Alex Mwaura PG&E 05:36:22.234 --> 05:36:22.384 I. 1126 Alex Mwaura PG&E 05:36:24.934 --> 05:36:25.322 Sky. 1127 Sky Stanfield 05:36:25.354 --> 05:36:28.742 So, are you looking at look at section? 1128 Roger Salas SCE 05:36:29.882 --> 05:36:31.292 But again is. 1129 Roger Salas SCE 05:36:31.324 --> 05:36:32.344 To screen. 1130 Alex Mwaura PG&E 05:36:32.734 --> 05:36:33.124 Yes. 1131 Roger Salas SCE 05:36:33.394 --> 05:36:34.294 Screen name. 1132 Sky Stanfield 05:36:34.714 --> 05:36:35.524 You read it. 1133 Sky Stanfield 05:36:39.184 --> 05:36:58.084 It falls is the is the this is the whole oddity around how we did this. I agree. It's confusing as heck, so don't so bear with me, but screen I is the screen about whether using acceptable export controls. But then it says if you're using this export control, go to go to section in them to. 1134 Sky Stanfield 05:36:58.356 --> 05:37:19.234 Or, or what depending on which 1 you're using, and then it explains how the screen the other screens would be applied. And in particular it identifies, for example, J. K. L. M. N. O. and how those would be applied using the export capacity email, or the name play rate. If you were above. 1135 Sky Stanfield 05:37:19.266 --> 05:37:40.234 2nd response time, for example, you don't get the benefit of using your export capacity amount, but the whole point of creating all those additional, and then, et cetera was to ensure the customers get reviewed using your export capacity. There's no point if that doesn't happen, nobody would ever do this. Why would you agree? Why would you. 1136 Sky Stanfield 05:37:40.388 --> 05:37:45.874 In your export, if you're just saying you're going to study me as though I'm when would you study the limited export them out? 1137 Alex Mwaura PG&E 05:37:47.614 --> 05:37:51.874 For screens, not not screen name for screen D for example, who would apply. 1138 Sky Stanfield 05:37:51.874 --> 05:37:57.904 Alex, you have the tariff in front of you tell me what section 2 sets. 1139 Sky Stanfield 05:38:01.834 --> 05:38:07.264 Particularly is under the evaluation of limited export system, requesting interconnection under this section. 1140 Alex Mwaura PG&E 05:38:09.874 --> 05:38:10.714 Give me 3rd. 1141 Alex Mwaura PG&E 05:38:25.384 --> 05:38:32.494 I'm looking for it's guy cause, uh, I was looking at the advice letter, but let me actually pull the tariff itself. So I can see it. 1142 Alex Mwaura PG&E 05:38:32.704 --> 05:38:33.604 So. 1143 Younes, Amin 05:38:34.836 --> 05:38:36.456 256 is what you want to think. 1144 Alex Mwaura PG&E 05:38:36.816 --> 05:38:47.946 Yeah, and to to, uh, so if maximum value, um, impacts of grid under screens D. I. J. K. M. N. 1145 Alex Mwaura PG&E 05:39:00.454 --> 05:39:00.694 Yeah. 1146 Sky Stanfield 05:39:10.562 --> 05:39:28.954 So, the 1st sentence in that section is, if the maximum value is greater than 1% of the PCs controlled name, play as provided by the middle, utilize the requested limited export value, plus maximum, steady state value of the times the PCs. 1147 Sky Stanfield 05:39:29.134 --> 05:39:34.204 To evaluate the impact to the grid under screens. D. I. J. K. L. M. N. O. 1148 Yi Li SDG&E 05:39:37.024 --> 05:39:43.534 What is the but what is the control nameplate and whoever driving this? I can't go to the next slide. Please. 1149 Yi Li SDG&E 05:39:47.614 --> 05:40:06.364 Scott in this scenario, let's forget about the when you see the names of the PCs, are you referring to the combined export of the generator only or they combine export minus the low, which is at the meter? Is it export to the grid or the generator? 1150 Sky Stanfield 05:40:06.364 --> 05:40:06.994 Export. 1151 Yi Li SDG&E 05:40:07.324 --> 05:40:09.574 You are using this export too loosely here. 1152 Sky Stanfield 05:40:11.286 --> 05:40:32.404 So maybe Brian can help me out here a little bit but I I think that what we were envisioning was the export pass the, um, and that was kind of the whole point, especially because when we talk about adding so if you have a storage plus solar system as you have envision here, what we wanted to avoid is a project being studied. This is the storage. 1153 Sky Stanfield 05:40:33.336 --> 05:40:53.554 Putting simultaneously that was the that's the most basic use case. Here is just saying, I'm not going to export from the battery and the solar system simultaneously. It will be limited by the. So, we'll never export and it could be, you know, the number is up to the customer. What that is as long as you're using. 1154 Sky Stanfield 05:40:53.582 --> 05:40:57.124 Pcs that meets all those criteria we identify. 1155 Roger Salas SCE 05:40:59.494 --> 05:41:10.204 Yeah, wonder, I wonder if we're I know that, you know, I'm, I'm wondering if we focus a little bit on on the issue here, rather than debating everything I was I, I think. 1156 Sky Stanfield 05:41:10.204 --> 05:41:10.414 Call. 1157 Roger Salas SCE 05:41:10.414 --> 05:41:20.344 Okay, which is needle, I will say re, familiarizes with that, but let's go back to the issue here at hand and why this is a problem because I think maybe this is a. 1158 Roger Salas SCE 05:41:20.374 --> 05:41:28.804 Soon, why we need to continue to discuss is the main issue here is that if we have an. 1159 Roger Salas SCE 05:41:30.062 --> 05:41:49.954 Uh, you know, a data electrical node that you see there with the, that, that I see profile, um, accounts for the load of these customers, right? It assumes that this customer has 1 megawatt 1 megawatt. 1160 Roger Salas SCE 05:41:50.704 --> 05:42:11.104 And when we do our modeling, we, uh, we model 1 Meg will load and that's the reason why at allocation you have to maybe 2.5 megawatts of right? It assumes that these location, what has 1 megawatt load right now if if you know an example here you take the 2.5. 1161 Roger Salas SCE 05:42:11.134 --> 05:42:32.254 It doesn't say, okay. Yeah, I have 2.5 megawatts here, but you actually are able to export 2.5 megawatts and serve the local load. Now you will double counting the problem. Meaning like meaning like the original value that you believe I met was originally. 1162 Roger Salas SCE 05:42:32.554 --> 05:42:40.446 The 1 megawatt or Valley 1 megawatt load in the simulation and that's the reason why we had a 2.5 megawatts. 1163 Roger Salas SCE 05:42:41.016 --> 05:43:01.866 Uh, if if the logo wouldn't have been there, it probably would have been 1.5 megawatts of but because of the loads there, we have 2.5 megawatts of. And so if the generator exports, the full 2.5 megawatts of, and serves the 1 megawatt load, then essentially. 1164 Roger Salas SCE 05:43:01.984 --> 05:43:08.794 We're double counting the 1 megawatt load that we got there. Right? It would be like having 2 megawatts of load. 1165 Regnier, Justin 05:43:10.984 --> 05:43:11.584 Here though. 1166 Roger Salas SCE 05:43:11.944 --> 05:43:12.334 Mm, hmm. 1167 Regnier, Justin 05:43:12.754 --> 05:43:14.254 Just with a direct question. 1168 Regnier, Justin 05:43:17.586 --> 05:43:29.766 Is this issue so, my understanding of this issue is that if you start with no generation system, if you start looking at just these 21 megawatts of load. 1169 Roger Salas SCE 05:43:30.336 --> 05:43:30.726 Mm, hmm. 1170 Regnier, Justin 05:43:31.956 --> 05:43:37.086 You've got an value of, you know, it says the thermal here is 2.5 megabytes. 1171 Regnier, Justin 05:43:37.144 --> 05:43:37.564 Sure. 1172 Regnier, Justin 05:43:40.204 --> 05:43:52.594 Whether the generation facility is a static permission to operate so 1 megawatts all the time. Mm. Hmm. Or limited generation profile. 1173 Roger Salas SCE 05:43:52.984 --> 05:43:53.374 Yeah. 1174 Regnier, Justin 05:43:54.304 --> 05:43:56.404 Varying is the same problem. 1175 Roger Salas SCE 05:43:56.824 --> 05:43:57.574 Same problem. Yeah. 1176 Regnier, Justin 05:43:57.574 --> 05:44:00.304 Understanding the same problem is that the. 1177 Roger Salas SCE 05:44:00.694 --> 05:44:00.964 Right. 1178 Regnier, Justin 05:44:01.116 --> 05:44:06.154 Factor in the diminishment of existing load when a generator is added. 1179 Roger Salas SCE 05:44:06.606 --> 05:44:07.054 That's right. 1180 Regnier, Justin 05:44:07.536 --> 05:44:18.814 So, I don't see that this meets the criteria that we've discussed in the resolution of only imposing restrictions upon projects that are triggered by particularly. 1181 Yi Li SDG&E 05:44:19.324 --> 05:44:22.234 No, I, I wouldn't agree with that. It. 1182 Yi Li SDG&E 05:44:22.266 --> 05:44:32.044 Right, right so think of the current generating customer, when they apply, they are getting value based on nameplate. Right? So. 1183 Yi Li SDG&E 05:44:36.002 --> 05:44:54.602 So, when name please being compared to the icaay, it is fair comparison. So, I, I don't think the problem is that if it's static or if it's dynamic it, the problem is really is, what are we referring to as the point of measurement and what we're are we comparing it to we again. Um. 1184 Yi Li SDG&E 05:44:55.144 --> 05:45:14.914 I'm speaking for in here, right? We, we don't necessarily have our self position married to any particular way of measuring this. We're just saying that, yes, if we consider that, we're measuring at the point of meter and we have to remove the load in words. You have a proper comparison with the. 1185 Yi Li SDG&E 05:45:15.934 --> 05:45:36.392 We wanted to measure at the PCs, and we do not have to measure to remove the load to do this comparison because that the PCs is representing the output of the generation. But that does pose a challenge to our previous topic meter. Right? Because now when we get the data. 1186 Yi Li SDG&E 05:45:36.970 --> 05:45:55.176 That's not representing what the output is, because the output is what's at the PCs. So again, we're not trying to cause trouble here. We just want to talk this out because I think the important now we're talking, you know, in the same language, because these are a little confusing. Right? Let's just be I'll be transparent with that. 1187 Sky Stanfield 05:45:55.536 --> 05:45:58.026 That's fair. So what I hear you saying. 1188 Sky Stanfield 05:45:58.144 --> 05:46:05.914 Is that I don't think this is an issue. I think when you said the reference to the. 1189 Sky Stanfield 05:46:06.784 --> 05:46:27.662 Again, protested the, the need for quarterly reporting on the same basis that you're using a certified system. And what you're saying is, you want a verification of the certified system works and that's not our exposition is that that's not necessarily the commission hasn't decided that 1 or the other and I appreciate the middle ground. You guys offer there but this is not. 1190 Sky Stanfield 05:46:27.902 --> 05:46:48.874 A unique issue, it may be an issue that we need to have a broader conversation about but I still didn't hear anything that actually has to do the distinguishes the performance of the system from the performance of a limited export system in terms of how the screen should be applied I'm not. And again I. 1191 Sky Stanfield 05:46:48.904 --> 05:47:06.544 To be clear that Brian and I are texting on the side. Like we do, we might need to have another conversation about this issue as it applies to any system that's controlling export when when we're applying the IC it. But I don't I'm not hearing that. This is a profile issue. 1192 Yi Li SDG&E 05:47:09.754 --> 05:47:28.984 So, this is not necessarily issue for 511 right? But for 5 to 30, I use our asked to clarify that when we speak of, we are talking strictly to the export at the point of the, to the grid, not the output of the generation. 1193 Yi Li SDG&E 05:47:30.092 --> 05:47:50.912 Saying that before, we can clarify that. We need to reach the common ground to your point that we may have an issue with the current language in the row, 21 of having the same issue. But that's a separate conversation that I don't think it falls into any of these roles in scope but I understand it's not an issue but we are direction now. 1194 Yi Li SDG&E 05:47:50.920 --> 05:48:07.984 To working on the tariff changes too far advice letters to propose the language what's you know, it's it's important we get it right, right. If we have a language in the original that needs to be corrected, let's tackle that. But for the language that we're going to propose, let's make sure we do it. Right? 1195 Sky Stanfield 05:48:08.224 --> 05:48:12.064 Okay, yeah, I can agree on that. I just wanted to distinguish to make sure we. 1196 Sky Stanfield 05:48:12.068 --> 05:48:33.212 They're all on the same page with what the problem is. So, I think for Iraq, what I, what I can say, unless brand wants to jump in and has passed or processing skills and I do, you know, I think we're going to need to digest this. Not just for, but also for limited export projects overall, whether they're using a relay or a. 1197 Sky Stanfield 05:48:33.516 --> 05:48:54.276 Or or something, um, but it does sound like, you may have potentially identified an issue, we need to think about broadly. Um, and maybe the time to think about it here is that I just wanted to make sure we were distinguishing what is specifically caused by the profile versus caused by just limiting export as a whole, um. 1198 Sky Stanfield 05:48:54.370 --> 05:48:58.954 Can we go back to the earlier slide? I think I'm afraid I've lost the other questions I may have had, but I'm hoping. 1199 Yi Li SDG&E 05:49:00.334 --> 05:49:04.984 Has his hands raised, Alex? Do you want to comment on something on that topic? 8. 1200 Sky Stanfield 05:49:05.104 --> 05:49:06.724 I mean, as is. 1201 Alex Mwaura PG&E 05:49:07.324 --> 05:49:15.514 Yeah, I just I just wanted to confirm, um, to sky. I think I did already, but it might have been somebody else talking that, you know, you. 1202 Alex Mwaura PG&E 05:49:15.692 --> 05:49:17.732 Correct that under. 1203 Alex Mwaura PG&E 05:49:18.516 --> 05:49:35.946 Is included in analyzing, uh, using the limited export value. So, I mean, obviously, as we've discussed this, uh, direct conflict between the current screen and language, and so, as part of maybe. 1204 Sky Stanfield 05:49:36.846 --> 05:49:39.484 I just want to pause there is not a conflict. This was. 1205 Sky Stanfield 05:49:39.664 --> 05:50:00.456 Unintentional it was intentional. That was why we did it the way. This was the way you guys wanted to do it. You did just want to put it in screen. You wanted to put it in. It is not a conflict. It's expressly stating. This is how you will apply it and that was the preferred approach. It doesn't mean that this issue goes away, but this is not this this was. 1206 Sky Stanfield 05:50:00.754 --> 05:50:04.774 Exactly what we were trying to accomplish through M. 1207 Alex Mwaura PG&E 05:50:04.804 --> 05:50:05.074 Yeah. 1208 Sky Stanfield 05:50:05.494 --> 05:50:21.784 Et cetera now again, it doesn't mean we don't need to work on it. So I don't think we should spend time fighting about it but it is really important. That today if you're proposing to interconnect the project that's limited export. It sounds like there's some disagreement about how you guys are actually doing it. Um, so I feel like we've raised a much bigger. 1209 Sky Stanfield 05:50:21.814 --> 05:50:26.494 Issue here, which is worth debating or figuring out, but it's not. 1210 Alex Mwaura PG&E 05:50:26.494 --> 05:50:35.134 The reason I say, yeah, the reason that's the conflict is because screen and language is very clear, but obviously, you know. 1211 Alex Mwaura PG&E 05:50:36.124 --> 05:50:53.404 I don't want to spend too much time on this, but the issue here, I think what happened is we were so focused on resolving the ones and the screen. I language that we completely kind of forgot about this screen him. You know, changes that we're making to the tariff. We didn't really reconcile the 2 things, but anyway, that's that's all I have to say. 1212 Younes, Amin 05:50:54.034 --> 05:50:57.034 Can I jump in? I I think, and I'm not. 1213 Younes, Amin 05:50:57.064 --> 05:51:18.184 Super familiar with the limited export profile. I'm just reading about it. In fact, the 1st, time ever but in glancing through it. I believe that. That is measuring export at the, not at the, at the and so, the word export. If you talked about limited export, profile and limited generation profile, those export words are not the same thing they're talking about. 1214 Younes, Amin 05:51:18.214 --> 05:51:39.184 Different types of export 1 is export from a combined power system. 1 is export at the point and I think that is why yeah, so the PCs in the BCC so that is why there's a difference between how a limited export system would apply in a limited. 1215 Younes, Amin 05:51:39.366 --> 05:51:41.016 Generation profile would apply. 1216 Sky Stanfield 05:51:41.376 --> 05:52:00.484 Well, I don't think we've decided that that's I think the question here is, I don't, I don't recall any conversation about playing the at a different point than than the limited export is obviously it's something we're going to need to work out, but I don't think I don't know what you're where you're reading not from but I don't recall ever that being a conscious. 1217 Sky Stanfield 05:52:00.490 --> 05:52:05.286 Conversation so, Brian, did you want to weigh in here? 1218 Brian Lydic - IREC 05:52:06.276 --> 05:52:21.634 Yeah, I just wanted to say that I think the original concept was that, you know, a power control system is managing export, whether it's for the limited limited generation. Um, whatever we call it limited export. 