The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Last Week's New Ruling +1
Prehearing Conference Details
A prehearing conference for Rulemaking 25-02-005 will take place on April 7, 2025, at 10:00 a.m. via videoconference, with telephone access available.
Access Information
Access details include a webinar link and phone numbers for participation.
Speaker Information Submission
Parties must email their designated speaker and alternate speaker information, including title, party name, email, and phone number, to Nicholas Bonino and Thomas...
Gutierrez by April 2, 2025. Each party is limited to one speaking representative and one alternate.
Ruling Issuance
This ruling was issued by Administrative Law Judge Jacob L. Rambo on March 21, 2025, in San Francisco, California.
Last Week's New Comments +6
Overview
A range of stakeholders, including labor unions, utility companies, community associations, and advocacy groups, have submitted comments on CPUC proceeding R25-02-005. These comments address various aspects of the proposed updates to the Energy Resource Recovery Account (ERRA) and Power Charge Indifference Adjustment (PCIA) policies, reflecting diverse perspectives on ensuring fairness, accuracy, and stability in the PCIA framework.
PCIA Framework
CalCCA emphasizes the need for fair administration of the PCIA framework to ensure equitable treatment of both bundled and unbundled customers. CUE recommends against adopting a monthly calculation method unless it incorporates all transaction data to reduce rate volatility.
Resource Adequacy Market Price Benchmark (RA MPB) Calculation
TURN highlights significant flaws in the current RA MPB methodology, advocating for the inclusion of both short-term and long-term resource commitments to better reflect procurement costs. Joint IOUs support interim changes to the RA MPB and suggest expanding the dataset used for more comprehensive calculations.
Monthly Procurement Budgets (MPBs)
CUE expresses concerns about the accuracy of MPB estimates when transactions are divided into monthly categories, particularly in high-cost months. CAL ADVOCATES/BONE/CPUC supports the use of monthly MPB values while maintaining market sensitivity rules.
Exclusion of Transactions
Cal Advocates proposes excluding affiliate, swap, and sleeve transactions from RA MPB calculations to prevent market manipulation and ensure accurate market price signals. The Alliance for Retail Energy Markets, Direct Access Customer Coalition (AReM/DACC) also recommends excluding certain transactions to avoid double-counting and misrepresentation of market values.
Affordability and Cost Allocation
CalCCA critiques the current PCIA framework for potentially increasing costs for unbundled customers while benefiting bundled customers. Joint IOUs stress the importance of fairness in cost allocation to prevent bundled service customers from shouldering higher rates compared to departing load customers.
Legal and Methodological Reforms
TURN advocates for comprehensive reforms, including the addition of Renewable Portfolio Standard (RPS) MPB adjustments and the development of imputed RA values for renewable resources. Cal Advocates calls for legal clarity on negative PCIA rates and supports methodological enhancements to improve data modeling and reflect current market conditions accurately.
Support for Proposed Timeline and Process
Joint IOUs endorse the proposed timeline for Track 1 of the OIR and advocate for the inclusion of renewable portfolio considerations in the Resource Adequacy framework. They also support the release of anonymized data to inform future discussions in Track 2.
Data Representation and Modeling
Cal Advocates emphasizes the importance of using a large and diverse dataset to accurately represent market values, proposing the inclusion of data from multiple years to enhance the reliability of MPB calculations. AReM/DACC supports using data from the most recent three years to better reflect current market conditions.
Last Week's New Comment +1
Parties Involved
The Joint Investor-Owned Utilities (IOUs) of California, including PG&E, SDG&E, and SCE, are responding to Alexis Wodtke's Application for Rehearing (AFR).
Background
This response pertains to the California Public Utilities Commission (CPUC) Resolution E-5354, which was issued on February 4, 2025. The resolution involves PG&E's implementation of Income Graduated Fixed Charges (IGFC) as mandated by Decision 24-05-028 and Assembly Bill 205.
Critiq...
ue of Wodtke's AFR
CPUC's Discretion and Compliance
The CPUC has broad discretion in its proceedings, including the determination of appropriate notice and the necessity of hearings. Wodtke's claims about inadequate public notice and the need for evidentiary hearings are refuted, as the advice letter process complied with existing regulations and provided her with a meaningful opportunity to be heard. The CPUC's decisions are based on a well-developed record, and Wodtke's assertions about errors and unreasonable assumptions lack specific evidence of prejudice.
