California Distribution Resources Plan

California Distribution Resources Plan

Integrated Capacity Analysis Working Group

DRAFT Final Report – Due March 1, 2017

NOTE: This is a first draft of the ICA WG report. Comments in tracked changes can be sent to .

Table of Contents

Contents

Table of Contents

Acronyms

Executive Summary

Background

Scope and Organization of the Report

Discussion Topics, Points of Consensus, Proposed Alternatives if Any, Recommendations, Next Steps

Use Cases

ACR Requirements – ICA Modeling and Input Assumptions

Short-term activities of the ICA WG

Long-term refinement activities with potential for inclusion into initial ICA methodology

Next Steps for the ICA WG

Process for incorporation of long-term refinements

Appendix

Table of Contents...... 1

Acronyms...... 1

Executive Summary...... 1

Background...... 1

Scope and Organization of the Report...... 5

Discussion Topics, Points of Consensus, Proposed Alternatives if Any, Recommendations, Next Steps6

Use Cases...... 6

ACR Requirements – ICA Modeling and Input Assumptions...... 12

Short-term activities of the ICA WG...... 16

Long-term refinement activities with potential for inclusion into initial ICA methodology...... 25

Next Steps for the ICA WG...... 26

Appendix...... 28

Acronyms

TBD

Executive Summary

This is the Final Report of the Integrated Capacity Analysis Working Group to the California Public Utilities Commission. The Report summarizes the development of the Integrated Capacity Analysis to date and discusses timeline considerations for implementation across entire IOU service territories, recommendations on how to improve the methodology going forward and how the results may be used to inform decision-making on the part of the Commission, utilities, providers of distributed energy resources, and customers.

Background

Adopted in 2014, Section 769 of the California Public Utilities Code requires the IOUs to prepare a distribution resources plan which identifies optimal locations for the deployment of distributed energy resources. In August 2014, the California Public Utilities Commission (CPUC) began implementation of this requirement through Rulemaking (R.) 14-08-013, the Distribution Resources Plan (DRP) proceeding. A Ruling from the Assigned Commissioner in November 2014 introduced the Integration Capacity Analysis (ICA) as a tool which would support the determination of optimal locations by specifying how much capacity of integrated distributed energy resources may be available on the distribution network at the circuit level.[1] Pursuant Commission direction, California’s Investor Owned Utilities (IOUs) filed Applications[2] developing their Distribution Resource Plans, including a proposal to complete a Demonstration of their proposed ICA (“Demo A”). Stakeholder holder input on the IOU proposals was gathered, leading to further guidance issued in May 2016. That guidance authorized a demonstration project of the ICA, requiring the Investor Owned Utilities (IOUs) to meet the following nine functional requirements:

1. Quantify the Capability of the Distribution System to Host DER

2. Common Methodology Across All IOUs

3. Analyze Different Types of DERs

4. Line Section or Nodal Level on the Primary Distribution System

5. Thermal Ratings, Protection Limits, Power Quality (including Voltage), and Safety Standards

6. Publish the Results via Online Maps

7. Use Time Series Models

8. Avoid Heuristic approaches, where possible

9. Perform the complete ICA analysis for all feeders down to the line section or node on two Distribution Planning Areas (DPA).[3]

In addition to the ACR, the May 2016 ruling established the ICA Working Group (WG). The purpose of the WG is to monitor and provide consultation to the IOUs on the execution of Demonstration Project A and further refinements to ICA methodology. CPUC Energy Division staff has oversight responsibility of the working group, but it is currently managed by the utilities and interested stakeholders on an interim basis. The utilities jointly engaged More Than Smart, a 501(c)3 non-profit organization, to facilitate the WG. The Energy Division may at its discretion assume direct management of the working group or appoint a working group manager.

Between May 2016 and this Final WG Report, the WG met 16 times. Discussions focused on developing the ICA have been facilitated by MTS. The WG has benefitted from contributions by a large range of stakeholders. A complete list of contributing stakeholders is provided in Appendix A. The WG expects to continue its efforts through August 2017 as it begins to address long-term refinement items.

In December 2016, Pacific Gas & Electric (PG&E), Southern California Edison (SCE), and San Diego Gas and Electric (SDG&E) submitted their final Demo A reports, representing a substantial milestone for the WG. These reports summarize demonstration project results, lessons learned, and the IOUs’ recommendations on methodology calculation and feasibility of implementation of the ICA across the entire distribution system.