1219 Brian Lydic - IREC 05:52:21.784 --> 05:52:42.784 Which is just a steady state limit. Um, it's doing the same thing as you would do with the. But it's just doing it at 1 static limit. Um, and you know, how the exactly where the PCs lies in the system is up to the developer to determine where the best appropriate spot is but we're really. 1220 Brian Lydic - IREC 05:52:42.814 --> 05:53:03.634 Takes effect, from the rule standpoint is the export, and that's most likely also the place that it would technically take effect. So that, you know, if they have load at the site, they would also be able to account for all the load and serve their load before exporting. So, I think we can think about it logically as. 1221 Brian Lydic - IREC 05:53:04.024 --> 05:53:14.464 The same type of system same equipment doing the same thing, but the PCs is doing it by schedule in 1 case with the, and it's just doing it. Statically. In the other case. 1222 Roger Salas SCE 05:53:18.454 --> 05:53:37.714 And, for me, as simpler solution, Here's what we propose on, down down at the bottom, which is consistent with what there's other on the other sections. So, other of the, uh, order, which basically, if you reduce, if you're reducing your own load in impacting the IC values, then let's just be wrong. 1223 Roger Salas SCE 05:53:37.780 --> 05:53:43.564 What the real values at our location to get the most updated I see your values, assuming that they sort of load. 1224 Regnier, Justin 05:53:46.294 --> 05:53:53.676 Roger, it sounds like you are proposing that solution for both static, limited, export and limited generation profile. 1225 Roger Salas SCE 05:53:54.244 --> 05:53:54.516 Yeah. 1226 Regnier, Justin 05:53:55.116 --> 05:53:56.734 Ca value it's not to. 1227 Roger Salas SCE 05:53:57.964 --> 05:54:06.756 It'd be easy to address, you know, if we're going to be doing, it can be an export in whether it's, you know. 1228 Regnier, Justin 05:54:09.454 --> 05:54:28.414 Valuable that we've delighted this issue, um, at the top of this meeting was they did articulate the, you know, changes in how the is computed rather than the scope of this particular discussion. So, I mean, I think it is valuable that we delighted. And I think it's something we need to think about stakeholders. 1229 Regnier, Justin 05:54:28.654 --> 05:54:49.684 Commission, um, but I'm not sure this is the venue for resolving that particular question because fundamentally, it's a question, as I understand, that fundamentally is a question of when the is computing hosting capacity. Should it remove the load on site that the renewable energy. 1230 Regnier, Justin 05:54:49.714 --> 05:55:04.324 Generation facility is located prior to determining the value and it's all value. It doesn't have to do so much with the screens of the applications is what the IC value returns for consideration in. 1231 Roger Salas SCE 05:55:07.714 --> 05:55:11.044 Yeah, usually that's the case. I mean, that's that's kind of the issue, right? 1232 Regnier, Justin 05:55:12.604 --> 05:55:14.284 Yep, so I mean, I'm. 1233 Regnier, Justin 05:55:18.992 --> 05:55:32.222 Very noisy, because there's a facilitator, but I think we'd be okay with ruling this 1 out of the scope of this discussion thinking about it and bring it back up as necessary rather than discussing this particular topic. 1234 Roger Salas SCE 05:55:33.094 --> 05:55:33.332 Yeah. 1235 Regnier, Justin 05:55:33.632 --> 05:55:37.024 Computation update here. 1236 Aliaga-Caro, Jose 05:55:37.654 --> 05:55:45.394 So, uh, Justin, uh, thank you. Uh, so it looks like we need more discussion on how these screens will be applied. 1237 Aliaga-Caro, Jose 05:55:48.694 --> 05:55:57.332 That's my take away from the last few minutes that we've had on this topic, 7 and 8. 1238 Aliaga-Caro, Jose 05:55:59.614 --> 05:56:14.314 Uh, you know, from the November, 10 smarter were the working group might take out of that with that and oh, and parts of P would study the value. But now. 1239 Aliaga-Caro, Jose 05:56:15.934 --> 05:56:22.954 In the last few minutes I am now, my brain is a little muddy on, you know, what's going on here. 1240 Roger Salas SCE 05:56:24.394 --> 05:56:45.304 Yeah, I mean, it seems to me that again, um, you know, we can resolve this relatively quickly, or or make make a make it more complicated, but consistent with what I believe is like, or in paragraph 3 or 4. we basically said something like, when the IC values needs to be updated, you Theresa, allow to. 1241 Roger Salas SCE 05:56:45.308 --> 05:57:00.454 Basically update the IC value when, you know, when, when when when, um, determining whether or not the project passes the, um, the IC values there. I mean, that's essentially what. 1242 Sky Stanfield 05:57:00.632 --> 05:57:06.094 Was like for the limited scenario where the, the value had changed in the 1 month, period. 1243 Sky Stanfield 05:57:08.104 --> 05:57:27.274 Doing this, but I think I think this is something we're all gonna have to discuss and I want to like, I think we should probably everybody should be able to adjust this. But I want to say that the idea that the whole idea of streamlining all of this and adopting an, was that you could go to a map and you could plan your system based on a profile. 1244 Sky Stanfield 05:57:27.634 --> 05:57:48.454 It takes a lot of work as as as was explained earlier, um, a customer's going to do a lot of math and a lot of deliberation to figure out a profile that works. If the isn't, they aren't going to know what the profile is. That's the problem. Now, I'm not saying that's off the table, Robert. Maybe that that's what we have to do to fix this but I think. 1245 Sky Stanfield 05:57:48.786 --> 05:58:09.904 We haven't had a chance to digest this and think through the solution. It's helpful that you put 1 forward. But I think that, that 1, my initial gut on that is that that undermines the ability for customer to even design a profile because I don't actually know what the profile is being designed around. If I say it has to be rerun on the customized basis. And so I. 1246 Sky Stanfield 05:58:09.936 --> 05:58:31.054 Think that we have to think more about whether this is a real issue how it's accommodated and I'd like to Jose and Dustin I think, you know, credit to the utilities. We're identifying this as a potential issue. Overall. Maybe we need to talk about what they have a separate call or something to think about this. I think again, I don't think it's really an issue, but it's, it's an issue potentially. 1247 Sky Stanfield 05:58:31.082 --> 05:58:34.322 An issue that we all need to digest and confer on. 1248 Roger Salas SCE 05:58:35.794 --> 05:58:36.094 Yeah. 1249 Sky Stanfield 05:58:36.394 --> 05:58:36.964 Um. 1250 Sky Stanfield 05:58:38.854 --> 05:58:44.794 If we're agreeing that we should pause this for that reason, I wanted to go back into some of our customers. The other slide. 1251 Aliaga-Caro, Jose 05:58:47.344 --> 05:58:58.894 Uh, yeah, go ahead. Slide. Uh, I did want to say that, you know, my, and thank you for this graph, uh, to utilities cause I had not considered this at all. Uh, my take from export. 1252 Aliaga-Caro, Jose 05:59:00.036 --> 05:59:20.164 Was basically what is actually being put outside onto the grid itself after load has been after load that's its job and consumes, you know, whatever comes out of the. So, because that ultimately is what. 1253 Aliaga-Caro, Jose 05:59:20.410 --> 05:59:21.634 Fix the, um. 1254 Aliaga-Caro, Jose 05:59:24.062 --> 05:59:37.114 The quality and reliability of the grid. So I like I said, I think you, uh, to utilities for putting this, uh, diagram because I had not considered this scenario before. 1255 Sky Stanfield 05:59:38.312 --> 05:59:44.374 The other thing to keep in mind too, just for everybody's digestion is, is that the ice as we talked about the 24. 1256 Sky Stanfield 05:59:44.404 --> 05:59:58.744 Our profile, it's not being designed around actual, an actual profile. So some, there's some other issues with the way the load is already being incorporated into the, and it'll have to be in this mix as well. 1257 Sky Stanfield 06:00:00.484 --> 06:00:05.464 I think, okay, going back, go back to the earlier slide. If you could please. 1258 Sky Stanfield 06:00:09.094 --> 06:00:21.004 So, uh, 1 other and this is maybe a smaller well, I shouldn't say that I've never never end up being that way. So I appreciate the difference between the application versus the. 1259 Sky Stanfield 06:00:21.064 --> 06:00:42.184 In terms of what you might be looking at, in terms of, like, what actually happens though, when there is an operational flexibility issue, and there needs to be an emergency reconfiguration. It seems to me, like, the options that are on the table at the same either way, you're going to do the emergency reconfiguration. The customer is going to be curtailed. Like we talked about already what would happen in those. 1260 Sky Stanfield 06:00:42.190 --> 06:01:03.334 Circumstances it may be that it that happens could happen more often if you didn't reject the project because of, which is a whole, another big conversation. But I just wanted to confirm what, if you do that reconfiguration you're not going to have the project exporting. You're going you have the ability under. 1261 Sky Stanfield 06:01:03.340 --> 06:01:14.164 Our emergency emergency conditions, or whatever we want to call it to curtail that project until the reconfiguration is reversed back to normal essentially. Right? 1262 Yi Li SDG&E 06:01:15.574 --> 06:01:24.276 Yeah, so to provide some background, we're providing this just to, to lay out the risk right? Cause that was the discussion of the worst stop number 1. 1263 Yi Li SDG&E 06:01:24.876 --> 06:01:45.574 We're not saying that this doesn't change our position as how we're gonna handle in the emergency situation but that is something that we don't have to deal with as often if a project did stay under the. Right. So I think that's something that we should probably agree to is that there is a different level of likelihood that. 1264 Sky Stanfield 06:01:46.654 --> 06:01:48.844 I don't know that that is quite right. 1265 Yi Li SDG&E 06:01:48.874 --> 06:01:49.834 Because. 1266 Sky Stanfield 06:01:50.464 --> 06:02:06.724 We don't know how you guys are applying the, what you're doing when a project fails the, and it gets to something That'll review. This has been a big problem, right? Is you guys haven't defined what you're actually going to do? Are you going to say that a project a regular project? 1267 Sky Stanfield 06:02:06.790 --> 06:02:27.904 Whether it's limited generation or not limited export or not. Is are you going to reject projects that go below the and might require them to do upgrades? If so we're pretty much it's going to be radically expensive interconnection across the state of that's the case that you guys have sort of been said. 1268 Sky Stanfield 06:02:27.940 --> 06:02:39.304 We're going to do it on the case by case basis, I think, with no guidance on what how that will actually be evaluated but you haven't said every project that violates will actually have to do upgrade. 1269 Yi Li SDG&E 06:02:39.514 --> 06:02:49.084 No, I, I disagree that we provide no guidance. I mean, our rule 20 ones very clearly laid out what the process will be. If a project fell icaay. No. 1270 Yi Li SDG&E 06:02:49.116 --> 06:02:51.634 And when it's, you know, novel. 1271 Yi Li SDG&E 06:02:52.266 --> 06:02:52.536 Right. 1272 Sky Stanfield 06:02:53.644 --> 06:02:55.026 That language is that. 1273 Yi Li SDG&E 06:02:55.054 --> 06:02:55.624 Kind of. 1274 Sky Stanfield 06:02:55.624 --> 06:02:56.494 What you're going to do. 1275 Yi Li SDG&E 06:02:56.616 --> 06:02:58.564 Yeah, my screen, I'm Ashley, I took the. 1276 Sky Stanfield 06:02:58.564 --> 06:02:59.134 3. 1277 Yi Li SDG&E 06:02:59.134 --> 06:03:12.696 1 yeah, screen yeah, you can see that. I have a project sales is going to go to technical screening and our engineer will do an analysis to see what's causing this to be on. And the problem here is that we're seeing, is that. 1278 Yi Li SDG&E 06:03:13.082 --> 06:03:34.204 Without screening, we don't have the ability to do studies. Right that's the whole point of using to fast track. These application. That may be it'll allow it to operate above. So, we don't have the ability to perform the studies to even understand what those limit violation is, to your point. 1279 Yi Li SDG&E 06:03:34.774 --> 06:03:55.354 If we did do those studies, we, our engineer may be coming up with scenarios that we can do, we can implement some steps to mitigate the issue. Right. For example, switching or we know that there was a problem. That will cause reverse flow on this particular application. But what we're saying here is that for customer, they don't even get. 1280 Yi Li SDG&E 06:03:55.360 --> 06:04:13.474 Probably against the right so there's no further study no technical review against that point because they don't really like, unless, you know, someone who's not doing mass, they wouldn't really even go through and fail screen, em, in the scenario for customer. 1281 Yi Li SDG&E 06:04:19.714 --> 06:04:23.884 Just so I, I don't know if your hands are from before, or you have a question here. 1282 Yi Li SDG&E 06:04:30.664 --> 06:04:32.344 Dustin, hey, there. 1283 Regnier, Justin 06:04:33.124 --> 06:04:34.564 Yeah, um. 1284 Regnier, Justin 06:04:36.392 --> 06:04:57.242 No, my comment, I wanted to make sure that we got into the discourse here has to do with sky's point last time about not only risks to the system, but benefits for systems. So, I think we, we do want to make sure that we daylight the benefits for the system unique benefits through the system. 1285 Regnier, Justin 06:04:57.482 --> 06:05:00.604 Not just the ones for the customers. 1286 Regnier, Justin 06:05:01.714 --> 06:05:08.824 Operating at a higher capacity factor was represented in the last 1 as a benefit for rate Paris. 1287 Regnier, Justin 06:05:10.116 --> 06:05:29.346 I can see why that would be, but we don't have a record built around us. So we should probably speak to what that benefit is at some point. Um, I think that the non parties have been very Frank and direct about, um, you know. 1288 Regnier, Justin 06:05:31.596 --> 06:05:52.384 The fact that more full utilization, higher capacity, factor of existing infrastructure reduces the flexibility of the to manage the grid. So they have less options available to them potentially. So, we're, we're making that trade off. 1289 Regnier, Justin 06:05:52.414 --> 06:06:04.654 On a conscious basis, I just want to make sure that we get into the record what we started. The benefits of a higher capacity factor grid are are running the grid at a higher capacity factor on. 1290 Yi Li SDG&E 06:06:06.064 --> 06:06:13.504 When you say running a good a higher capacity, provide benefits to all the repairs, what are the. 1291 Yi Li SDG&E 06:06:13.564 --> 06:06:14.314 Record on that. 1292 Sky Stanfield 06:06:16.864 --> 06:06:18.634 I think what he's asking is, is that we. 1293 Regnier, Justin 06:06:18.634 --> 06:06:19.384 Trying to build. 1294 Sky Stanfield 06:06:19.504 --> 06:06:21.094 To build the record on that. 1295 Regnier, Justin 06:06:21.124 --> 06:06:21.394 Yeah. 1296 Sky Stanfield 06:06:21.904 --> 06:06:37.504 And Justin, we can talk about where that comes in, I guess, but I don't think I think there's a real basic element here that is clear that there's, I don't know if any of you guys are an customer. 1297 Sky Stanfield 06:06:37.536 --> 06:06:58.654 But if you get between 5 and 60 PM a request to reduce your load all the time, during those hours, it's because we don't have enough energy. And what we're trying to do is provide more energy during those critical hours. That's the whole story here. And without having to upgrade the grid, because it's not needed, but California has a. 1298 Sky Stanfield 06:06:58.660 --> 06:07:19.804 Position shortage during those critical hours that either we're going to solve by reducing load through demand response, which is 1 thing that's being explored. We're going to build more generation and potentially have to build more generation plus more grid essentially to do that. And we can avoid that. If we allow projects to perform with. 1299 Sky Stanfield 06:07:19.832 --> 06:07:40.954 The system constraints, that's our basic characterization of the issue. And I think that means point whenever nobody's modeled all that that's not but I don't think it's very far off basic conceptual understanding of that's what the point is is and we know, I mean, it's headline national news that California needs more power during certain. 1300 Sky Stanfield 06:07:40.984 --> 06:08:02.104 Hours of the day, especially during certain times of the year and that grid constraint if we decide that they have to upgrade the grade, even though it doesn't need to be upgraded to provide that that is going to raise cost. I mean, that's just as simple as kid who's going to pay those costs. That means point. That will be decided, depending on how the rates are. 1301 Sky Stanfield 06:08:02.110 --> 06:08:11.404 And so on, but the interconnection customer, or the developer will certainly be paying the cost if they have to upgrade the grid in order to provide it, because that's how the cost allocation rules. 