Implementation Timeline
PG&E's implementation of the IGFC structure is scheduled for March 2026, with additional advice letters required to ensure accurate rate calculations. The CPUC's requirement for Tier 3 Advice Letters allows for adequate stakeholder participation and aligns with the approved rate design framework.
Concerns Addressed
Conclusion
Overall, Wodtke's AFR is deemed insufficient, lacking specific legal citations and factual evidence necessary to demonstrate legal error. The Joint IOUs request that the CPUC deny her application based on these grounds.
Last Week's New Comments +7
Overview
This update provides a summary of comments filed on March 20, 2025, by various stakeholders regarding CPUC proceeding R23-01-007. The comments address the implementation of Senate Bill 846, particularly focusing on the extension of operations at the Diablo Canyon Power Plant and the management of Volumetric Performance Fees (VPFs).
Implementation of Senate Bill 846
Coalition of California Utility Employees (CUE) recommends that the Public Utilities...
Commission (PUC) continue to implement SB 846 in accordance with Decision D.23-12-036, allowing Pacific Gas and Electric Company (PG&E) discretion over its VPF compensation. PG&E acknowledges that the Proposed Decision (PD) resolves several issues but identifies errors that need correction to align with statutory guidelines.
VPF Spending and Restrictions
CUE opposes proposals from Utility Reform Network (TURN), California Community Choice Association (CalCCA), and Alliance for Nuclear Responsibility (A4NR) that seek to restrict PG&E's spending of VPF compensation, arguing that these restrictions contradict SB 846 and Decision D.23-12-036. TURN emphasizes the need to prevent PG&E from using VPFs to benefit shareholders, recommending that VPFs be prioritized for energization and wildfire mitigation projects. CalCCA and A4NR advocate for equitable distribution of VPFs, with CalCCA specifically calling for VPF funds to prioritize projects that benefit the largest number of customers and prohibit their use for PG&E’s generating assets.
Application Process for VPF Spending
CUE suggests eliminating the requirement for PG&E to file an application for VPF spending plan approval, advocating instead for an advice letter process to expedite funding for public priorities.
Affordability and Reporting Requirements
Small Business Utility Advocates (SBUA) supports the Commission's focus on affordability but calls for enhanced reporting on small commercial customers benefiting from VPF initiatives. TURN recommends rejecting PG&E's annual VPF compensation report template in favor of a more comprehensive reporting approach. PG&E argues that the PD’s inclusion of affordability and customer benefit metrics violates statutory language and recommends modifications to align with existing provisions.
Equitable Distribution and Participation of Small Businesses
SBUA emphasizes the importance of increasing small business participation in utility programs by identifying gaps and conducting targeted outreach. CalCCA advocates for prioritizing VPF spending on distribution and transmission projects to ensure equitable benefits for all customers, preventing disproportionate costs on small businesses.
Legal Concerns and Statutory Compliance
A4NR criticizes the PD’s reliance on Decision D.23-12-036 for limiting critical public purpose priorities to PG&E’s service territory, arguing it undermines anti-discrimination provisions of Public Utilities Code Section 453. TURN highlights concerns that the PD does not adequately prevent shareholder enrichment and calls for compliance with Section 712.8(s) to ensure VPFs are used for public purposes.
Recommendations for Commission's Guidance and Decision
CUE and CalCCA advocate for maintaining PG&E’s discretion over VPF spending while calling for process revisions to align with legislative intent. TURN suggests adopting its proposals to constrain VPFs for essential capital expenditures and enhancing reporting requirements. PG&E recommends that the Commission evaluate the necessity of ongoing audits and modify findings related to customer benefit metrics to better align with statutory guidelines.
Collaboration and Funding Plans
A4NR emphasizes the need for PG&E to collaborate with SCE and SDG&E to create funding plans for critical public purposes within their respective areas, advocating for a harmonized approach to VPF distribution and utilization.
Prioritization of Projects
CalCCA urges the Commission to prioritize VPF spending on electric distribution and transmission projects, allowing generation project funding only when other options are exhausted to maximize customer benefits and maintain equitable distribution of resources.
