A California Public Utilities Commission administrative law judge (ALJ), in a Jan. 21 ruling, sought comments by Jan. 30 from interested parties on the commission staff’s proposal titled, “Short-Term Actions to Accelerate the Deployment of Microgrids and Related Resiliency Solutions.”
Reply comments must be filed and served by Feb. 6, ALJ Colin Rizzo said.
The commission in September 2019 initiated the rulemaking to design a framework surrounding the commercialization of microgrids associated with Senate Bill (SB) 1339, as well as to account for the commission’s commitment toward utilizing additional technologies and activities that would be useful for achieving overall resiliency goals, Rizzo said.
As noted in staff’s proposal, SB 1339, enacted in 2018, directs the commission to undertake activities to further develop policies related to microgrids.
Rizzo said in the ruling that an Energy Division staff workshop was held in December 2019, with staff and stakeholders discussing short-term actions related to microgrids and other resiliency strategies that could be initiated in early 2020 to reduce the impact of public safety power shutoff (PSPS) outages or other catastrophic events. The assigned commissioner in December 2019 issued a scoping memo and ruling, directing the commission’s Energy Division staff to issue a staff proposal aimed at proposing potential solutions to the “Track 1” issues for Phase I of the rulemaking, Rizzo said.
As noted in staff’s proposal, the issues included in the scope of Track 1 are:
- Prioritizing and streamlining interconnection applications to deliver resiliency services at key sites and locations
- Modifying existing tariffs to maximize resiliency benefits
- Facilitating local government access to utility infrastructure and planning data to support the development of resiliency projects
As noted in the filing, staff recommends requiring investor-owned utilities (IOUs) to, for instance:
- Develop and implement the ability to use standardized, pre-approved system designs in interconnections applications for projects that can deliver energy services during broader grid outages
- Commit additional resources to their interconnection study and distribution upgrade teams, as well as to the information technology solutions that support those teams, in order to facilitate faster processing for all projects
- Modify Net Energy Metering (NEM) tariffs to allow storage devices to charge from the grid during the pre-PSPS window
- Modify NEM tariffs to remove storage sizing limit and to require islanding ability for energy storage systems larger than 10 kW
- Conduct meetings to educate and inform local government agencies on vulnerable electric transmission and distribution infrastructure and critical operations that serve the local jurisdictions
- Develop a guide to assist and engage local governments in navigating the IOUs’ interconnection processes for deploying a resiliency project
Among other things, staff noted that the interconnection application review process for small generating facilities on the NEM tariff take, on average, two to three days to review, and that most interconnecting projects qualify for the Fast Track process within the IOUs’ Rule 21 Tariffs, which allows for an expedited interconnection review.
However, during informal conversations, stakeholders have reported that the time required to interconnect certain, more complex types of distributed energy resource systems represents a significant constraint on the overall rate of statewide deployment of distributed energy resources. Staff added that projects that provide resiliency are more likely to experience interconnection delays than simpler projects that cannot provide resiliency because, in general, resiliency focused projects must have the ability to electrically island generation and energy storage assets. Projects that island require longer study processes to ensure that there is no inadvertent export of energy to the grid, staff said, adding that validation of those systems often requires more extensive review of interconnection applications in order to protect worker safety and avoid creating a source of ignition.
Rizzo said that to guide parties’ and the commission’s review of the material, the ruling directs parties to respond in their comments to certain questions about the recommendations contained in the staff proposal and any IOU proposals. Those questions include whether changes to any rate schedules or electric rules are needed to implement any of the proposals; whether commission action is required in order to implement any of the proposals; and whether the commission should consider cost recovery for any of the proposals in the proceeding, Rizzo said.