1302 Yi Li SDG&E 06:08:16.594 --> 06:08:35.914 Um, I, I, I think I've been sick for too long intelligence level has jobs. I'm not drawing a direct line between, like, when we're having a big issue and how is necessarily going to help that problem. Um, and cause I. 1303 Yi Li SDG&E 06:08:35.974 --> 06:08:56.884 To say that, you know, it's not really threatening or there's not enough. At least to me that LGB is really going to, like, avoid up your costs. Maybe you can defer it. Cause utility are still incurring a lot of costs for the down the road to install the upgrade. If it's inevitable you need it. 1304 Yi Li SDG&E 06:08:57.184 --> 06:09:00.364 And let's not forget all the costs that's encouraged right now. 1305 Sky Stanfield 06:09:00.484 --> 06:09:02.824 But if they don't really wouldn't be needed is the. 1306 Roger Salas SCE 06:09:03.814 --> 06:09:18.244 Right, the only way to prevent that from happening is to not allow any more are below 1 mill what require upgrades because what really is going to happen here. 1307 Roger Salas SCE 06:09:18.248 --> 06:09:19.652 Is that analogy the. 1308 Roger Salas SCE 06:09:19.660 --> 06:09:37.294 Project is going to take this, look it up to the maximum level. They don't have to pay for the upgrade then a few months later a less than 1 megawatt. Any price is going to come in. We can tell them that that project and therefore we're going to do the upgrades of the customer repair. 1309 Regnier, Justin 06:09:45.664 --> 06:09:56.044 I don't think anybody's got a crystal ball in terms of how things will happen after inner connection. But that is thank you for sharing perspective on likely outcome. 1310 Yi Li SDG&E 06:10:03.754 --> 06:10:06.844 Uh, I I actually believe these are my last slides. 1311 Yi Li SDG&E 06:10:07.564 --> 06:10:10.474 Collecting the slides sorry? 1312 David Schiada 06:10:10.504 --> 06:10:20.284 Just, yeah, this is Dave just before we move on just Dave shot just a question, Justin so I'm understanding kind of the, uh, expectation. 1313 David Schiada 06:10:20.290 --> 06:10:41.104 On on getting benefits on the record was, is it that, that the, I owe you advice letters would include something like W. W during workshop discussions. There was consensus that the extent there were tools and processes that allowed. 1314 David Schiada 06:10:42.064 --> 06:10:50.194 More, uh, higher efficient use of the grid. Those should be encouraged because they could benefit customers. Is that. 1315 David Schiada 06:10:51.332 --> 06:10:53.042 That or is there anything more than that? 1316 Regnier, Justin 06:10:55.954 --> 06:11:15.274 I think, unfortunately, Brad is not here and he's the 1 that articulated it. And this is something that came out of our review of the, the video last time. But there's an assertion that a higher capacity running, the greater, the higher capacity factor provides benefits. Um, we want to make sure that. 1317 Regnier, Justin 06:11:15.280 --> 06:11:20.494 We understand what stakeholders mean by that. So it captured in the record um. 1318 Regnier, Justin 06:11:23.912 --> 06:11:24.184 Yeah. 1319 David Schiada 06:11:24.364 --> 06:11:24.844 Yeah. 1320 Regnier, Justin 06:11:24.844 --> 06:11:36.662 Get a conjecture about Brad man, I can think of of ways. That that might be true, but I want to make sure that we hear from the stakeholders what they're seeing as the benefit to our capacity factor. 1321 David Schiada 06:11:39.274 --> 06:11:50.014 Okay, then just be helpful to get that input from Brad or others to the extent that there's any expectation that that would be reflected in an advice letter. So thanks. 1322 Sky Stanfield 06:11:50.284 --> 06:12:00.364 Can I just I'm, I'm not sure. Did my explanation not make sense to anybody I, I don't understand. I, this is in my mind very simple. And what I'm hearing is, is that we need Brad doing. 1323 Sky Stanfield 06:12:00.424 --> 06:12:09.332 Explain it, and maybe, maybe if we have him explain it better than I, but I'm not sure if I'm understanding why this isn't pretty simple. 1324 Regnier, Justin 06:12:09.962 --> 06:12:14.524 Understood what you said, not sure that it's the entirety of what Brad would have said. Right Hmm. 1325 Sky Stanfield 06:12:14.552 --> 06:12:21.542 I'm sure that's fine but okay. And but today's question are you not are you do disagree. 1326 Sky Stanfield 06:12:21.548 --> 06:12:42.454 With my characterization, or what I want to make sure that I do understand if I'm wrong about the basic concept here that providing more energy during the times when California most needs it, it's going to be no specific, et cetera without upgrading the grid is a better a lower cost way. 1327 Sky Stanfield 06:12:42.724 --> 06:12:50.854 providing the energy than it is to upgrade the grid when it doesn't need to be upgraded to provide that additional energy 1328 David Schiada 06:12:52.864 --> 06:13:12.364 Yeah, yeah, I understand that why I'm just looking at, from the perspective of, you know, when I asked my managing director to sign off on the advice letter of what's being represented cause it's not I think it's still an advice letter that will be filed. And if it's representing, you know, that these were discussions that were held during the workshop. 1329 Sky Stanfield 06:13:12.392 --> 06:13:12.722 Yeah. 1330 David Schiada 06:13:12.754 --> 06:13:13.684 And it was. 1331 David Schiada 06:13:13.746 --> 06:13:34.866 Consensus that, you know, more efficient use of the grid while being able to operate reliably and safely can provide a benefit to, uh, customers, you know, if it's along those lines. I think that's something we could probably represent if it goes beyond that. Or if I'm not fully aware of either your position or brad's position, it's hard. 1332 David Schiada 06:13:34.894 --> 06:13:38.134 To incorporate that in the advice that are given the time we have. 1333 Sky Stanfield 06:13:40.234 --> 06:13:40.894 I mean. 1334 Younes, Amin 06:13:41.920 --> 06:14:03.064 When you say to customers, I just want to clarify that. The point that that guy had mentioned is that that exact way that those ddrs are compensated, makes a huge difference in terms of whether, or not there's a benefit to the customers. I would say that there's a potentially a societal benefit from animating or using those low cost resources, or those existing resources. 1335 Younes, Amin 06:14:03.274 --> 06:14:12.274 Without without upgrade integrated, but whether or not that provides a benefit to rate pairs, certainly, you know, it depends on exactly exactly how that happens. 1336 Sky Stanfield 06:14:13.322 --> 06:14:24.212 And I think that's, I hope I made that clear that I am. I understand that. That's the case. But I also think this is where we have the sort of bifurcated we need to design and interconnection policy. 1337 Sky Stanfield 06:14:24.246 --> 06:14:45.366 separate from the rate structures and the commission can take this into account in the rate structures but if the interconnection policy does not allow a project to do a limited generation profile and requires the upgrades to happen that that value can't be captured even whether it's captured by the customers or just the developer the interconnection rules are separate from the rate rules and that's part of the problem we're having 1338 Sky Stanfield 06:14:45.394 --> 06:15:06.514 We're trying to set up the International was to enable those, those pricing opportunities and so on. So there's a chicken and egg a little bit. But but the interconnection policy is that the customer pays for the upgrades, unless you allow them to do an, and that cost is going to get built into the project either way. Now, whether they get competent. 1339 Sky Stanfield 06:15:06.542 --> 06:15:27.602 Fully for that, or not goes into the rate proceedings, but here that's why if we don't enable it, it will never happen. You can never capture that benefit if the customer, or you can never capture the savings. You can get the customer to upgrade the grid. If you pay them even more, but that's and I think it would be fabulous to have some. 1340 Sky Stanfield 06:15:27.696 --> 06:15:48.814 Data numbers, I don't know this, but I think that's not going to happen in our proceeding. I think what we're trying to do, I'm trying to do is to enable that capability, so that the commission can do the right rate setting around it. But without that capability, there will be no no option for the customer to do what the commission is trying to encourage, which is performance. 1341 Sky Stanfield 06:15:48.844 --> 06:15:51.124 During peak hours and non pccoe. 1342 Eva Wang TotalEnergies 06:16:08.914 --> 06:16:26.884 I want to comment on, um, into his comments about the whole point of, to defer upgrade instead of, you know, the eliminate upgrades. If that's the case right? If we have to have some sort of upgrade. 1343 Eva Wang TotalEnergies 06:16:26.914 --> 06:16:48.034 Sound road then I would say, like, all of our customers won't be interested in doing this, because that that's just saying that we have to pay anyway down the road sometime down the road. And then that also like a hanging thing, like the uncertainty that on top of what we are going to. 1344 Eva Wang TotalEnergies 06:16:48.040 --> 06:16:57.064 Here, and then still have to go through like, 10 years limited generation. Um, other than full export. 1345 Eva Wang TotalEnergies 06:17:00.364 --> 06:17:09.542 So the whole point is to eliminate upgrades here for the out GP customers, not to defer the upgrades. 1346 Regnier, Justin 06:17:10.412 --> 06:17:20.374 Well, and that's why I stepped in when Roger spoke that I think the entire idea is to eliminate upgrades where possible and maximize the hosting capacity that. 1347 Regnier, Justin 06:17:20.470 --> 06:17:41.556 Already has been paid for by rate. Paris is Brad articulated in last workshop. If you assume on every limited generation profile application, there will be a subsequent upgrade that is required. Um, negate at least some of the benefit. I don't know that the are taking the position that they think. 1348 Regnier, Justin 06:17:41.620 --> 06:17:54.604 But every limited generation profile application will be followed by a subsequent upgrade that cost is born by the repair. That seems a bit of an extreme position based on the record. But I don't want to put words in their mouth. 1349 Roger Salas SCE 06:17:55.564 --> 06:18:02.764 Yeah, I mean, I, I think that does get to be determined in my opinion, because the reality in general, I think is going to be that you can. 1350 Roger Salas SCE 06:18:02.792 --> 06:18:23.792 With 1, limited generation project per circuit, because, as we've shown before and LGB project essentially maximizes why you can put on that circuit. That's exactly essentially what what he's doing. And so, let me know, capacity left over for future projects, you know so if you have any. 1351 Roger Salas SCE 06:18:24.154 --> 06:18:45.064 That comes afterwards that is, you know, up to 1 megawatt and, you know, we cannot tell that, that any project that they have to curtail, we have to connect them and, you know, we'll see what happens, you know, that's my prediction. And I'm having, you know, nearly 15 years of condition experience, but. 1352 Roger Salas SCE 06:18:45.094 --> 06:18:53.162 I think that was going to happen is probably gonna take it off, blow it to his maximum value. Any enterprise is gonna come in and we'll have to re, upgrade. 1353 Sky Stanfield 06:18:53.972 --> 06:18:54.332 I think. 1354 Regnier, Justin 06:18:54.332 --> 06:18:54.572 Well. 1355 Regnier, Justin 06:18:56.374 --> 06:19:13.384 I would, I would point back to our last workshop discussion where we kind of all had consensus that the most likely outcome is that we're not going to run into future issues with the parting load that, that, uh, require a subsequent upgrade. So, I think. 1356 Regnier, Justin 06:19:14.706 --> 06:19:15.484 We don't know. 1357 Roger Salas SCE 06:19:15.904 --> 06:19:16.294 We don't know. 1358 Regnier, Justin 06:19:16.294 --> 06:19:35.464 We don't know what's going to happen with increased blood and electrification. There are a whole bunch of different variables that we just can't know about. So, I don't, I don't know if the are taking an official position that they think that I see I had handshake from Rogers. Maybe I don't even need to finish that but. 1359 Roger Salas SCE 06:19:36.184 --> 06:19:56.972 That's my my personal opinion, that position, John, my personal opinion, having done, you know, nearly 15 years of, you know, conditions customers like to go where there's no upgrades and any projects the only way to care. Right? There's any price less than 1 megawatt. Connect me. And they don't care whether they're or non and. 1360 Roger Salas SCE 06:19:56.978 --> 06:19:59.374 You know, we will have to connect them anyways 1 way or another. 1361 Younes, Amin 06:20:01.174 --> 06:20:05.912 That it phase 2 could change that. Right? That's my understanding. Phase. 2. this proceeding could. 1362 Roger Salas SCE 06:20:07.082 --> 06:20:12.124 Not for 1 megawatts and less then 1 megawatt less we're required to pay for the upgrades. 1363 Regnier, Justin 06:20:13.504 --> 06:20:15.992 That would be an proceeding that's outside of scope. 1364 Roger Salas SCE 06:20:16.292 --> 06:20:17.764 Yeah, W, the DNA proceeding, right? 1365 Younes, Amin 06:20:18.184 --> 06:20:19.834 My understanding of the scope of. 1366 Younes, Amin 06:20:20.104 --> 06:20:20.674 2, is that. 1367 Younes, Amin 06:20:23.524 --> 06:20:24.934 Allocation broadly. 1368 Roger Salas SCE 06:20:26.494 --> 06:20:27.184 I don't think enough. 1369 Sky Stanfield 06:20:28.294 --> 06:20:28.594 And that. 1370 Alex Mwaura PG&E 06:20:28.594 --> 06:20:29.104 Actually, come. 1371 Sky Stanfield 06:20:29.104 --> 06:20:43.504 From another statute, not just from the commission that the costs would be way and I think it's also important to remember that those upgrades directly have been very affordable as its own device letter just points out that raises the cost for a small amount. So. 1372 Sky Stanfield 06:20:43.510 --> 06:20:57.366 I don't think this is a big point of should be a big point of contention. Yeah, Jose can we? I think we're we only it's 230 and we haven't gotten direct proposal and I'm wondering if we should just move off of this. 1373 Aliaga-Caro, Jose 06:20:57.394 --> 06:21:04.624 Yes, uh, sky was just gonna, uh, recommend that. So it seems like, uh, regarding this. 1374 Aliaga-Caro, Jose 06:21:04.660 --> 06:21:23.196 Topic and the screens, we do need further discussions, uh, which are part of, uh, you know, the upcoming resolution uh, 5,230. so, uh, Cory, could you bring up, uh, presentation? Please, thank you. 1375 Sky Stanfield 06:21:32.464 --> 06:21:32.734 But. 1376 Aliaga-Caro, Jose 06:21:33.004 --> 06:21:34.234 go ahead 1377 Sky Stanfield 06:21:35.134 --> 06:21:36.694 Can you move on to the next slide? 1378 Sky Stanfield 06:21:40.082 --> 06:21:59.552 All right, I'm going to try to move us through some of this fairly fast, because I think most of the basic points have been talked out. What I, what I set up in these. 1st slides is just sort of layout Narratively where I think we stand. Um, in terms of of what to help us get to what the core issues are. 1379 Sky Stanfield 06:21:59.764 --> 06:22:20.792 We've talked about most of this on here, we've already addressed that the permanent grid modification and future expansion of the grid are non specific issues per se. And I think the main thing that that there seems to be some agreement around is that the risk of the long term reduction is the primary sticking point. 1380 Sky Stanfield 06:22:20.824 --> 06:22:38.644 The potential emergency reconfiguration, which are curtailment, which could apply to other projects. I haven't heard concerns from any parties about that. Especially with the understanding they're going to be treated as other customers. So, next slide please. 1381 Sky Stanfield 06:22:43.114 --> 06:23:01.564 So, focusing in here, I think what we've heard from the utilities, in terms of the safety reliability issues that they had done that they think could trigger or could be triggered are largely going to come from reductions or changes in the load profile. 1382 Sky Stanfield 06:23:02.164 --> 06:23:22.744 They're quoting from the earlier slides that would be the most impactful grid condition and those could result in either expenses a voltage or thermal limits. The problem underlying all of this is that no data has been provided to characterize the likelihood that this would. 1383 Sky Stanfield 06:23:24.332 --> 06:23:43.954 Or how likely how often it would occur, or we're completely operating on basic assumptions that it won't happen often, but nobody has any grasp on the magnitude of how often it could potentially happen in the future. Similarly. If it did occur, we're also operating on a lack of data. 1384 Sky Stanfield 06:23:43.990 --> 06:24:05.134 About what the potential costs could be, if it did occur. So these 2, I think unknowns, which aren't necessarily which, to some extent, are always unknowable because they will always rely on speculation about future grid conditions, but potentially could be modeled out further to, to means point earlier, I think, are really driving. 1385 Sky Stanfield 06:24:05.164 --> 06:24:26.284 Where the difficulty is here, because what these come down to is that neither the ratepayers, nor the interconnection customer has ability to grasp what the risk is. And that makes financing a project difficult. And it also makes it difficult for the utilities and rape her advocates. 