Last Week's New Comments +22
Overview
The California Public Utilities Commission (CPUC) is conducting Rulemaking 23-10-011, which focuses on reforms to the Resource Adequacy (RA) Program. Various stakeholders, including utilities, trade associations, and energy providers, have submitted reply comments addressing key aspects such as Planning Reserve Margins (PRM), load obligation trading, and the integration of energy storage resources. This update highlights a sampling of these positions to...
provide a comprehensive view of the ongoing discussions.
Planning Reserve Margin (PRM)
Calpine Corporation supports the proposed PRMs of 21% for June-October and 20% for other months to achieve a 1-in-10 Loss of Load Expectation (LOLE) annually. Southern California Edison Company (SCE) advocates for a 17% PRM, arguing it suffices for reliability and criticizes higher proposals as financially driven. Microsoft Corporation endorses Staff Proposal B, recommending a 22.5% PRM to meet LOLE standards. American Clean Power - California also supports a robust PRM aligned with a 0.1 LOLE, emphasizing reliability.
Load Obligation Trading
The California Community Choice Association (CalCCA) advocates for hourly load obligation trading to enhance affordability and efficiency, proposing a 25% limit with a review after one year. Pacific Gas and Electric Company (PG&E) supports CalCCA’s adjustments and recommends further examination of these limits. The Alliance for Retail Energy Markets (AReM) endorses the proposal, suggesting accountability measures for Load Serving Entities (LSEs) post-trade.
Unforced Capacity (UCAP)
The California Energy Storage Alliance (CESA) calls for developing a UCAP accreditation methodology for thermal power plants and battery storage systems, emphasizing the need for comparable UCAP values across resource types. Microsoft Corporation recommends a structured working group for future LOLE modeling to enhance transparency in UCAP development. Middle River Power LLC (MRP) urges collaboration with CAISO on UCAP and opposes counting Energy-Only resources towards RA requirements.
Resource Sufficiency and Imports
Calpine Corporation expresses concerns that SCE's recommendations may overly rely on non-resource adequacy (RA) imports, potentially jeopardizing the 1-in-10 LOLE objective. The Clean Energy Buyers Association (CEBA) criticizes SCE’s approach to PRM and import reliability, advocating for a robust PRM to meet LOLE standards. California Environmental Justice Alliance (CEJA) emphasizes that relying on imports could undermine reliability and supports maintaining higher PRMs.
Energy Storage Integration
California Energy Storage Alliance (CESA) opposes SCE’s proposal to eliminate interim charging sufficiency for paired resources, advocating instead for a nuanced approach based on duration and efficiency. Microsoft Corporation supports integrating energy storage at its Effective Load Carrying Capacity (ELCC) to align RA value with reliability. Middle River Power LLC (MRP) rejects mandates for Long Duration Energy Storage (LDES) in the RA program, suggesting such discussions occur within the Integrated Resource Planning (IRP) framework.
Methodological Concerns and Reliability Standards
California Independent System Operator Corporation (CAISO) opposes lower PRM justifications, asserting that higher PRMs are necessary for meeting 0.1 LOLE reliability standards. Shell Energy North America (US), L.P. raises concerns about the RA waiver process potentially leading to market distortions. The Center for Energy Efficiency and Renewable Technologies (CEERT) supports UCAP methodologies that align with IRP obligations to ensure reliability without compromising affordability.
Stakeholder Collaboration and Future Planning
CalCCA and The Alliance for Retail Energy Markets (AReM) emphasize the need for ongoing dialogue and collaborative working groups to refine PRM and UCAP methodologies. Cal Advocates/M.Miley/CPUC urges the Commission to adopt broker initiatives and enhance market-driven solutions for co-located resources. San Diego Gas & Electric Company (SDG&E) and other stakeholders call for maintaining the current PRM while supporting further analysis for future adjustments.
Affordability and Cost Mitigation
Microsoft Corporation argues that higher PRMs do not necessarily increase costs and highlights historical instances where low PRMs led to significant price spikes and reliability issues. The California Environmental Justice Alliance (CEJA) counters concerns about PRM affordability by emphasizing the long-term costs of an unreliable grid. Shell Energy North America (US), L.P. supports PRM measures that do not impose additional burdens on ratepayers while maintaining reliability.