This Final Report contains the full Working Group’s recommendations for the ICA methodology and related actions coming out of stems from the IOU’s December filings. The , constituting the full Working Group’sWG offersrecommendations on the significant progress made to date, recommendations on how to improve the methodology going forward and how the results may be used to inform decision-making on the part of the Commission, utilities, providers of distributed energy resources, and customers. These include recommendations on the following three categories:

1. Uses of ICA: the WG identifies two primary use cases for the ICA. The first and most developed an immediate is for use of ICA to facilitate a significantly streamlined interconnection process. The second less developed use case is for , and an ongoing use of ICA within various system planning processes to identify when and where capacity upgrades are needed [BS1]on the distribution systeminterconnection of DERs may be constrained by hosting capacity limits, as a result of DER growth.. [SCS: there is no reason to limit this to changes as a result of DER growth, the ICA could be used for all sorts different types of changes] The WG report clearly outlines immediate, near and long term methodological refinements to enable the use of ICA within the interconnection process, and lays out considerations for the planning use case, with a goal of developing methodology recommendations for use within the planning context in the near-term (and in coordination with ongoing planning proceedings at the PUC).
2. Development of Common IOU methodology: the IOUs tested ICA under two separate methodologies, known as the “iterative” and the “streamlined” methodology, in Demo A. A majority of WG members recommend that the iterative methodology is used for interconnection purposes, with added refinements detailed further in this report. PG&E recommends a “blended” approach in using both methods for interconnection[4]. The streamlined methodology may provide value into the planning process, and will continue to be discussed as the WG further defines the uses of ICA in system planning.
3. Timeline: the WG recommends that the IOUs implement ICA across their entire service territory within 12 months of a PUC final decision on ICA methodology, [LW2]and include the identified recommendations from this report. Further, the WG recommends that the Commission establish two processes to incorporate modifications to the ICA:
4. As the WG continues to refine and enhance the ICA based on new studies and developed methods, it is requested that the Commission establish a process to allow the ICA WG to approve multiple enhancements to the methodology as they are developed in consultation with the WG during the long-term refinement process.
5. The WG makes the following refinements based on best available knowledge and in-depth discussions among a broad stakeholder group, though there are recommendations contingent upon costs and modeling software capabilities. It is requested that the Commission establish a process for the IOUs to consult with the PUC Energy Division if one or more IOUs determines that a methodology component (specific to the added refinements) cannot may not be included in the first system-wide rollout of ICA, due to these issuesissues not possible to predict at this time (i.e. those discovered during the rollout process). For those changes, the WG expects that IOUs will prioritize their resolution in the next [BS3]iteration of ICA.

The CPUC envisions that an approval of a final ICA methodology common across all utilities will be made in a Proposed Decision in early 2017.

[SCS: Re: below list Should this just be in an Appendix as noted above? Also, I think there needs to be a caveat added below since the vast majority of the organizations listed participated minimally, if at all. It doesn’t seem quite right to suggest that they all contributed or even were following what happened. I attempted something but I wasn’t quite sure how best to convey this.]

The “Working Group” references all active parties participating in ICA WG meetings, which include the IOUs, government representatives, DER developers, nonprofits, and independent advocates and consultants. The following stakeholder groups attended at least one meeting or webinar of the ICA WG, but there were only a handful of organizations that participated actively throughout and helped to draft this Final Report:

1

California Distribution Resources Plan

Integrated Capacity Analysis Working Group

DRAFT Final Report – Due March 1, 2017

NOTE: This is a first draft of the ICA WG report. Comments in tracked changes can be sent to .

-ABB Group

-Advanced Microgrid Solutions

-Alcantar & Kahl

-AMS

-Artwel Electric

-Bloom Energy

-CAISO

-California Energy Storage Alliance

-California Energy Commission

-California Public Utilities Commission

-CPUC Office of Ratepayer Advocates

-California Solar Energy Industries Association

-City of Burbank

-Clean Coalition

-Community Choice Partners

-Community Environmental Council (Community Renewable Solutions LLC representing)

-Comverge

-DNV GL

-ECCO International Inc.

-Energy and Environmental Economics

-Electric Power Research Institute

-Energy Foundation

-Environmental Defense Fund

-Gratisys Consulting

-Greenlining Institute

-Helman Analytics

-ICF International

-Independent Energy Producers Association

-Independent advocates

-Independent consultants

-Integral Analytics

-Interstate Renewable Energy Council

-Kevala Analytics

-Lawrence Berkeley National Laboratory

-Lawrence Livermore National Labs

-Natural Resources Defense Council

-Northern California Power Agency

-NextEra Energy

-New Energy Advisors

-Nexant

-Open Access Technology International

-Pacific Gas and Electric Company

-PSE Healthy Energy

-Quanta Technology

-Sacramento Municipal Utilities District

-San Diego Gas & Electric

-SEIASolar Energy Industries Association

-Shute, Mihaly & Weinberger LLP [SCS4]

-Siemens

-Smart Electric Power Alliance

-SoCal REN

-SolarCity

-Solar Retina

-Southern California Edison

-Stem Inc.

-Strategy Integration

-Sunrun

-SunPower

-The Utility Reform Network

-UC Berkeley

-Vote Solar

1

California Distribution Resources Plan

Integrated Capacity Analysis Working Group

DRAFT Final Report – Due March 1, 2017

NOTE: This is a first draft of the ICA WG report. Comments in tracked changes can be sent to .

