Background

Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), and San Diego Gas & Electric Company (SDG&E), collectively the large investor-owned utilities (Large IOUs), submitted Tier 3 Advice Letters (ALs) -- PG&E AL 6058-E, SCE AL 4404-E, and SDG&E AL 3678-E -- to comply with Ordering Paragraph (OP) 16 and ALs -- PG&E AL 6141-E, SCE AL 4455-E, and SDG&E AL 3721-E -- to comply with OP 15 and 51 of D.20-09-035 (the Decision). 

The Decision resolved Issue 9 (Limited Generation Profiles or LGP) from Working Group Two.  As stated in the Decision: 

Issue 9 looks at the conditions of operations the Commission should adopt to allow distributed energy resources to perform within existing hosting capacity constraints and avoid triggering [distribution grid] upgrades… The purpose of resolving Issue 9, as highlighted by IREC, is to utilize the Integration Capacity Analysis data to allow modern inverters, storage, and other technologies to confidently respond to grid conditions while ensuring safety and reliability.

 

Ordering Paragraph (OP) 16 of the Decision required the Large IOUs to submit ALs providing “the specifics of whether and how reductions to a customer’s Limited Generation Profile are determined. The Advice Letter shall include a description of how the Utilities will implement Ordering Paragraph 15.”   OP 15 adopted the Large IOUs’ counter proposal for Issue 9 with modifications and required the Large IOUs to submit ALs:

“providing recommendations (as applicable) regarding the standard review, certification requirements, and interconnection processes necessary for implementation of the proposal…Retroactive alterations to generation profiles shall not reduce generation to below a pre-defined static level, i.e., the lowest Integrated Capacity Analysis – Static Grid typical profile value identified at the time of the Interconnection Application. As part of the proposal, Utilities shall: i) allow customers to utilize a smart inverter’s ability to increase its output on a monthly basis; and ii) use a 10 percent buffer, which shall be revisited.” 

Resolution E-5211, issued by the California Public Utilities Commission (the Commission) on October 10, 2022, rejected PG&E AL 6058-E, SCE AL 4404-E, and SDG&E AL 3678-E without prejudice.  Resolution E-5211 ordered the Large IOUs to participate in a minimum of two full-day workshops to confer with stakeholders on topics identified as needing discussion, and ordered the Large IOUs to file subsequent Tier 3 ALs within 90 days after issuance of the resolution.

Resolution E-5230, issued by the Commission on December 9, 2022 approved in part, modified, and sought clarity on PG&E AL 6141-E, SCE AL 4455-E, and SDG&E AL 3721-E providing recommendations regarding the standard review, certification requirements, and interconnection processes necessary for implementation of the Limited Generation Profile proposal and proposal that would allow an inverter approved for non-export and limited-export to be set using different maximum export value settings at different times of the year.  It required Large IOUs to participate in a minimum of two half-day workshops to discuss outstanding issues, and ordered the Large IOUs to file subsequent Tier 3 ALs updating their proposals by May 1, 2023. 

These workshops continued discussions to resolve Limited Generation Profiles (per OP 16 and 15 of D.20-09-035).

Relevant Documents

Meetings

October 27, 2022:  Smart Inverter Working Group

November 7, 2022:  Limited Generation Profiles Workshop 1 per Resolution E-5211

November 10, 2022:  Smart Inverter Working Group

November 29, 2022:  Limited Generation Profiles Workshop 2 per Resolution E-5211

December 16, 2022: Limited Generation Profiles Workshop 3 per Resolution E-5211

January 19, 2023: Smart Inverter Working Group

February 1, 2023: Limited Generation Profiles Workshop 1 per Resolution E-5230

February 2, 2023: Smart Inverter Working Group

February 16, 2023: Smart Inverter Working Group

February 21, 2023: Limited Generation Profiles Workshop 2 per Resolution E-5230

March 2, 2023: Smart Inverter Working Group

March 14, 2023: Limited Generation Profiled Workshop 3 per Resolution E-5230

March 16, 2023: Smart Inverter Working Group

March 30, 2023:  Smart Inverter Working Group

April 7, 2023:  Limited Generation Profiles Workshop 4 per Resolution E-5230

April 13, 2023: Smart Inverter Working Group

Current Status as of July 2023:

The Large IOUs filed a Joint Advice Letter— PG&E Advice Letter 6816-E, SCE Advice Letter 4941-E, and SDG&E Advice Letter 4138-E –on January 9, 2023 and a Joint Supplemental Advice Letter— PG&E Advice Letter 6816-E-A, SCE Advice Letter 4941-E-A, and SDG&E Advice Letter 4138-E-A–on January 23, 2023 to meet the requirements of Resolution E-5211.

The Large IOUs filed a Joint Advice Letter—PG&E Advice Letter 6929-E, SCE Advice Letter 5025-E, and SDG&E Advice Later 4215-E—on May 1, 2023, to meet the requirements of Resolution E-5230.

The Advice Letters are under review by Energy Division and will be subject of an upcoming resolution Quarter 4 of 2023.

Contacts:

For information specific to Limited Generation Profiles proposals contact Jose Aliaga-Caro at jose.aliaga-caro@cpuc.ca.gov