1386 Sky Stanfield 06:24:26.314 --> 06:24:47.434 Included to know what the potential impacts could be for repairs. If they were on the hub. I just wanted to put that basic data problem out there. Because I think that is what underlines all the all the discussion we're really having. And then from an applicant standpoint, applicants have little if any ability really to know. 1387 Sky Stanfield 06:24:48.004 --> 06:25:07.624 Whether the conditions will arrive the data problem and because they're entirely dependent on a factor that's out of basically everybody's hands, which is the, a hypothetical customer or customers on the grid, changing their behavior in a way that nobody can predict. So, next slide please. 1388 Sky Stanfield 06:25:12.632 --> 06:25:29.732 So, we're looking at with that sort of background what really been trying to do is think around well, how do we manage that risk and what is the right way to a portion that risk or mitigate or manage that risk? And whether it's. 1389 Sky Stanfield 06:25:30.154 --> 06:25:50.856 Fully on the, the customer fully on the right payer or some combination they're in. I think that that's the major sticking point. And this is really a summation of what we've already talked about. Utilities are proposing that minor upgrades or mitigations. They'd be willing to do, but for any longer term or a major of. 1390 Sky Stanfield 06:25:50.888 --> 06:26:12.034 That that would be on the shoulders of the introduction customer. Um, and that what that means for the interconnection customer, is that the only limitation on the risk is that they would not be reduced below the minimum, which translates to. 1391 Sky Stanfield 06:26:12.064 --> 06:26:33.184 Again, I'm sorry, if I'm being super simplified here, what it translates to is that the economics of the project potentially have to be such that any additional capacity you build on top of the is entirely profit, because they have no ability to absorb under. 1392 Sky Stanfield 06:26:33.214 --> 06:26:54.334 And the risk, the likelihood it would happen, or the potential costs for any upgrade, should they be required to do 1? So they're working on and this is somewhat simplified. But basically, the idea is that the economics would have to work out that the rate structures, or the procurement vehicles are structured. So that, anything above that. 1393 Sky Stanfield 06:26:54.338 --> 06:27:15.062 C. A. S. G is purely access profit and the project would have to already pencil out otherwise. So, my, I don't have any economic data to say whether that is the case. And as the, they don't know either. But I think that it is highly unlikely that that is. 1394 Sky Stanfield 06:27:16.054 --> 06:27:33.394 Um, I don't think the project economics are so wonderful, especially when it comes to batteries at this point that that's likely to incense a lot of projects to build capacity without having any guarantee that they could recover some additional profit from it. Next slide. Please. 1395 Sky Stanfield 06:27:37.082 --> 06:27:56.374 So, what I want to do with that sort of basic background, is I want to talk about what been trying to do, and where we've gotten to in our conversations with the development community. And this, of course, is where we need to invite lots of participation from the developers and other non party. 1396 Sky Stanfield 06:27:56.378 --> 06:28:17.524 And then put on the table a, I wouldn't call it yet on direct proposal, but an alternate approach that we've come up with to try because we haven't been successful in the 1st column. So, let's get to what we, we had a call with the, with some members of the development community. 1397 Sky Stanfield 06:28:17.530 --> 06:28:38.644 Have been participating in these calls yesterday to try to really talk about what I'm broadly calling our costs and it could be characterized either as a cap on what the upgrades would be or a cap on the amount of the project or the duration in which the project would be reduced. We can see both pros and cons to doing a. 1398 Sky Stanfield 06:28:38.706 --> 06:28:59.824 +, and I kind of lead those out on this slide. But the conclusion that we've come to is that because of all the different unknowns and variables that we have right now, both in terms of the basic data problems that we've already characterized, and the fact that every profile is different and. 1399 Sky Stanfield 06:28:59.854 --> 06:29:20.882 We have a sort of a still emerging market to provide the price signals around that time of use again, the chicken and egg problem. We weren't able to come to an approach that would enable us to arrive at a rational cap that could be applied in the terror as a generic application. 1400 Sky Stanfield 06:29:21.242 --> 06:29:42.124 Every single example, would would require a huge amount of customized modeling analysis on a project by project basis. Um, so that's, that's where I rec, landed at the end of the conversation about how to impose a cost. Not that developers aren't willing to absorb some of the risk meaning if they. 1401 Sky Stanfield 06:29:42.154 --> 06:30:03.244 Operate with some bounds around what the risk is, they could potentially make projects work, but what those bounds would have to be. We were stumped on how to actually get there, especially within the timeframe that we're working with. I want to pause there and make sure everyone's following. Why where I'm at with that and also open up the. 1402 Sky Stanfield 06:30:03.280 --> 06:30:24.394 Conversation with does do others have ideas on how we would get to a rational cap? Oh, and I guess I should say the idea with the cap again, whether it's an upgrade upgrade amount or a reduction cap is that we would be splitting splitting the sharing the risk. The risk would be some of the. 1403 Sky Stanfield 06:30:24.430 --> 06:30:45.574 This would be on the customer, the initial risk would be on the customer, but in the end, the rate pairs would still be on the hook to some extent. And again, that is unknowable based on the data gaps that we have. So, I'll pause to see if anybody has thoughts on that, or has other creative ideas. 1404 Sky Stanfield 06:30:45.578 --> 06:30:51.844 On how we would develop a rational approach to designing a cap. 1405 Roger Salas SCE 06:30:55.024 --> 06:31:13.354 Yesterday, my comments more about just no, no, no the proposal server, which is what we are allowed to do here. I mean, are we even allowed to put repairs in as part of the discussion here? I mean, I just don't know whether that's even borrowed. What's allowed here? 1406 Aliaga-Caro, Jose 06:31:14.014 --> 06:31:15.034 So, uh, Roger. 1407 Aliaga-Caro, Jose 06:31:15.244 --> 06:31:22.594 That would fall into phase 2, but right now we do need some sort of path forward to make this happen. 1408 Aliaga-Caro, Jose 06:31:23.822 --> 06:31:36.902 So, ultimately, you know, that would be determined into phase 2 of the proceeding. So, but we do need something to feed into phase 2. 1409 Roger Salas SCE 06:31:38.072 --> 06:31:44.792 So, just for me to understand what you're saying is that, you know, a proposal would proposals with. 1410 Roger Salas SCE 06:31:44.798 --> 06:32:02.284 Be developed standard under these work. Those proposals would then be sent over for phase 2 and phase 2 would then approve the proposal the proposal or maybe. Is that the sequence or or the wrong. 1411 Aliaga-Caro, Jose 06:32:02.734 --> 06:32:05.824 Uh, yes, that would be the sequence cause the advice letter. 1412 Aliaga-Caro, Jose 06:32:05.974 --> 06:32:27.094 Not do any, uh, rate making, uh, advice letters do not handle rate making issues, but, you know, these advice letters are feeding into phase 2 of the r170707. So, without any type of thing. 1413 Aliaga-Caro, Jose 06:32:27.124 --> 06:32:36.034 Information to discuss costs then there is no information for phase 2 to. 1414 Aliaga-Caro, Jose 06:32:40.384 --> 06:32:42.514 Not continue, but to, uh, you know. 1415 Aliaga-Caro, Jose 06:32:44.042 --> 06:32:46.712 You start up discussions. 1416 Sky Stanfield 06:32:48.752 --> 06:33:05.162 I think the other thing I'll say there is, I mean, maybe the, the intent with phase 2 was just discuss the cost of implementation of the, um, I don't think it's not exactly how it's characterized, but I'm going to be clear that from the beginning that we. 1417 Sky Stanfield 06:33:05.676 --> 06:33:26.106 We're trying to be practical here and I I believe that the commission will also allow us to be practical here. And what we have identified is that no project is going to go ahead if there's not some risk mitigation on way that they can mitigate. I don't know what the right way to exactly characterize. It is but have some certainty. 1418 Sky Stanfield 06:33:26.374 --> 06:33:47.462 And they might be able to bear some risk, but they need to know what that risk is. And ideally it probably needs to be kept in some now. Um, beyond, just the, that's what we're assuming. And if the commission wants to say, nope, then again, no benefit of that it seems unlikely to mean that the commission would. 1419 Sky Stanfield 06:33:47.556 --> 06:34:00.006 To throw up our hands in that way I don't speak for the commission, but as a, as a, you know, long term interview, I do think the commission probably wants us to be practical and that's what we're trying to grapple with. 1420 Sky Stanfield 06:34:13.234 --> 06:34:14.944 Justin, you waiting for me to call on, you. 1421 Aliaga-Caro, Jose 06:34:17.434 --> 06:34:18.572 Oh, go ahead. 1422 Regnier, Justin 06:34:20.254 --> 06:34:20.972 Um. 1423 Regnier, Justin 06:34:24.036 --> 06:34:27.336 Yes, I was waiting for it to be called on, um, the. 1424 Regnier, Justin 06:34:30.062 --> 06:34:50.732 Per discussion earlier today, it sounds as though the parameter that concerns a developer is risk of loss of revenue on 1 end and imposition of upgrades at a later point, or in position on the cost of upgrades at a later point. 1425 Regnier, Justin 06:34:51.846 --> 06:34:55.324 In prior conversations, um. 1426 Regnier, Justin 06:34:57.392 --> 06:35:15.034 And smarter working group, at least, there's been a discussion that the once the developer has developed the project having to go back and then pay for things is is very difficult to accountants. So it seems as though. 1427 Regnier, Justin 06:35:16.324 --> 06:35:37.444 Locking in the maximum exposure at the time of application would be beneficial to developers. Um, what that what seems to fall from that in my mind is rather than having a cap amount. Well, I guess the 3rd element. 1428 Regnier, Justin 06:35:37.450 --> 06:35:51.754 That right now, uh, business, as usual is that rate pairs pay for upgrades to allow interconnection agreement terms to be honored just as a matter of course. 1429 Regnier, Justin 06:35:54.274 --> 06:36:13.444 1 of the concerns that the have raised is paying an exorbitant amount of money for an upgrade that has minimal benefit to either the customer or the rate pair. Where all that leads. My simple brain. Is that rather than a cost cap on upgrades later. 1430 Regnier, Justin 06:36:14.524 --> 06:36:23.104 Um, we haven't established even there's a separate customer category where they'd have to pay for upgrades later. 1431 Regnier, Justin 06:36:25.594 --> 06:36:46.534 It may make sense to take a look at a threshold for upgrades that restore the original export values that some percentage loss of revenue to the developer because that front. 1432 Regnier, Justin 06:36:46.594 --> 06:37:07.654 All of the considerations to the time of interconnection, but also limits the rate pairs exposure to what would be turned by some as an imprudent investment. Um, let's I'm not sure any of that made sense but that's that's where my brain goes upon seeing. 1433 Regnier, Justin 06:37:07.744 --> 06:37:08.914 Dave shade of Scott. 1434 David Schiada 06:37:13.474 --> 06:37:33.036 Yeah, um, if I can get on video here. All right. Um, yeah, I was just trying to just conceptually understand how the cost cap, um, concept would work and it is it I get the time of interconnection. There would be, um, and I'll make up a number here. 1435 David Schiada 06:37:33.094 --> 06:37:38.642 Because I I do agree arriving at a rational cap is challenging. Um, but if you said. 1436 David Schiada 06:37:40.174 --> 06:38:01.264 Let's say, 50,000 dollars if if the, um, so the customer would interconnect and if down the road, let's say, load departed and then the utilities would, um, necessitate an upgrade to restore the introduction agreement. Um, uh, capacity value, then the utility would. 1437 David Schiada 06:38:01.922 --> 06:38:20.462 Pursue that upgrade and if it costs 60,000 dollars, then the customer would pay 50,000 the generator generator. And then 10,000 would be recovered by the utility through distribution rates from, from ratepayers is that the basic construct there or. 1438 Sky Stanfield 06:38:20.582 --> 06:38:22.412 So, there's 2 ways to do it. I think that's. 1439 Sky Stanfield 06:38:22.420 --> 06:38:43.446 A contract, if you assume the upgrade gets happens, the other way to do, it might be to compensate the customer or a reduction. So, the customer's modeled out what their expected revenue is of the life of the project and if they had to curtail to mitigate, there could be some again. 1440 Sky Stanfield 06:38:43.594 --> 06:39:04.712 On how much reduction they can have, but you don't have to say it as a compensation, but if there was a cap, it would lead to potentially the need to upgrade or to compensate the customer for the delta. It seems like there's 2 different ways of thinking about it either around saying the customer will be reduced and avoid the need for. 1441 Sky Stanfield 06:39:04.746 --> 06:39:25.836 The upgrade, but they need to be able to have some visibility or our, our belief based on without actual data, is that the getting all the way down to the is probably not going to be financially viable. So, something that would cap the amount of reduction in a way that makes the. 1442 Sky Stanfield 06:39:25.894 --> 06:39:41.344 Project still palatable. Now, I get there. Does that make sense, Dave in terms of just trying to say there's either way of thinking about it around around upgrades happening or, as Justin was characterizing just revenue reduction from the curtail. 1443 David Schiada 06:39:44.224 --> 06:40:05.344 Yeah, I think that's adds another layer of complexity, but I understand the concept the other 1. um, so it can maybe to Jose and Justin on the kind of what's in play here. I think Roger raised it as well for advice. Letters. Is it? And again, not agreeing to anything here, but just kind of conceptually, if there was this cost. 1444 David Schiada 06:40:05.374 --> 06:40:26.494 Cap approach is that something that would be like, in the advice letter? It would say, here's how the is proposed to be ordering paragraphs 15 and 16 in addition the workshop talked about a cost cap and That'll feed into phase. 2. is that kind of the thinking or just trying to understand. 1445 David Schiada 06:40:26.524 --> 06:40:28.472 Kind of what what's in play here so. 1446 Aliaga-Caro, Jose 06:40:29.972 --> 06:40:47.582 So, uh, that is my thinking is speaking that is by thinking, uh, uh, Dave, that, you know, items within the advice letters are daily, uh, or clearly delineated between what's in. 1447 Aliaga-Caro, Jose 06:40:48.034 --> 06:40:54.482 What can be approved in the advice letters and then, you know. 1448 Aliaga-Caro, Jose 06:40:56.110 --> 06:41:16.984 Another section for phase 2, this was proposed on how this could be implemented and therefore, now, for phase 2, we have a, you know, uh, you know, we have something to kick off and start, you know. 1449 Aliaga-Caro, Jose 06:41:17.286 --> 06:41:19.266 Getting down to the logistics. 1450 David Schiada 06:41:20.346 --> 06:41:22.714 Okay all right. Thanks. 1451 Aliaga-Caro, Jose 06:41:22.714 --> 06:41:35.404 I haven't answered that. I had a, I guess a general question in terms of cost sharing. I'm wondering what benefits would be. 1452 Aliaga-Caro, Jose 06:41:37.742 --> 06:41:57.962 In there for rate pairs for that particular circuit, for example, you know, and it's been a while since I've been involved in data and the whole distribution planning process but, you know, the utilities, I remember, they prioritize their upgrades. 1453 Aliaga-Caro, Jose 06:41:58.174 --> 06:41:59.674 Or, or or their. 1454 Aliaga-Caro, Jose 06:42:01.386 --> 06:42:19.356 And I'm wondering whether let's say 1 circuit gets impact, has that LGB customer, low drops and this cost cap cost sharing mechanism comes into play. 1455 Aliaga-Caro, Jose 06:42:22.324 --> 06:42:29.524 With that, and let's say originally in the distribution planning process, let's say that was. 1456 Aliaga-Caro, Jose 06:42:30.694 --> 06:42:51.722 On the list, but now, because, you know, uh, developer is partly paying for it, it would it come up in the, you know, from being 10th on the list because it's being now paid for partly by a developer. 1457 Aliaga-Caro, Jose 06:42:51.812 --> 06:43:03.482 It would come out too, like, let's say, number 2 on the list of work to be performed, you know, would that be, uh, you know, would that be beneficial to rate. 1458 Roger Salas SCE 06:43:10.052 --> 06:43:26.882 And also, it's a little bit difficult to understand the scenario there. What I would say though, is that that most of the projects that are going through the process are because we have very highly loaded systems. So we. 1459 Roger Salas SCE 06:43:26.978 --> 06:43:47.462 I want to have a situation where a project is under the process, because we are doing a system upgrades for capacity needs and have this condition where, you know, you probably won't even need an for that project because you have so much load. You probably have last month. 