Limited Generation Profiles
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
- Working Group Two Report (See Issue 9)
- D.20-09-035 (See Discussion on Issue 9 at p.51-60, and OPs 15 and 16 at p.209-210)
- Resolution E-5211
- Resolution E-5230
Meetings
October 27, 2022: Smart Inverter Working Group
- Agenda
- Presentation Slides: Integration Capacity Analysis (Limited Generation Profiles)
November 7, 2022: Limited Generation Profiles Workshop 1 per Resolution E-5211
- Energy Division: Introduction and Agenda
- IOU Presentation Slides
- Topic and Requirements for Workshop 1
- November 7th Recorded Workshop password - FbYh27m3
- November 7th Workshop Transcript (.txt)
- November 7th Workshop Transcript (.vtt -- can be opened with a text editor)
November 10, 2022: Smart Inverter Working Group
- Presentation Slides: Integration Capacity Analysis (Limited Generation Profiles)
- Follow-Up to Presentation Slide #8 (Explanation of the 90 and 10% loading: Clarification on how this is arrived at and used in determining the 576 profile)
November 29, 2022: Limited Generation Profiles Workshop 2 per Resolution E-5211
- Energy Division: Introduction and Agenda
- IOU Presentation Slides
- IREC Presentation Slides
- November 29th Recorded Workshop password - MxS6FTFE
- November 29th Workshop Transcript (.txt)
- November 29th Workshop Transcript (.vtt -- can be opened with a text editor)
December 16, 2022: Limited Generation Profiles Workshop 3 per Resolution E-5211
- Energy Division: Introduction and Agenda
- Excerpts from Resolution E-5211
- IOU Presentation Slides
- IREC Presentation Slides
- December 16th Recorded Workshop password - DmensNT3
- December 16th Workshop Transcript (.txt)
- December 16th Workshop Transcript (.vtt - can be opened with a text editor)
January 19, 2023: Smart Inverter Working Group
February 1, 2023: Limited Generation Profiles Workshop 1 per Resolution E-5230
- Energy Division: Introduction and Agenda
- The Public Advocates Office (PAO) Slide Presentation: 288-Value Limited Generation Profiles
- KITU Systems Slide Presentation: CSIP for LGP Resolution E-5230 Requirements
- EPRI Slide Presentation: DER LGP Profiles and Standard Schedule File Format
- IOU Slide Presentation: Implementation of LGP Using Current Smart Inverter Functions & Implementing More than 12 LGP Values Per Year; and Data Analysis
- February 1st Recorded Workshop password - hJFpbZU8
- February 1st Workshop Transcript (.txt)
- February 1st Workshop Transcript (.vtt - can be opened with a text editor)
- February 1st Workshop Chat Transcript
February 2, 2023: Smart Inverter Working Group
February 16, 2023: Smart Inverter Working Group
- Agenda
- IOU Slides: Implementation of Limited Generation Profiles Using Current Smart Inverter Functions
February 21, 2023: Limited Generation Profiles Workshop 2 per Resolution E-5230
- Energy Division: Introduction and Agenda
- IOU Presentation Slides:
- Implementing More than 12 LGP Values Per Year: Data Analysis
- Implementation of Limited Generation Profiles Using Current Smart Inverter Functions
- Use of Gross Nameplate Rating
- Overview of Proposal
- February 21st Recorded Workshop password - UdrSJCR7
- February 21st Workshop Transcript (.txt)
- February 21st Workshop Transcript (.vtt - can be opened with a text editor)
March 2, 2023: Smart Inverter Working Group
March 14, 2023: Limited Generation Profiled Workshop 3 per Resolution E-5230
- Energy Division Introduction and Agenda
- IOU Presentation Slides
- March 14th Recorded Workshop AM Session password - yQ2j6tHX
- March 14th Recorded Workshop PM Session password - Limited23!
- March 14th Workshop Transcript (.txt)
- March 14th Workshop Transcript AM Session (.vtt - can be opened with a text editor)
- March 14th Workshop Transcript PM Session (.vtt - can be opened with a text editor)
March 16, 2023: Smart Inverter Working Group
March 30, 2023: Smart Inverter Working Group
- Agenda
- IOU Slides: LGP Topics B.2, C, and E
- (Tentative) The Public Advocates Office (PAO) Slide Presentation: 288-Value Limited Generation Profiles
April 7, 2023: Limited Generation Profiles Workshop 4 per Resolution E-5230
- Energy Division: Introduction and Agenda
- IREC: Blocked LGP Analysis
- IREC: RTAC
- ASE: RTAC
- The Public Advocates Office (PAO): 288-Value Limited Generation Profiles
- PG&E: Statistical Analysis LGP
- SCE: Additional LGP Analysis
- IOU Presentation Slides
- April 7th Recorded Workshop password - MvFbhZW7
- April 7th Workshop Transcript (.txt)
- April 7th Workshop Transcript (.vtt - can be opened with a text editor)
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