Last Week's New Comments +12
Overview
The California Public Utilities Commission (CPUC) proceeding R21-06-017 focuses on the modernization of California's electric grid with an emphasis on expanding Flexible Service Connections (FSCs). Various stakeholders, including environmental organizations, utilities, trade associations, and advocacy groups, have submitted comments addressing the implementation, standardization, cost-effectiveness, and technical requirements of FSCs to enhance grid...
capacity and support the integration of distributed energy resources (DERs).
Flexible Service Connections (FSCs) and Standardization
Environmental Defense Fund recommends standardizing FSCs across all utilities and offering options like flat, scheduled, and dynamic limits to maximize participation and effectiveness. CalCCA advocates for the rapid development of dynamic FSCs and ensuring equitable access for Community Choice Aggregators (CCAs) alongside Investor-Owned Utilities (IOUs). Vehicle-Grid Integration Council emphasizes the need for a standardized FSC framework, including customer agreements and capacity schedules, to support grid flexibility.
Utility Preparedness and Implementation
Environmental Defense Fund highlights the uneven preparedness of utilities, noting that while PG&E and SCE offer FSCs to some customers, SDG&E does not. San Diego Gas & Electric Company (SDG&E) proposes Flexible Service Connection Agreements (FSCAs) and emphasizes existing options under Rule 21, advocating for clear definitions and performance standards. Pacific Gas and Electric Company (PG&E) underscores the importance of flexible grid connections and operational flexibility under current regulations, presenting options like Load Limit Letters and Flex Connect Pilot programs.
Cost-Effectiveness and Economic Impact
Environmental Defense Fund points out that FSCs can reduce costs by deferring expensive grid upgrades and potentially lowering electricity rates. Vehicle-Grid Integration Council estimates that FSCs could save ratepayers over $23 billion in distribution upgrade costs by 2035. Cal Advocates/M.Miley/CPUC emphasize the need for a cost-benefit analysis to ensure DER services provide economic benefits that exceed their costs. SDG&E raises concerns about the cost-effectiveness of using ratepayer funds for compensation related to deferred upgrades.
Technical Requirements and Communication
Interstate Renewable Energy Council (IREC) discusses the need for system-level and equipment requirements, including cost-effective communication methods and cybersecurity measures. Pacific Gas and Electric Company (PG&E) highlights challenges with power control systems (PCS) certifications for flexible applications. San Diego Gas & Electric Company (SDG&E) emphasizes the necessity of advanced management systems like DERMS and ADMS for effective grid response and communication with PCS.
Policy Recommendations
Environmental Defense Fund recommends that the Commission mandate utilities to offer a range of FSC options and develop technical capabilities such as DERMS. Southern California Edison (SCE) suggests policy changes within interconnection and energization rules to better accommodate flexible connections. CalCCA calls for compensating customers who opt into firm FSCs and ensuring equal access to flexibility solutions for both IOUs and CCAs. The Clean Coalition advocates for streamlined interconnection processes and clear utility response deadlines to support DER integration.
Data Insights and Reporting
Environmental Defense Fund urges the Commission to require utilities to provide more detailed data on load factors and available capacity. The Clean Coalition highlights gaps in Interconnection Capacity Assessment (ICA) maps and calls for better utility accountability. IREC emphasizes the importance of accurate data and efficient sharing protocols to support the integration of DERs and flexible connections.
Integration of Distributed Energy Resources (DERs)
Environmental Defense Fund and several other commenters emphasize the role of DERs, including electric vehicles and solar generation, in promoting grid stability and efficiency. Southern California Edison (SCE) discusses the integration of advanced technologies like DERMS and smart inverters. The Clean Coalition and Vehicle-Grid Integration Council highlight the importance of integrating Solar Microgrids and enhancing EV charging infrastructure to optimize grid use and support California's electrification goals.
Compensation and Incentives
CalCCA and Vehicle-Grid Integration Council advocate for compensating customers and DER owners who provide operational flexibility. They stress the need for compensation structures that encourage participation in FSC programs. SDG&E highlights the challenges in incentivizing DER owners for real-time support and the necessity of clear compensation guidelines. Cal Advocates/M.Miley/CPUC recommend developing compensation mechanisms to ensure that FSC contracts contribute to system efficiency and cost containment.