1460 Roger Salas SCE 06:43:48.544 --> 06:44:02.284 You know, generation capacity, so you probably don't even need to apply a project. But nevertheless, if you did, I, I don't think I don't think you have both conditions at the same time. If if that's what you're referring. 1461 Aliaga-Caro, Jose 06:44:06.094 --> 06:44:09.484 Okay, thank you. I think it that may have answered my question. 1462 Sky Stanfield 06:44:23.166 --> 06:44:24.816 Okay, so, um. 1463 Sky Stanfield 06:44:26.224 --> 06:44:30.694 I guess I'm gonna leave that there unless there's have additional comments that this is. 1464 Sky Stanfield 06:44:32.944 --> 06:44:52.982 General confusion conclusion is that developers overall would be willing to bear some risk for the, for the expected return as we discussed. But to determine that they have to be able to understand what the magnitude of the risk is. And or, and ideally how it. 1465 Sky Stanfield 06:44:53.016 --> 06:45:11.224 It's too high, but we can't we just didn't feel equipped to figure out how we get to that, especially because it's going to be a bit of a customized analysis under the current the current set of unknowns that we have. Um. 1466 Sky Stanfield 06:45:13.114 --> 06:45:33.722 The other thing, just to speak to the ratepayer or the phases, and the repair impacts discussion I think that it's really important to remember the data gaps here and that we are talking about a hypothetical risk that the utility is as indicated has never happened with current interconnection scenarios. 1467 Sky Stanfield 06:45:33.934 --> 06:45:37.264 Could potentially be more likely with that we still don't have data. 1468 Roger Salas SCE 06:45:37.264 --> 06:45:37.624 To work. 1469 Sky Stanfield 06:45:37.684 --> 06:45:54.634 And and is unlikely to occur in the future. So it's not like we're talking about actual costs necessarily that will arrive. We're talking about a hypothetical risk management on everybody's side. So, with that. 1470 Sky Stanfield 06:45:55.030 --> 06:46:15.424 Less people have additional comments or thoughts about how to design a cap of some sort of again, Eva upgrade cost cap or revenue loss cap. I was going to go into another sort of different approach that Iraq was thinking about potentially putting on the table. 1471 Sky Stanfield 06:46:17.256 --> 06:46:18.724 With that next line. 1472 Sky Stanfield 06:46:23.314 --> 06:46:41.554 So, because the way we've been thinking about this is around this, unlikely to ever occur. But if it did occur could be expensive, I guess, is the way to characterize it issue what? And the inability or the. 1473 Sky Stanfield 06:46:41.582 --> 06:47:02.492 Challenge at least I'm not going to say it's impossible. Capping it in another way is we were thinking around what about a compromise that still would would have repairs, carry the risk. But with understanding that the risk is even further reduced. 1474 Sky Stanfield 06:47:02.944 --> 06:47:23.854 So that's what, this what I'm going to sort of lay out as an idea for this purely for workshop discussion at this stage. So, 1 of the elements that we've, everyone's agreed that the issue here is load reductions. And I think the question is, is that risk of load reduction. 1475 Sky Stanfield 06:47:24.514 --> 06:47:31.144 Spread equally across all feeders. Is it possible? Or would it be possible for us to. 1476 Sky Stanfield 06:47:32.674 --> 06:47:53.434 Identify feeders where that risk is higher, um, and limit the applicability of the, during the test or interim period, at least, um, to not be able to propose an project on theaters where that risk is high. Um, again, we don't have any character. 1477 Sky Stanfield 06:47:53.470 --> 06:48:14.616 Position of the basic risk at this point. But if there are feeders where the risk of a load reduction is higher, that would be a way of a different way of thinking about this and mitigating the risk. And what we were thinking is that the biggest risk is probably. 1478 Sky Stanfield 06:48:15.184 --> 06:48:35.764 In the large customer disappearing, or a couple of large customers disappearing that's going to significantly reduce the load and potentially would introduce, you know, thermal equipment overload if you allow the scenarios to go forward. So that and we know already through. 1479 Sky Stanfield 06:48:35.852 --> 06:48:56.732 The application of the 1515 rule in the we actually already identified the feeders that meet either aspect of the 1515. that data is redacted from the, from the maps at this point. Um, whether the 1515%, a single customer being. 1480 Sky Stanfield 06:48:57.124 --> 06:49:18.036 Is the right metric of those higher risk feeders? I don't know. It's it's the same problem as afford. How do you get to that magic number? But I thought it was an idea that was worth exploring and putting out there both for the utilities to weigh in on on. The basic question of is this for, is higher on some Peters and other and if so. 1481 Sky Stanfield 06:49:18.094 --> 06:49:33.062 How would we characterize which Peter's the risk is higher on? Maybe that's the the 1st place to start the discussion. And then we could get into the details of how you would do that. If that ended up making sense. 1482 Yi Li SDG&E 06:49:39.936 --> 06:49:54.756 Scott sorry before digest this kind of making any technical signs at all, like mm, hmm. In the scenario here if say, there's a magical way that developers can decide which feeders has a lower risk versus which 1 has a higher risk and. 1483 Sky Stanfield 06:49:54.756 --> 06:49:56.044 Would it be too bad for. 1484 Sky Stanfield 06:49:56.164 --> 06:50:03.934 To be clear, it would be, we have to define them in advance. It would probably be the utilities identifying them in advance. 1485 Yi Li SDG&E 06:50:04.564 --> 06:50:16.264 Yeah, no forget about that part. I'm talking about the actual applicant, right? Whoever decides to use so, stays the applicant developer decides to some for the project. 1486 Yi Li SDG&E 06:50:17.288 --> 06:50:31.232 And based on the assumption characteristics low and the developers, nice enough financial incentive board a project. Are you saying that, that lower risk is still bearable by the ratepayers? Not the developer themselves. 1487 Sky Stanfield 06:50:31.742 --> 06:50:37.952 Yes, that's what I'm proposing. And again, with the understanding that I'm open to the repairs. 1488 Sky Stanfield 06:50:38.764 --> 06:50:39.664 We haven't been able to do. 1489 Yi Li SDG&E 06:50:39.814 --> 06:50:41.764 A repair, I'm feeling the pan. 1490 Sky Stanfield 06:50:41.974 --> 06:50:59.584 Yeah, I'm trying I'm trying out a different approach because of the challenges of the of the other approach. Um, and again I just, you know, and the idea behind this again is that we think it is pretty unlikely this is going to happen overall. But again, we don't have great that on that. We know that. 1491 Sky Stanfield 06:50:59.590 --> 06:51:11.134 It hasn't happened in the past, and we know that we expect a system wide base, a significant load growth from electrification on each node may or may, or may not arise. 1492 Roger Salas SCE 06:51:12.696 --> 06:51:20.464 Okay, let me ask a little bit broader question and see, I think goes along with this topic here. Um, obviously. 1493 Roger Salas SCE 06:51:20.974 --> 06:51:41.196 You know, for us as well, I mean, we'd want to impose more risk to the applicant than the necessary. I mean, for us, it would be good if the customer goes and submits an application or whatever kind of what full knowledge of what the risk is. And based on that, they can determine they want to proceed or not proceed. Right? So, I guess to that end. 1494 Roger Salas SCE 06:51:42.154 --> 06:52:02.734 What what what what, what do you think or maybe some developers here are here what would they need from us in order to sort of like, you know, evaluate whether or not they can take on these risk like, what, what would they need to know if you were to just, you know, throw things out there. 1495 Roger Salas SCE 06:52:03.038 --> 06:52:15.212 You know, and say, well, well, if I knew these facts about the circuit or the station or whatever is then I have enough information for me to know that I can take the risk or not take that risk. 1496 Sky Stanfield 06:52:16.082 --> 06:52:23.972 Yeah, I, I want to let the developers weigh in on that. What I heard is based on the same way. I identify the data needs. 1497 Sky Stanfield 06:52:24.274 --> 06:52:45.334 Is the risk, but the overall risk is unknown, but the more the bigger driving factor is, what is the magnitude of the risk? Um, is it capped? Essentially, if if there's a risk that is on that, we don't know how often it is, although we, we believe it is unlikely, but that could wipe the entire value of the. 1498 Sky Stanfield 06:52:45.340 --> 06:53:06.484 Project or below the additional capacity that was added clean. That that seemed like a non starter from what we were talking about. So, they I think that the primary thing is being able to know what how much you could be reduced in the end. I think or how much you would have to pay for. 1499 Sky Stanfield 06:53:06.516 --> 06:53:07.686 It's in the in. 1500 Roger Salas SCE 06:53:08.074 --> 06:53:27.544 Yeah, and I think that's that's a tough 1 to to determine but I think what I'm saying is like, is there information that we could provide as a utilities for them for the customer to sort of make a a almost say, calculated evaluation or not. 1501 Roger Salas SCE 06:53:28.774 --> 06:53:34.384 Is this is the information that we could provide that would allow them to say, you know what I'm willing to take this risk. 1502 Roger Salas SCE 06:53:39.366 --> 06:53:40.624 Sorry, I got you on mute. 1503 Sky Stanfield 06:53:42.876 --> 06:53:55.654 I was saying I can speak for developers. Um, I haven't I, it does seem to me, like, any sort of just unlimited risk is hard going to be hard to finance. But again, we need to hear from the developers that they think that they could finance that. 1504 Roger Salas SCE 06:54:01.204 --> 06:54:19.742 Discuss for me, I think that's where, where I would be interested in knowing. I mean, if if if stakeholders saying look if I know X Y, and C and based on that, I can determine whether or not it's it's it's, uh, it's it's the risk is slow. Based on my risk tolerance, or maybe. 1505 Roger Salas SCE 06:54:20.582 --> 06:54:26.372 Then then we should be looking as to whether or not, we can provide X. Y Z. right? Um. 1506 Sky Stanfield 06:54:26.402 --> 06:54:34.622 Yeah, I mean, I think the other question is here is this insurable you know, like, those are all the things, but I just don't have that that insight to offer. 1507 Yi Li SDG&E 06:54:39.034 --> 06:54:58.714 Yeah, I agree with Roger, this is really challenge for us to even comment on right? Cause the last workshop well, we've been hearing is that the issue with with is with a limited risk and state relatives are willing to take on some risk, but looking at this proposal, without, you know, getting to the detail. It's saying that even when the risk is low. 1508 Yi Li SDG&E 06:54:59.612 --> 06:55:04.622 Are still unwilling to take any risk and want to pass on to the customer. That's not my. 1509 Sky Stanfield 06:55:04.652 --> 06:55:20.432 It's saying that we don't know how to define how to limit it. I was very clear that we arrived at this not because we don't developers aren't willing to take on the risk is that we couldn't come up with the way to define it. That's why I asked you for your input. So don't I understand this is difficult. I'm not disagreeing with. 1510 Sky Stanfield 06:55:20.440 --> 06:55:30.424 You on that, but don't characterize it as people being unwilling to. It's a question of how would we do it and at least Iraq nor anybody here seems to come up with that approach. 1511 Frances Cleveland 06:55:44.582 --> 06:56:04.142 I guess I, I would like to understand a little bit more by what you would do or what's the, the risk, uh, you know, if you identify a particular level of risk, um, or a particular circuit, what would you. 1512 Frances Cleveland 06:56:04.148 --> 06:56:23.732 You expect to be done with that risk knowledge because it ultimately would result in revenue stream stream what you know, it's not it's not just the likelihood it's the impact. 1513 Roger Salas SCE 06:56:25.324 --> 06:56:46.444 Yeah, I mean, I think just again, you know, speaking out loud here and just this basic concept, right it's like, you know, big picture circuits. Right? You know, once it has a whole bunch of hundreds or small customers, residential, small commercial, uh. 1514 Roger Salas SCE 06:56:46.476 --> 06:57:07.566 1 of those customers can close and move somewhere else. Probably not an issue, right? Like, they're so small that is essentially a 11 customer closeness, almost non material for, for these purposes where you have a circuit where you have a pretty large customer. 1515 Roger Salas SCE 06:57:08.314 --> 06:57:28.714 And if that customer goes, so maybe 1 or maybe, you know, a few, you know, 2 or 3, that are dominating the, the capacity of the circuit then 1 of them going will have a significant outcome. So, you know, you have 2 scenarios there where, in 1, where you have the. 1516 Roger Salas SCE 06:57:29.014 --> 06:57:49.802 So, distributor among customers, that is probably very, extremely low risk that, that, you know, the will require to be, uh, uh, reduce, um, compared to the 2nd scenario. But, you know, maybe we can find what that is, you know, and also. 1517 Roger Salas SCE 06:57:49.898 --> 06:57:57.124 Asking earlier, like, what is the customer need to know to evaluate the risk between those 2 scenarios or something in between. 1518 Regnier, Justin 06:57:59.284 --> 06:58:19.354 So this guy's point about insurability, um, the customer doing a deterministic analysis may, or may not qualify for bank ability or insurability? Um, I guess I'd like to understand 1 thing here on the, it sounds like feeders. 1519 Regnier, Justin 06:58:20.164 --> 06:58:27.394 Where you've got a customer that's greater than 15 of it's all load are already omitted from the is that right? 1520 Sky Stanfield 06:58:27.426 --> 06:58:33.096 Yeah, the I see, Roger go ahead. You can characterize it. 1521 Roger Salas SCE 06:58:33.664 --> 06:58:40.654 I know the IC values are there, it says the, the certain values are redacted. 1522 Roger Salas SCE 06:58:40.712 --> 06:58:50.014 Like, the operational flexibility value is redacted. Um, the low profiles are rejected, but the IC values are still there. 1523 Regnier, Justin 06:58:51.242 --> 06:58:53.704 Okay, so. 1524 Regnier, Justin 06:58:55.414 --> 06:59:15.876 What seems to be coming into focus is the most likely customer, which should be an M, export customer greater than 1 megawatt on a feeder. That's got a high as as, um, Alex is saying, a high delta between Max. 1525 Regnier, Justin 06:59:15.934 --> 06:59:37.052 Minimum load and sounds like what sky is saying is to mitigate risk. We'd restrict the initial roll out of this to customers where the feeder load isn't dominated by any single customer, or. 1526 Regnier, Justin 06:59:37.562 --> 06:59:42.902 Any group of large customers or or whatever threshold we've got there and that that that. 1527 Regnier, Justin 06:59:44.494 --> 07:00:01.144 Seems to make sense absent feedback from other folks. There's, there's a persistent discussion here about having the interconnection customer beyond the hook for a later upgrade. 1528 Regnier, Justin 07:00:02.974 --> 07:00:22.444 I think we've discussed that a, a number of times in this meeting that, you know, there's no record for a different customer class and a different treatment of where the upgrade costs would be allocated. If it's necessary to. 1529 Regnier, Justin 07:00:23.590 --> 07:00:28.926 At the terms of the interconnection agreement back on track as it were. 1530 Regnier, Justin 07:00:31.234 --> 07:00:42.844 Um, so failing that, maybe we can take later a billing of the interconnection customer for an upgrade. Um. 1531 Regnier, Justin 07:00:44.946 --> 07:00:46.596 Off as a concern, I mean. 1532 Regnier, Justin 07:00:49.806 --> 07:01:04.776 So the kind of the, the conceptual framework that pops into my mind is if we look at that, that targeted customer right? So that over 1 megawatt M, export on a high Delta circuit with no big loads or no big single customer loads, right? 1533 Regnier, Justin 07:01:06.304 --> 07:01:27.034 And we look at the amount of revenue that they can get under static export versus limited generation export, and just pulling a number out of error say that they can get 30% greater revenue, um, in excess of the. 1534 Regnier, Justin 07:01:27.092 --> 07:01:29.192 Additional cost for their hardware. 1535 Regnier, Justin 07:01:31.682 --> 07:01:52.412 Um, you know, maybe it's if you split it right down the middle, it's if, if their revenue realized by taking option drops by more than 15, that triggers the requirement of, uh, you know, getting the circuit upgrade into the planning. 1536 Regnier, Justin 07:01:52.444 --> 07:02:10.864 That may be a framework that keeps us from spending a whole lot of money on upgrades, but the rate parents have to pay for, for a tiny amount of generation. I see. Sky may or may not intend to be neutral. But she is. 1537 Sky Stanfield 07:02:11.402 --> 07:02:12.392 I know I'm on mute. I was. 1538 Sky Stanfield 07:02:13.776 --> 07:02:15.366 Testing with Yogi. Sorry. 1539 Regnier, Justin 07:02:15.876 --> 07:02:18.096 All right no worries, no worries. Um. 1540 Regnier, Justin 07:02:21.154 --> 07:02:23.674 I mean, that's that's where my brain goes, and I don't know if the. 1541 Regnier, Justin 07:02:26.734 --> 07:02:47.314 If that is a framework for going forward, if if we've got consensus that are most likely interconnection customer would match those parameters. Um, and that setting a threshold of reduced revenue for. 1542 Regnier, Justin 07:02:47.408 --> 07:03:08.132 System upgrades is something that helps with bank ability and with insurability because I hear the frustration from Roger that, you know, just tell us what data you need to quantify the risk to satisfy your lenders and we'll get you that technical data and you can, you can quantify it, but I'm not sure that that will satisfy the lenders. I think what. 1543 Regnier, Justin 07:03:08.556 --> 07:03:20.732 Would make a bankable as an assurance that, you know, if you lose more than X amount of revenue, then you're gonna be in the queue for an upgrade. And that upgrades not going to be on your done. 1544 Sky Stanfield 07:03:23.702 --> 07:03:29.702 Just like for 1 comment um, I think that I don't think that. 1545 Sky Stanfield 07:03:29.794 --> 07:03:50.584 We should limit the idea of who the optimal customer is to this to, behind the meter. Only I think what what you're likely to see enabled through this and is is front of the meter systems with solar plus storage that are really capturing ultimately locational. 1546 Sky Stanfield 07:03:51.004 --> 07:04:12.004 Saying and those differentials now, whether those will be projects interconnected through rule 21 at this point. It's a question. I think that what we're trying to get to is, I think there's a smaller pool of customers doing this behind the meter. And the potential real benefits that we were talking about from the grid might come from actual front of the media. 1547 Sky Stanfield 07:04:12.036 --> 07:04:33.154 And maybe even like, the new community solar program, for example, which requires storage, maybe customers, depending on how their infrastructure there can capture some of this, I don't know enough about all those different procurement programs that exist today, or might be developed in the future. That's again. Part of what we're trying to chicken today care, but I don't think that we should assume that this is that. 1548 Sky Stanfield 07:04:33.184 --> 07:04:37.864 But if it is actually, our greatest opportunity comes from behind the meat of the customers. 1549 Regnier, Justin 07:04:39.482 --> 07:04:52.292 I didn't mean to assert that, uh, just within the confines of real 21, but that would seem the most likely candidate for exercising limited generation profile again within the confines of real time. So that's all we. 1550 Sky Stanfield 07:04:52.712 --> 07:04:54.302 Yeah, I mean, there's lots of ways the commissions. 1551 Sky Stanfield 07:04:54.306 --> 07:05:06.482 Structure programs that stay within rule 21, that that incentivize procurement on more of a time of use basis so to speak. But those aren't all on the table. 1552 Sky Stanfield 07:05:10.652 --> 07:05:13.292 I mean, I mean, is it, I mean, or a man, I don't want to keep. 1553 Younes, Amin 07:05:13.292 --> 07:05:13.684 But. 1554 Sky Stanfield 07:05:13.684 --> 07:05:14.944 Your name sorry? 1555 Younes, Amin 07:05:15.572 --> 07:05:16.024 Thank you. 1556 Sky Stanfield 07:05:16.024 --> 07:05:16.354 Me. 1557 Younes, Amin 07:05:17.524 --> 07:05:29.552 I just want to go back kind of to this conversation about risk level. Um, so it kind of seems like if, if a project's getting built and say you're building 20% in excess. 1558 Younes, Amin 07:05:29.582 --> 07:05:49.952 The value I understand that that Delta is entitled that Delta is 100% at risk, but the project itself is only, I forgot what I said, 20% or 10%. Um, you know, the relative risk downside risk of the project is is not necessarily that unlimited. Um. 1559 Younes, Amin 07:05:50.914 --> 07:06:11.704 And so, it seems like, I guess it seems like even if, um, projects had the risk of being permanently curtailed to the value, which we all agree is a small probability, but could be bearing impact could be high impact for some projects. But it might be that we actually do see interconnections. Um, it could very well be that. 1560 Younes, Amin 07:06:11.914 --> 07:06:33.004 Particularly with now, I can't, I guess this this could be utilized by them larger than 1 megawatt. So potentially with those types of installations, which get, you know, have a pretty short payback period potentially that those projects wouldn't see that much risk and using the. 1561 Younes, Amin 07:06:33.756 --> 07:06:53.974 And so we would see some projects like that coming online, uh, and then once that starts happening, then we can start gathering data and potentially say yeah. Oh, I mean, and actually, we wouldn't even necessarily necessarily need to do anything. Well, no, I guess, sorry at that point, we could reconsider and say, you know, that, that curtailment is going to go away. Uh. 1562 Younes, Amin 07:06:54.184 --> 07:07:15.302 That that rate parents would pay for the upgrade, because it's so rare, uh, you know, that it's 1 in a 1Million. Um, and then that that could lead to, to kind of more projects and long term I guess just to, to reiterate that cause I kind of wandered around a little bit. But the point is that what we might see customers using, and if we do, then we can gather the data and we don't need to have. 1563 Younes, Amin 07:07:15.332 --> 07:07:19.022 Have this risk born by rate pairs necessarily immediately. 1564 Sky Stanfield 07:07:20.402 --> 07:07:35.462 Yeah, it's it's, I certainly can't say it's not possible that will happen, you know, that if there's enough additional revenue that can be captured and the price signals exists that somebody could absorb that risk. 1565 Sky Stanfield 07:07:36.604 --> 07:07:46.624 It's, it's possible, it's a lot of work to get there. If that doesn't happen is the, the challenge and my sense when why we're kind of. 1566 Sky Stanfield 07:07:48.214 --> 07:08:08.286 Leaning on the face is because we think it's gonna be unlikely and that the overall cost, and I want to, you know, I don't want to sound like I'm, you know, using the rate base here. What I, my intent is, is that the rate base has this broad layer of security, right? Because it's spread across all the customers. Whereas the way that this works is, it has to be on a single customer and that's that. 1567 Sky Stanfield 07:08:09.064 --> 07:08:30.004 But the only way that it's reasonable to use the rate base is if it is truly unlikely. And, and therefore, it's, you know, in the ring base is used like this as an sort of an insurance policy of its own and a lot of cases. And whether we agree, and what the economics of it and are justified is part of our challenge. 1568 Sky Stanfield 07:08:30.062 --> 07:08:51.182 But I do think that that that if we put the risk on the developers, it seems logical that we're going to increase the costs of financing 1 way, or the other and maybe we don't need to do that. Because it's we're going to really arise is the problem, but we could, as you said, I mean, we could go. 1569 Sky Stanfield 07:08:51.214 --> 07:09:12.334 And design a whole program with the hope that the economics work out for a developer to absorb all the risk. My guide is that that's probably not where the market is right now, and it could be in 5 years, and when we finally do better pricing and so on. But my guess is that that's not going to give us a lot about that. 1570 Sky Stanfield 07:09:12.394 --> 07:09:15.606 My guess, but not based on any, any. 1571 Younes, Amin 07:09:17.256 --> 07:09:29.824 Yeah, I guess adding to that, I mean, we could also set in, in addition to the data collecting another piece of data collecting could be monitoring how many systems come online and revisiting in a year or 2 if we don't see any systems at all we could go back and look at this again. 1572 Sky Stanfield 07:09:30.634 --> 07:09:33.484 Yep, that's when we were doing it or or we can get some data on. 1573 Sky Stanfield 07:09:33.516 --> 07:09:54.606 Some actual projects and see how they perform and go back and revisit it if it raises, because it's a which 1 do you want to shift it to? And how strongly do you want it to happen? I think is the question in a timeframe. That's reasonable. That's the dilemma. Why don't we go into the next slide? What I did oh, actually, just go ahead and go on. 1574 Sky Stanfield 07:09:54.638 --> 07:10:02.344 I don't think the not following slide. Please next slide. There we go. Um. 1575 Sky Stanfield 07:10:03.124 --> 07:10:24.184 What I did again, these were kind of just throwing ideas on the table, as I did think regardless of whether we do this approach or another approach we have to, we haven't really defined. I mean, to your particular point, in the beginning, what data would we need to figure out the risk better? Um, and then on the next. 1576 Sky Stanfield 07:10:24.784 --> 07:10:45.392 Identify so we have, what data would we need even to make the current decision if we were making going to make it with an a more informed way and then the next slide gets into if we're going to do some sort of pilot, whether it's piloting it with with Frank paragraph, develop a risk or some combination there in what data do we need to collector? And our pilot would actually. 1577 Sky Stanfield 07:10:45.424 --> 07:11:02.552 Inform what we would do going forward because if nothing happens either, no upgrades are required and the thing or no developer builds a project under the other scenario. What how do we move ahead? Because we might just be right back where we started. 1578 Sky Stanfield 07:11:06.334 --> 07:11:15.844 And I, I admit that lack some of the, I feel like the skills to really think about exactly how we would nail these things down in a more certain way with the right. 1579 Aliaga-Caro, Jose 07:11:47.614 --> 07:12:06.994 So, Scott, I would say, so, uh, I'm just trying this idea out there. Um, I don't know if this fits into data or not, but 1 data point may be is an upgrade is needed, you know, the cost of that upgrade uh. 1580 Aliaga-Caro, Jose 07:12:07.322 --> 07:12:23.374 You know, specifically, if it's shared if the cost is shared by ratepayers, um, I do not know if you know what I mean? Uh, depending on how the utilities study, the various screens. 1581 Aliaga-Caro, Jose 07:12:25.510 --> 07:12:46.654 If they study it, let's say, at the highest value, which is, you know, which would be the highest value that they would need to bring it up to, uh, you know, with any medication option, assuming that just theoretically or, you know, I'm thinking what. 1582 Aliaga-Caro, Jose 07:12:46.684 --> 07:13:07.802 There they could identify a cost outright or estimate a cost saying that, well, you know, it's not going to cost you anything because you're staying within the for upgrades. But in order to assuming you were. 1583 Aliaga-Caro, Jose 07:13:07.806 --> 07:13:28.952 To export at the highest, uh, value upgrades would have cost you X amount of dollars. So let's say if those X amount of dollars, and I'm just throwing figures out here are. 1584 Aliaga-Caro, Jose 07:13:29.254 --> 07:13:50.104 Uh, if if the commission where to adopt, and so, like, cost sharing mechanism, you know, if those X amount of dollars are very small, let's say only 10,000 then rate pairs would bear. Let's say 50, 50 is throwing it out there. 1585 Aliaga-Caro, Jose 07:13:50.194 --> 07:14:08.134 The higher they go, then rate pairs would bear less because now the risk is higher, uh, for them to be, you know, on the hook for in costs. So, I'm just throwing that idea out there, you know, something to play around with. 1586 Sky Stanfield 07:14:13.686 --> 07:14:32.106 So, you know, we're thinking about this is using the with where we're not doing a customized study of what the and it again, it depends on the magnitude of the load. What the actual load loss would be. That would what upgrade cost would be. Right? So, there's a lot of variables. 1587 Sky Stanfield 07:14:32.434 --> 07:14:53.552 That make it again, this is why I went back to say, we really tried to work out what was the frame of cost cap of some sort, or cost share as you're describing it. And I, and we lack the ability to figure out how we do it. In a quasi generic fashion, um, partly because we don't know what the. 1588 Sky Stanfield 07:14:53.582 --> 07:15:14.672 Upgrade would cost, and we don't know where it would be triggered and we don't know how often it would be triggered. So, if we had 100 projects that went ahead in the next 2 years, we don't know if 1 or all 100 would trigger an upgrade. And then we don't know, for each of those upgrades what they would cost, which means we're back to the point where. 1589 Sky Stanfield 07:15:14.734 --> 07:15:35.824 The repair, or the developer has certainty, could we get closer to a comfort level of the, the risk that it will occur? Yes. That's the where I think that the utilities have provided historical data and had some good modeling on load growth. We'd be able to get to a better clarity around is this. 1590 Sky Stanfield 07:15:35.860 --> 07:15:51.874 Likely to happen at all, but I don't know how we get to a greater clarity, and we might be able to get the utilities to say, here's the highest cost separated that could be happened on all of our feeders and extrapolate from that that's sort of my questions here is, would that data really tell us something that would help us move forward? 1591 Roger Salas SCE 07:15:54.994 --> 07:16:15.334 I mean, I I think 1 thing is whether or not you can do the analysis back to justin's point, whether, or not others would accept that analysis. I mean, if you, I think if you're just looking at it from the purely analytical point of view, um, you know, 1 would argue that, you know, if you had certain information. 1592 Roger Salas SCE 07:16:15.366 --> 07:16:36.456 You can probably perform a pretty good evaluation to determine whether you want to take the risk on that. For instance, you know, you know, contingent on 1515 and whether or not. We can even provide this information or not just throwing things out things like, hey, how many how many large customers do you have any circuit? You know, just how many customers greater than 2. 1593 Roger Salas SCE 07:16:36.516 --> 07:16:57.634 What do you have on the circuit? As an example what type of customers are they are very, you know, are they large customers do this type of these type of customers? You know, then that may give someone, um, relatively good information as to, like, Ah, this type of customers are pretty stable. Uh, no. Or we don't even have any of these type of. 1594 Roger Salas SCE 07:16:57.664 --> 07:17:18.724 Customers in the circuit, and therefore it's likely that that, um, that any 1 customer going away is gonna create a problem um, things like company, you know, I'm just throwing things out, like, how many customers you have in the circuit you know maybe what is their relative size, you know, uh, all of those customers, things like that. 1595 Roger Salas SCE 07:17:19.202 --> 07:17:39.842 Again, not even sure that we can provide. This is throwing, you know, you know, from the perspective of, like, the 1515 rule, like confidentiality. But that's what I was asking. Like, what what what what our developers need to feel comfortable on taking this additional risk just like we provide, you know, other maps you provide information. 1596 Roger Salas SCE 07:17:40.294 --> 07:18:01.024 Amount of current generation, you know, uh, you know, type of, you know, other other information on the maps. Well, we will do that for them to take, uh, take all this information and determine whether they want to take the risk to interconnect the project or the location. So, if we knew what that information was, then we could think about, you know, whether. 1597 Roger Salas SCE 07:18:01.116 --> 07:18:04.446 We can provide a such that they could determine whether or not they can think of it. 1598 Eva Wang TotalEnergies 07:18:07.504 --> 07:18:10.742 Like, most developers, like, we are pretty predictable. 1599 Roger Salas SCE 07:18:15.604 --> 07:18:15.874 A. 1600 Jacob Willman (Consultant) 07:18:17.194 --> 07:18:17.644 This is. 1601 Jacob Willman (Consultant) 07:18:18.036 --> 07:18:21.696 Jacob woman from it if you could just speak up into your Mike please. 1602 Eva Wang TotalEnergies 07:18:24.902 --> 07:18:26.254 What can you hear me? 1603 Sky Stanfield 07:18:27.454 --> 07:18:28.142 Yeah. 1604 Jacob Willman (Consultant) 07:18:28.354 --> 07:18:29.732 Yes, that's that's better. Thank you. 1605 Eva Wang TotalEnergies 07:18:31.322 --> 07:18:33.812 For some reason my audio is weird. 1606 Eva Wang TotalEnergies 07:18:35.374 --> 07:18:44.792 I'm saying, like, most developers, we're, we're a pretty big developer, but most developers don't really have, unless they're intuitive. 