Last Week's New Comments +18
Overview
This update provides a sampling of parties' positions on the California Public Utilities Commission's proceeding R24-01-018 regarding Flexible Service Connections (FSCs) and related grid management topics.
Flexible Service Connections (FSCs)
California Community Choice Association (CalCCA) advocates for the implementation of firm FSCs on all circuits to enhance grid capacity and reliability. Meanwhile, San Diego Gas & Electric Company (SDG&E) notes that it...
currently has no FSC pilots due to sufficient upstream distribution capacity but would consider interim partial energization arrangements if necessary. The Natural Resources Defense Council (NRDC) emphasizes that FSCs should expedite grid connections without replacing proactive grid planning.
Limited Load Profiles (LLPs) and Load Generation Profiles (LGPs)
Environmental Defense Fund (EDF) supports the adoption of LLPs with 24-value configurations to balance safety and reliability while increasing grid capacity. Vehicle-Grid Integration Council (VGIC) advocates for more granular LLPs to enhance customer import capabilities and recommends multiple optional schedule structures. Enphase Energy, Inc. suggests that LLPs should support at least 288 hourly values as per UL 3141 standards.
Competition and Data Sharing
California Community Choice Association (CalCCA) emphasizes the need for equitable competition between Investor-Owned Utilities (IOUs) and Community Choice Aggregators (CCAs), advocating for transparency and data-sharing to prevent bias towards IOU-centric options. The Clean Coalition highlights the importance of accurate data and efficient sharing protocols to maximize grid resilience.
DER Integration and Management Systems
California Community Choice Association (CalCCA) recommends the integration of Distributed Energy Resources (DERs) with FSCs to enhance grid services and operational flexibility. They also advocate for the deployment of DER Management Systems (DERMS) by CCAs. Enphase Energy, Inc. highlights the adequacy of Power Control Systems (PCS) for implementing static LLPs and suggests standards for managing DERs.
Compensation and Incentives
California Community Choice Association (CalCCA) recommends compensation for customers on unconstrained circuits who opt for firm FSCs and for DER owners providing non-firm import capacity. Vehicle-Grid Integration Council (VGIC) suggests a "shared savings" model to allow FSC customers to benefit from cost savings associated with deferred infrastructure upgrades.
Pilot Programs and Engineering Studies
Southern California Edison Company (SCE) discusses its Load Control Management System (LCMS) pilot, aimed at managing flexible loads and establishing PCS standards. Pacific Gas and Electric Company (PG&E) offers the Flex Connect pilot program with real-time grid condition-based limits. The Interstate Renewable Energy Council, Inc. (IREC) highlights the importance of pilot programs for enhancing grid flexibility and resilience.
Regulatory Framework and Compliance
San Diego Gas & Electric Company (SDG&E) suggests that the Commission consider approving pro-forma FSCAs or allowing utilities to seek approval for negotiated FSCAs. CAL ADVOCATES/FISHER/CPUC recommends that IOUs explore non-firm limits and conduct cost-benefit analyses for medium to long-term FSCs. Vehicle-Grid Integration Council (VGIC) emphasizes the need for the Commission to mandate utilities to utilize Load Integrated Capacity Analysis (Load ICA) for designing LLPs.
Capacity and Infrastructure Upgrades
California Community Choice Association (CalCCA) highlights the necessity of distribution system upgrades to meet increasing electrification demands. SEIA and CALSTART, Inc. advocate for proactive grid planning and detailed power availability assessments to prevent capacity constraints and delays in energization.
Timely Energization and EV Infrastructure
Alliance for Automotive Innovation stresses the importance of timely energization of EV charging infrastructure to boost consumer confidence and expand EV sales. Natural Resources Defense Council (NRDC) emphasizes that delays in energization hinder California's transportation electrification and decarbonization goals.
Transparency and Reporting
California Community Choice Association (CalCCA) calls for improved reporting and data-sharing to facilitate customer access to generation service options offered by CCAs. Environmental Defense Fund (EDF) and Vehicle-Grid Integration Council (VGIC) advocate for regular reporting from IOUs on FSC usage and grid connections to inform future developments and policies.