1607 Eva Wang TotalEnergies 07:18:45.334 --> 07:19:05.944 But we're talking about customers, right? They don't really have a powerful engineer on site on their team. So all the constraints that you can provide on feeder or on the voltage, like all that information, a lot of them don't really have the capacity of analyzing it. We rely on utilities to give us the value to give us. 1608 Eva Wang TotalEnergies 07:19:06.366 --> 07:19:27.066 The upgrade cost, and I said, I mentioned earlier, like, what really driven, whether a customer's willing to participate in our GP profile is the revenue at the end of the day, right? What the they're paying and what the risks they're taking. And then for customer developer, you can entertain it's interchangeable. 1609 Eva Wang TotalEnergies 07:19:27.124 --> 07:19:48.154 That's because we're 1 group, we want to get more solar on the customer site and to have those data, some of data may be useful. But then at the end of the day, we're still relying on the utility to tell us what exactly. You know. 1610 Eva Wang TotalEnergies 07:19:48.248 --> 07:20:06.722 Triggering certain upgrade and we don't even know the well, we know some itemized upgrade costs right? But we can't determine what the total upgrade is until you until you tell us. So that's the challenging part. 1611 Roger Salas SCE 07:20:07.684 --> 07:20:09.124 Yeah, I was more referring to. 1612 Roger Salas SCE 07:20:09.482 --> 07:20:30.542 it will continue to provide that but i was more referring to like so all we're talking about the discussion today or all these times has been about what if customers assigned to close doors and go somewhere else and essentially reduce the load on the circuit that's kind of the main issue right so so again 1613 Roger Salas SCE 07:20:30.574 --> 07:20:51.694 You know, what, if what, if you had a listing of 8, you know, these are the large number of new customers in this area um, you have, you know, 5 of them, 10 of them, whatever number, whatever the data makes sure. Yeah. I imagine that you could hire someone to perform an evaluation as to whether. 1614 Roger Salas SCE 07:20:51.726 --> 07:20:57.486 The risk is low, that any 1 of those customers going away from the customer problem or not. The problem is. 1615 Eva Wang TotalEnergies 07:20:57.486 --> 07:20:58.596 to go away right 1616 Eva Wang TotalEnergies 07:20:58.748 --> 07:21:19.774 We can hire a consultant or whatever, but if they go away, we still need to have a dollar value attached to it. But I can say, it's, you know, it's 5% of chance that 1 of the factor would close. But then, what's the impact on the grid? And what's the average cost? I don't think. 1617 Eva Wang TotalEnergies 07:21:20.132 --> 07:21:32.132 Engineer like, even with hire consultant to perform that, because, you know, most of the data, uh, only you guys have access to it and, you know how to perform those analysis. 1618 Roger Salas SCE 07:21:32.764 --> 07:21:41.042 Yeah, yeah, all this would be is whether or not someone going away could create a problem. You know, the. 1619 Roger Salas SCE 07:21:41.048 --> 07:22:02.164 I was going to depend on each specific circuit circumstances. So that, that that is the 2nd element, but at least, you know, I think, you know, someone could take a look at the data and, you know, I'm going to say, do some calculations, but maybe some statistical evaluation. 1620 Roger Salas SCE 07:22:02.226 --> 07:22:19.836 Whether or not, you know, any 1 of those customers are going to going away, we'll create a problem just trying to figure out if there's any way that we can provide data for developers to feel comfortable. Um, because otherwise we will get away. We not want to be able to get out of this kind of, you know, who's taking this risk. 1621 Eva Wang TotalEnergies 07:22:21.666 --> 07:22:23.346 Does not solve the fundamental. 1622 Eva Wang TotalEnergies 07:22:23.434 --> 07:22:34.054 The problem here, right? It's it's still the risks unknown and still the, the cap is unlimited and the duration is. 1623 Younes, Amin 07:22:34.444 --> 07:22:44.494 I don't think the cap is unlimited as, as Justin said, you know, there's no or as Justin believes there's no way that the developer would be. 1624 Younes, Amin 07:22:44.524 --> 07:23:05.642 the upgrade cost but i guess that's not you know from the commission but from energy division what what the risk up to the developer is having a curtailment a permanent curtailment and that risk is known that you know what the value of that energy is and you know what the impact on your on your cash flow would be um so i do think that the impact of that risk is is quantifiable 1625 Younes, Amin 07:23:05.648 --> 07:23:13.832 you know what those loads on the er yeah those loads on the circuit art which you could know i think the um you know s roger's atlas could provide that to you 1626 Eva Wang TotalEnergies 07:23:15.632 --> 07:23:36.662 I said the cap I was, assuming that we have the option of performing upgrade to bring back the customer profile to the original value. Right? That's what I meant the cap for the upgrades. If we don't even have that option, then that's even bigger risk. Right? 1627 Eva Wang TotalEnergies 07:23:36.992 --> 07:23:57.424 Utility design, uh, year 3, right to limit our maximum GP value. Then our calculating like year, 33 year, 25 or are we with calculating? Like year? 24 to 25? You know, you're talking about a wide range. 1628 Eva Wang TotalEnergies 07:23:57.876 --> 07:24:08.734 Connecting after 2 months, what could be shutting down to, like, the minimum lowest, uh, value. So, having that range, it's not it's not acceptable. 1629 Younes, Amin 07:24:11.256 --> 07:24:22.384 yeah that may be my my point was that you you don't necessarily need to know you can make a risk assessment without knowing the cost of distribution upgrades if you assume that you want to be 1630 Eva Wang TotalEnergies 07:24:22.384 --> 07:24:24.634 Don't have the option of going back to the. 1631 Younes, Amin 07:24:26.494 --> 07:24:31.446 Whether or not, you're willing to accept that risk is is your decision, but there is a way you can calculate them. 1632 Younes, Amin 07:24:31.684 --> 07:24:45.694 Potential maximum risk that you face without knowing anything about distribution upgrade costs now you may be able to mitigate that risk through distribution upgrades, but you can you can calculate the, the maximum risk. I mean, that that is quantifiable. 1633 Sky Stanfield 07:24:46.562 --> 07:24:50.194 You just can't calculate how how it is to occur. 1634 Sky Stanfield 07:24:50.822 --> 07:24:52.624 We know that, like, you can say. 1635 Sky Stanfield 07:24:52.832 --> 07:25:13.952 We'll just be back to we know that. The magnitude of the risk is the entire value of the could be wiped clean and I think the way you put it. Just now makes it. Really quick. Wasn't really striking to me. Which is like, if you think that if that could happen next year, I just think even if it's a 1 kilowatt more like, it's a very. 1636 Sky Stanfield 07:25:13.984 --> 07:25:17.794 To be very hard to justify that cost. Um. 1637 Sky Stanfield 07:25:19.624 --> 07:25:39.694 You know, my sense is, is that, from my perspective, at this point, I am still not comfortable with the basic premise here that LGB customer that we should be shifting the basic cost allocation principles. Utilities are in charge of the grid and how the historically managed it such that this has never result with all the interconnections. 1638 Sky Stanfield 07:25:40.774 --> 07:26:01.892 The 1Million dollar systems, and we've never had a system a situation where load dropped off enough to trigger upgrades and we know that load and things are changing, but likely in our favor. And I think that the planning process should accommodate this instead. And if we need to test that out over time, my, because of. 1639 Sky Stanfield 07:26:01.924 --> 07:26:22.954 The challenges that we've described with 1, putting the weight on 1 customer versus versus the rate base as a whole our, our inclination at this point is to lead on that approach. We've been very, I want to be clear that we've been super open and really trying to work out a different way of doing it and have just come up against a hardware. 1640 Sky Stanfield 07:26:23.284 --> 07:26:44.194 and that hardware is driven by the fact that we are fundamentally not sure we with the concept at all that a customer should interconnect and be responsible for conditions that arise after they've signed their interconnection agreement when they have no control over those circumstances that's a pretty 1641 Sky Stanfield 07:26:44.226 --> 07:27:05.346 Fundamental shift in the policy, and they maybe get some benefit, but that benefit is not unlimited. Either. It's going to be specific based upon what the rates are and so on. So, it's that's where we've come back to at this point after sort of struggling with another, trying to find a different approach. And I think that that's. 1642 Sky Stanfield 07:27:05.884 --> 07:27:26.494 you know something that the commission is going to kind of need to face and i'm not sure that they did when they when they set up the whole program is the idea that this customer should be treated differently um based on circumstances they can't control that's why i think they sent back to define better what those circumstances were and those circumstances continue to be 1643 Sky Stanfield 07:27:26.524 --> 07:27:27.992 Completely out of their control. 1644 Frances Cleveland 07:27:30.364 --> 07:27:47.462 So, I, I have a couple of thoughts here 1st of all risk is probability times the impacts and the impact is loss of revenue. So I don't think we can avoid trying to address the. 1645 Frances Cleveland 07:27:47.792 --> 07:28:08.434 Pack the loss of revenue. The other thing is that loss of load is not only customers going away, but it's also existing customers on that circuit, adding their own generation, and thus reducing, uh, load. 1646 Frances Cleveland 07:28:08.884 --> 07:28:29.764 For their own purposes, so we, you know, you can't look at it as just, um, the load going away. Um, and I think, you know, I, I hear, you know, that the risk is due to things that nobody can foresee but the utilities. 1647 Frances Cleveland 07:28:30.126 --> 07:28:51.096 Foresee it any more than the, um, folks can foresee it? So it seems to me that it's really a question of costs or upgrades getting to at least a a handle on what the costs might be. If there were this kind of upgrade or that kind of upgrade. 1648 Frances Cleveland 07:28:51.934 --> 07:29:11.494 Uh, and the cost for lost revenue, which should be easier to to figure out because you've got tariffs and et cetera, and then formulate and this is, I presume, part of phase 2, a way of sharing that risk. I I don't think you can say that, you know. 1649 Frances Cleveland 07:29:12.248 --> 07:29:33.062 Either side, uh, really, uh, house, uh, the reason for saying, I should not bear any risks sky. You've said that so I think it's really a formula for how do you share that risk once? You know what the costs might be? Um. 1650 Frances Cleveland 07:29:33.454 --> 07:29:54.274 Uh, and I think that that's the key, the key issues. Um, and it can be based, as you say, on, you know, you're better off going in the low risk areas for with but it's not just that it's really just coming up with a formulas for figuring out what the. 1651 Frances Cleveland 07:29:54.664 --> 07:29:59.584 Upgrades might be and the cost of lost revenue. 1652 Younes, Amin 07:30:10.744 --> 07:30:28.294 Just thinking out loud here and not something that we necessarily support, but a relatively simple way to think about it would be to just say, have have the utilities compensate for any lost any load that couldn't be, or any energy that couldn't be served due to. 1653 Younes, Amin 07:30:28.684 --> 07:30:46.114 Whatever conditions changes in conditions I'd say, half the rate. So that way half the, the rate periods, where half the cost, and the, um, the interconnects with customers have half the cost. And I think that the very use, if I'm thinking about that correctly, it's a very easy way to subdivide it without having to get into the nuances of the of the financing. 1654 Regnier, Justin 07:30:49.864 --> 07:30:54.094 So I want to speak a little bit to default. Um. 1655 Regnier, Justin 07:30:55.924 --> 07:31:14.552 The decision did not clarify the reduction of limited. The reduction of the Lumina generation profile to the value is permissible on an ongoing basis. 1656 Regnier, Justin 07:31:20.884 --> 07:31:37.474 That it can be used as a cure to safety and reliability issue that has not been established in the absence of establishing that utility practice is to. 1657 Regnier, Justin 07:31:37.534 --> 07:31:55.802 Perform the upgrades that are required as part of their planning process to restore the grid to a condition, such that the interconnection agreement as it's originally signed, can be honored the IO. 1658 Regnier, Justin 07:31:56.012 --> 07:31:58.502 Raise the concern that doing so. 1659 Regnier, Justin 07:32:01.052 --> 07:32:09.302 Has the potential to impose a disproportionate cost on rate there so. 1660 Regnier, Justin 07:32:10.232 --> 07:32:21.844 The situation I think that Roger put out in the last workshop was the 5Million dollar upgrade for 50 kilowatts of capacity. Um. 1661 Regnier, Justin 07:32:26.164 --> 07:32:29.164 I think the question we have to answer is. 1662 Regnier, Justin 07:32:31.382 --> 07:32:33.902 What is a reasonable balance? 1663 Regnier, Justin 07:32:36.906 --> 07:32:57.846 Between honoring our practice and not establishing a a separate class of customer that doesn't have the right to have their interconnection agreement honored versus putting rate pairs potentially. 1664 Regnier, Justin 07:32:57.964 --> 07:33:13.114 On the hook for large upgrade costs in edge cases, where it's just restoring a small amount of capacity but, you know, that's that's the default situation that we're in. 1665 Regnier, Justin 07:33:17.342 --> 07:33:19.832 So, if if we want to have. 1666 Regnier, Justin 07:33:21.846 --> 07:33:42.964 If we want to have some kind of a threshold or loss of revenue, it has to be met before the undertake the upgrades that's got to get justified current utility practices to provide those upgrades to restore the grid or the condition where the. 1667 Regnier, Justin 07:33:42.970 --> 07:33:48.666 Original interconnection agreement can be honored. That's the default. 1668 Aliaga-Caro, Jose 07:34:00.426 --> 07:34:05.914 So, Scott, I think you had 1 more slide or is that correct? Or not. 1669 Sky Stanfield 07:34:08.734 --> 07:34:14.644 Um, I don't think so I think I, I basically put up these 2 slides about the data needs, but. 1670 Aliaga-Caro, Jose 07:34:14.704 --> 07:34:15.634 Oh, okay. All right. 1671 Sky Stanfield 07:34:15.844 --> 07:34:18.994 We could talk through further, but frankly, I think everyone's too. 1672 Sky Stanfield 07:34:21.272 --> 07:34:28.652 And they're kind of built on hypotheticals about what dependent on which way we go with initial risk. 1673 Aliaga-Caro, Jose 07:34:28.922 --> 07:34:31.142 Okay, I just wanted to make sure we got through your slides. 1674 Sky Stanfield 07:34:31.292 --> 07:34:31.622 I think. 1675 Aliaga-Caro, Jose 07:34:32.012 --> 07:34:36.422 Discussions continued Gary has his hands up. 1676 gary holdsworth sdg&e 07:34:38.942 --> 07:34:42.122 Well, uh, this is a comment from, um. 1677 gary holdsworth sdg&e 07:34:42.214 --> 07:34:51.154 Is an observer of interconnection over 17 years like Roger, not from a position in San Diego or any other. 1678 gary holdsworth sdg&e 07:34:52.472 --> 07:35:12.332 Going back to and I know Justin was wrapping and and was trying to summarize and I, I don't disagree at all with what he was saying as far as summarization. But it does sure seem like this creation of, as you mentioned, Justin a 2nd. 1679 gary holdsworth sdg&e 07:35:13.208 --> 07:35:34.354 Type of customer of different type of customer with different, um, either a different risk profile or a different, you know, financing structure that it has worked for years, you know, just introduces. It's just an observation. Perhaps that just introduces more challenges than. 1680 gary holdsworth sdg&e 07:35:34.384 --> 07:35:35.914 Perhaps it's worth because. 1681 gary holdsworth sdg&e 07:35:38.374 --> 07:35:58.322 You know, despite the fact that, uh, sky will argue that the current system is doesn't work as well. It's worked well, for years it may not work ideally, for every party in every situation. But it's worked well for years and to kind of throw cost causation. 1682 gary holdsworth sdg&e 07:35:58.356 --> 07:36:13.536 Principles side to start talking about cross subsidization and, you know, determination forecasting load departing and when we can barely keep up with the work that we have in front of us. 1683 gary holdsworth sdg&e 07:36:15.902 --> 07:36:25.562 It sounds like more and more. This is way more complicated and it's going to provide any benefit just an observation. Thank you. 1684 Sky Stanfield 07:36:29.014 --> 07:36:49.084 I think Gary that you're right if it's implemented in the way we've been talking about it, we can make it super complicated or we can keep it super simple and that's kind of the choice we have in front of us. Um, I think I'd be curious for the utility is to take a look at some of the curves and think. 1685 Sky Stanfield 07:36:49.116 --> 07:37:10.176 What those curves represent? I think that I think very deeply. And the reason why you Eric has invested so much sweat and trying to come up with a complicated solution. Here is because it seems like there's a huge amount of value to the state of California broadly. Whether we characterize it as ratepayers or citizens. 1686 Sky Stanfield 07:37:10.266 --> 07:37:31.384 Role at, having energy, be able to be produced in a clean and local manner during the hours we need it and not during the hours. We don't need it and avoid thereby avoiding unnecessary grid upgrades. The speaks for itself in that area on the monthly profiles and in some cases. 1687 Sky Stanfield 07:37:31.504 --> 07:37:52.534 There are multiple megawatts of difference in there. That's a lot of energy being needed essentially. So I do feel like there's a huge amount of value potential here and indeed. It's the value potential utilities have been identified for years since the very 1st day is working with Roger on this. The complaint was that customers weren't able to design systems that matched the grid needs. 1688 Sky Stanfield 07:37:53.192 --> 07:38:13.682 That's what we're trying to do here with much resistance. Um, but I do think that you're right that the way the all these options are really complicated. Um, if we're if we're trying to change the cost allocation mechanism, the current, we are the current proposal. Utilities proposal is the 1 that actually is shifting the. 1689 Sky Stanfield 07:38:13.714 --> 07:38:34.834 Cost allocation proposal, the current approach is the customers don't bear the costs after they interconnect. It's it's a shift to they're having them bear the cost based upon the current framework, but I appreciate you sharing your thoughts. Gary I want to mostly wanted to respond that. I agree that we could get make this really complicated, but I also think there's a. 1690 Sky Stanfield 07:38:34.840 --> 07:38:38.884 We didn't do it simply based upon the overall risks in front of us. 1691 Sky Stanfield 07:38:40.478 --> 07:38:43.292 I didn't remember that. I had 1 more slide. Um. 1692 Aliaga-Caro, Jose 07:38:43.504 --> 07:38:43.892 If you know. 1693 Aliaga-Caro, Jose 07:38:44.132 --> 07:38:44.524 Go ahead. 1694 Sky Stanfield 07:38:45.754 --> 07:39:01.562 Uh, and this goes right to what I was just getting at, which this is a slide that's more of a heads up to everybody, um, as part of our work trying to really understand, um, the value so to speak but also how to do. 1695 Sky Stanfield 07:39:01.654 --> 07:39:22.774 How systems could be designed around this and what kind of profile makes sense to do we've been digging into the data that utilities provided us for phase 2 and both trying to look at some sample 24 hour profiles as well as sample 12 months profiles and. 1696 Sky Stanfield 07:39:23.284 --> 07:39:43.864 What we've found so far, is that the sample 24 hour profile by sample I mean, we pulled looked at the suburban feeders and suburban theaters in each of the territories and then we at each node. And then overall for the circuit, and what we're seeing. 1697 Sky Stanfield 07:39:44.132 --> 07:40:05.072 At this stage is not what we would expect, and not entirely explainable based on simple engineering understanding. I told Jose that I would give everybody a heads up about that that said we just got the data from our consultant last week and, um, thanks to having a holiday. 1698 Sky Stanfield 07:40:05.080 --> 07:40:26.224 We did not have not had a chance to fully digested um, we're going to spend hopefully the next week trying to really make sure we understand what we're seeing on our end. And but we do think it's probably going to be something, unless it's potentially something that we're going to need to discuss as a group both as we try to understand. 1699 Sky Stanfield 07:40:26.552 --> 07:40:47.344 Particularly, as we try to understand the 24 hour versus 12 month, or combination there in profile short story is, is that the IC data isn't lining up to what 1 would we typically describe it as looking like? Um, so that was a long winded way of saying there's something. 1700 Sky Stanfield 07:40:47.584 --> 07:41:08.224 We haven't quite understood yet and we're lagging it and I think it would be great if the utilities maybe on your end. Also I'm curious if you guys have ever done this yourselves, which is look at some 24 hour profiles across your systems. Um, because that's what we're going to want to come back to. If it turns out we can't explain it through some clear anomaly. 1701 Roger Salas SCE 07:41:09.034 --> 07:41:20.674 Yes, uh, just not not to go into much into that, but I said, when you say not expected, I said that the profiles are too low that they're fluctuate too much. 1702 Sky Stanfield 07:41:21.544 --> 07:41:29.674 Yeah, so there's a couple of different things and again, I don't want to spend too much too much time until we really digested them. They the main differences are. 1703 Sky Stanfield 07:41:29.678 --> 07:41:50.434 That the load, the thermal, and the voltage criteria do not follow a consistent curve and don't typically the thermal seems someone. Okay but the voltage is where things are seem odd, we would have expected the, not the flicker, but the steady state voltage to. 1704 Sky Stanfield 07:41:50.830 --> 07:42:11.766 Align fairly closely with the thermal curve, which would align fairly closely with the dot com or the load curve essentially. And in some cases, there are radical jobs. So you'll go 1 hour, 1, random hour. Not like, oh, everybody turned their lights on or at 50 PM something happened but like, at 11 0 am for some reason, you'll go from. 1705 Sky Stanfield 07:42:11.978 --> 07:42:33.124 An limit voltage, a limit of 1 megawatt to 5 megawatts or something while, um, so that's what we're seeing again, with a limited sample that we need to digest more down. Very much could be ways to explain why that is happening. Especially with how the 24 hour profile is set up. Um, but we had. 1706 Sky Stanfield 07:42:33.128 --> 07:42:54.274 Taking a look at those 24 hour profiles at the level of detail we need to to understand exactly what what the project would be doing and how they would be able to design the economics around it. So, it was kind of vague Roger, but I think you'll be able to see it. If you look at some of them yourself, they're going to look different for every feeder. So we looked at a sample. 1707 Sky Stanfield 07:42:54.904 --> 07:42:57.814 And and the samples were consistently confusing. 1708 Roger Salas SCE 07:43:01.174 --> 07:43:02.374 Look forward to seeing the data. 1709 Sky Stanfield 07:43:02.704 --> 07:43:03.184 Yeah. 1710 Sky Stanfield 07:43:06.482 --> 07:43:10.412 Um, can I just ask you Roger, if you guys have done that look yourself. 1711 Roger Salas SCE 07:43:10.472 --> 07:43:19.652 None, I don't think we done that type of evaluation and, I mean, we, we look at we generally just look at the actual. I see. 1712 Roger Salas SCE 07:43:19.658 --> 07:43:36.004 A profile, but that already encompasses the minimum value of the thermal voltage power quality. Um, and so those typically tend to be, I mean, are these, the ones that I've seen pretty well predicted, you know. 1713 Sky Stanfield 07:43:36.004 --> 07:43:39.962 When you're looking at the effort, what happens if you take the out. 1714 Roger Salas SCE 07:43:41.312 --> 07:44:01.952 I mean, I don't think I've seen any normalities, but but I think, uh, I mean, it seems that you're looking specifically at the, uh, the for voltage and the for Thermo individually and trying to make a sense of each of those individually. I don't think we've done the level, which is basic. Look like the 1 that has. 1715 Roger Salas SCE 07:44:01.958 --> 07:44:03.094 Everything on it, right? 1716 Sky Stanfield 07:44:03.724 --> 07:44:23.044 Yeah, so what we did, and again we'll get into it more. We did, we looked at the problem, which can be weird because it's and then we broke it down by the different criteria to see if we could understand why it was being weird. And that's where you see the, the differences. It's really interesting and we're going to talk a lot more about it. 1717 Sky Stanfield 07:44:23.494 --> 07:44:33.424 Um, but it is a little it does affect what we're doing here. Um, I don't know in in which direction quite yet. I mean, do you have a question. 1718 Younes, Amin 07:44:34.654 --> 07:44:38.014 No, I'm just very interested in what you're saying about that. Yeah, I, I've looked at. 1719 Sky Stanfield 07:44:38.014 --> 07:44:44.254 I'm not trying to hide things. We didn't want to share it until we all digested it ourselves just so that we could be coherent. 1720 Sky Stanfield 07:44:44.260 --> 07:44:52.144 And about it, and I talked with Jose about it, and he suggested just giving everybody a heads up. So that's what I'm doing. I'm not trying to be all sneakier. 1721 Alex Mwaura PG&E 07:45:00.152 --> 07:45:06.332 Is it possible to share that information Skype prior to the workshop, or this will be discussed so we can sort of. 1722 Alex Mwaura PG&E 07:45:06.542 --> 07:45:06.842 Into. 1723 Sky Stanfield 07:45:07.652 --> 07:45:16.682 I think what we haven't talked through it yet, because again, we need to digest it a few a bit more. But what we, what we could probably do is set up. 1724 Sky Stanfield 07:45:16.924 --> 07:45:37.834 Develop some slides that we share in advance of people to digest and then do a presentation and we can bring our consultant in. I mean, our consultants really just applying the data, like, taking what you guys sent us and putting it in a graph is the is the basic method. Um, but that's what we'd be happy to provide some. 1725 Sky Stanfield 07:45:37.866 --> 07:45:43.804 So, you guys can look at it and get some thoughts before the meeting and whenever that happens, that's what we still have to work out. 1726 Alex Mwaura PG&E 07:45:45.364 --> 07:45:46.624 I'm sorry, go ahead. 1727 Roger Salas SCE 07:45:47.254 --> 07:45:48.874 Please finish your reply. 1728 Alex Mwaura PG&E 07:45:49.174 --> 07:45:54.634 So this is based on 202,112 months so basically, January to December 2021. 1729 Sky Stanfield 07:45:54.694 --> 07:46:06.034 So, you guys provided us the data in March? I believe it was as March of 2021? No, March of 2022. so just earlier this year. 1730 Sky Stanfield 07:46:06.392 --> 07:46:27.182 Um, is that right? Yeah. Um, so it's, it's essentially the, the, for each of your territories that was stamped in March of 2022 that we're working off of and, and that happens to be beneficial, because the issues that came up with addison's, um, I see later. So, we're, we're kind of eliminating those and assuming that. 1731 Sky Stanfield 07:46:27.214 --> 07:46:41.584 The old data, the variations are not that different across the utilities. They're all unique in their own way, but it wasn't like, oh, this seems to be 1, utilities results versus and others again. I don't know what that means. 1732 Sky Stanfield 07:46:43.146 --> 07:46:45.066 Sharing what I what I can at this point. 1733 Roger Salas SCE 07:46:46.356 --> 07:46:48.336 I was going to ask about that because it's just. 1734 Roger Salas SCE 07:46:48.366 --> 07:46:58.804 We, we're in the process of updating our IC values over the next few months and so whatever data you had for cattle those discrepancies. So just. 1735 Sky Stanfield 07:47:00.154 --> 07:47:06.664 Shouldn't have had those discrepancies as far as I understand based on when you guys did the rollout. 1736 Roger Salas SCE 07:47:06.846 --> 07:47:07.324 Yeah. 1737 Sky Stanfield 07:47:07.414 --> 07:47:09.456 But we're happy to use the. 1738 Sky Stanfield 07:47:09.516 --> 07:47:26.946 That metadata, when you got it, but like I said, he doesn't look like it's, it's not the addison's. Was that different than the other? So I don't think there there was an anomaly from that again. It's really going to be helpful to get you guys as input. Once we and I feel silly telling you all about us so that we got to show it to, you. 1739 Regnier, Justin 07:47:28.836 --> 07:47:30.606 I think everybody's looking forward to the data. 1740 Sky Stanfield 07:47:30.994 --> 07:47:31.294 Yeah. 1741 Regnier, Justin 07:47:32.884 --> 07:47:39.664 So, I think we're starting to lose folks and it's been a long day. I just wanted to do a little bit of level setting before we wrap up. Um. 1742 Regnier, Justin 07:47:42.124 --> 07:48:03.062 Appreciate gary's frustration and concern um, but we are Ministerio and we have been instructed to implement this and we have to implement this. So, I, I don't know that there's any, any other option on the table. Um, at this point, I don't know that we've got any. 1743 Regnier, Justin 07:48:03.096 --> 07:48:24.214 Record that thanks, no worries. Um, I don't think that we've got any record that indicates that the have a viable path and permanently reducing the export values that are in the and. 1744 Regnier, Justin 07:48:24.220 --> 07:48:43.656 Connection agreement, the default is to go as we always have, um, where rate pairs pay for upgrades to return the grid to a condition where the interconnection agreement can be honored on a permanent basis. 1745 Regnier, Justin 07:48:45.394 --> 07:49:05.764 So, I think there's been a lot of flexibility by parties and trying to come up with designs that honor the concerns about inordinate costs per minimal benefit on edge cases. But. 1746 Regnier, Justin 07:49:07.532 --> 07:49:16.352 There needs to be a record if we want to deviate from the practice that has been common here. 1747 Regnier, Justin 07:49:19.564 --> 07:49:24.904 We need to get to, um, advice, letter language. 1748 Regnier, Justin 07:49:27.668 --> 07:49:29.344 Um, so. 1749 Regnier, Justin 07:49:30.516 --> 07:49:51.634 If we can't establish or values don't establish the, there's a rationale for treating customers, any different than any other customer. We're going to be on the default pathway. As far as I can see, we need a record to justify any deviation. 1750 Regnier, Justin 07:49:51.664 --> 07:49:58.894 From that, um, appreciate everybody's flexibility and trying to to find something that. 1751 Regnier, Justin 07:50:00.364 --> 07:50:02.194 Spies, everybody's concerns. 1752 Regnier, Justin 07:50:06.064 --> 07:50:14.914 I think we should bear in mind what the default cases, and what we need to do in terms of building a record. If we want to deviate from that default. 1753 Regnier, Justin 07:50:17.402 --> 07:50:17.882 I think. 1754 Regnier, Justin 07:50:19.956 --> 07:50:29.914 I'd leave it to, let's say, as the facilitator, but I think that we are at a, at the tail end of a very long day and we're starting to lose folks. So I don't know if. 1755 Regnier, Justin 07:50:31.120 --> 07:50:34.084 Have any other things we want to cover in today's conversation. 1756 Aliaga-Caro, Jose 07:50:39.334 --> 07:50:56.494 Um, I do not have anything, uh, left to say in my mind that this hour, other than I need sleep. Um, but, uh, you know, we're definitely going to have a workshop 3. 1757 Aliaga-Caro, Jose 07:50:56.674 --> 07:50:58.142 Logistics and date. 1758 Aliaga-Caro, Jose 07:50:59.320 --> 07:51:18.724 Still to be determined, um, we do need to get that in the books, though as soon as possible. So, you know, definitely not next week. Of course. But I am thinking some time the week of December. 1759 Aliaga-Caro, Jose 07:51:20.556 --> 07:51:24.426 Uh, to get that going, um. 1760 Aliaga-Caro, Jose 07:51:26.464 --> 07:51:36.124 The, uh, recording, uh, and the slides should be updated to the rule 21 webpage probably by Thursday or Friday this week. 1761 Aliaga-Caro, Jose 07:51:37.414 --> 07:51:38.254 Um. 1762 Aliaga-Caro, Jose 07:51:41.374 --> 07:51:42.694 I'm going to say is. 1763 Aliaga-Caro, Jose 07:51:44.440 --> 07:51:50.104 I don't know why bother making agendas with I mean, considering they never work out. 1764 Aliaga-Caro, Jose 07:51:53.492 --> 07:51:56.042 So, anyways, that's a joke. 1765 Aliaga-Caro, Jose 07:51:58.024 --> 07:52:00.274 Right now I'm thinking, I should just say. 1766 Aliaga-Caro, Jose 07:52:02.494 --> 07:52:22.474 1, to 5, everything in 1, big chunk but, uh, anyways, uh, kidding aside. Uh, thank you everybody for, uh, this, uh, great discussion today. Um, definitely this is a very complicated. 1767 Aliaga-Caro, Jose 07:52:22.510 --> 07:52:31.536 I think we do have some good ideas that we need to think about. Uh, thank you Scott for presenting this. Um. 1768 Aliaga-Caro, Jose 07:52:34.022 --> 07:52:54.542 So, I think I will follow up within the next couple of days with follow up items to the utilities and to the non parties. Once I review the recording again, and we can discuss next steps, uh, through email. And, you know, if you always. 1769 Aliaga-Caro, Jose 07:52:55.594 --> 07:52:56.464 Want to meet. 1770 Aliaga-Caro, Jose 07:52:57.760 --> 07:53:09.336 Discuss offline, or outside the workshop, uh, and talk for a little bit, you know, just shoot me an email and we can make that happen. So, um. 1771 Aliaga-Caro, Jose 07:53:10.506 --> 07:53:16.836 Just for a couple minutes, I guess I'll open it up to. And if anybody else has anything else to say. 1772 Sky Stanfield 07:53:18.934 --> 07:53:27.124 I just wanted to say, thanks for everybody for a good conversation as well. There's certainly a lot of part issues here and appreciate everybody's engagement. 1773 Aliaga-Caro, Jose 07:53:33.064 --> 07:53:37.024 All right, well, thank you again. Everybody. 1774 Roger Salas SCE 07:53:37.114 --> 07:53:37.714 Thanks everybody. 1775 Aliaga-Caro, Jose 07:53:38.104 --> 07:53:44.854 And, uh, I hope you have, uh, I hope you can, uh, decompress, uh, this evening somehow. 1776 Roger Salas SCE 07:53:47.164 --> 07:53:48.034 It. 1777 Aliaga-Caro, Jose 07:53:48.694 --> 07:53:50.134 All right thanks. Everyone. 1778 Frances Cleveland 07:53:51.814 --> 07:53:52.144 By. 1779 Aliaga-Caro, Jose 07:53:52.596 --> 07:53:52.804 Bye.