The ICA WG met consistently to discuss proposed methodology for Demonstration A and review final Demo A reports. A full summary of WG documents including meeting agendas, presentation slides, and participant lists may be found in the Appendix.

Scope and Organization of the Report

All three IOUs submitted their Demo A reports at the end of December 2016 and the maps and downloadable data wereas made available in January and February of 2017. These reports lay out in detail the assumptions and calculations used within the ICA methodology. Additionally, the IOUs each separately made their own recommendations on which final methodological choicesmethodology(i.e., using a streamlined or iterative methodology) should be used going forward in a system-wide rollout of ICA. based on two identified use cases of ICA discussed by the WG (ICA is expected to be used to facilitate a streamlined interconnection process, and to provide useful input in guiding utility system planning efforts). These recommendations were are made to inform the CPUC in making a proposed decision on final ICA methodology. The WG took those recommendations into account but has reached different conclusions in some areas.

In order to provide the CPUC with useful recommendations while allowing the IOUs to continue implementation of the ICA, the WG is submitting this report now, but expects to file separate considerations indicating where cost effectiveness should be strongly considered by the Commission in deciding on a common methodology. A second filing will both give the IOUs the opportunity to summarize a general cost range for implementation of various methodological options, and allow the WG to consider additional whether different or addditional recommendations are necessary based upon the cost estimates provided.

The WG acknowledges that continued deliberation with regards to cost impacts and cost recovery will likely occur in a separate forum. It is also acknowledged that theencrouages the IOUs tocan continue to engage in some work related to the full system roll-out, such as data clean-up efforts, independent of a CPUC proposed decision.[LW5][BS6]

Further, the WG acknowledges there is a need to balance the incorporation of methodological changes and still implement the ICA on the entire distribution system in a timely manner. Further, there are several meaningful recommendations made in this report that were discussed among the WG, but not necessarily required to be tested as a part of Demo A. For these recommendations, the IOUs and stakeholders jointly engaged in discussion regarding the need for the changes and the practical feasibility of need and practical feasibility on whether the change should be incorporating themed in the initial system-wide rollout vs. , or to setting them it as a longer-term goals. For those identified for inclusion in the first system-wide rollout, the WG understands that IOUs may encounter unexpected issues in their implementation. To this end, the WG requests that the Commission establish a formal process whereby the utilities may submit a request to the PUC Energy Division regarding a change in methodology that is needed as a result of unforeseen circumstances, for further consideration. For those changes that cannot be resolved in the first rollout, the WG expects that IOUs will prioritize their resolution in the next iteration of ICA and work with stakeholders on any refinements that may be necessary as a result of new learning.

Similarly, the WG expects that additional work developing over the next six months on long-term refinements of the ICA (as specified under the ACR) will result in the development of additional methodology or refinements that may be included in either the first system rollout, or subsequent iterations of the ICA. [BS7]Given that the ICA is understood to improve over time, given incorporations of best efficiency practices and additional methodology, the WG requests that the Commission establish a process whereby improved iterations of the ICA may be incorporated through a WG approval process [SCS: Seems like the Commission might prefer that the Energy Division be the actual one “approving” anything?], [BS8]rather than through a formal request through the PUC. This gives IOUs flexibility to phase in additional ICA enhancements as they are developed through the long-term refinement process (e.g, fixed power factor functions) with expediency.

The ACR additionally specifies multiple items the WG should focus on to continue refining the ICA methodology. The WG filed an interim long-term refinement report in December 2016 detailing work to-date on those items, and sorting topics into a tiered system to develop a rough schedule for WG work in 2017. Since the filing of that report, the WG has identified additional long-term refinement items after reviewing the IOUs’ final Demo reports. Those items are included in an amended Table[5], and the WG will endeavor to prioritize this list at the beginning of its long-term refinement work. For the WG, “long-term refinement” details WG activity 6 months after the filing of this final report, beginning March 1, 2017 and ending August 31, 2017.

To this end, the WG agrees to identify consensus items where parties have built consensus, and identify specific parties places where there is non-consensus and alternative proposals have been made.

[SCS: Since our WG really only wrote recommendations principally on things that needed to be changed or refined from the Demo or where a choice was presented, we may want to clarify that WG silence on specific aspects of the methodology outlined in the final utility reports should be considered as support for, or at least non-opposition to, the utilities proceeding as they did in the Demo.]

Discussion Topics, Points of Consensus, Proposed Alternatives if Any, Recommendations, Next Steps

The sections below detail the further refinements to ICA methodology the WG recommends for incorporation. Where possible, recommendations are mapped to the specific section in the ACR.

The WG recommendations can be defined in three categories:

1. ICA Use cases of ICA
2. Standardization of methodology across IOUs
3. Short-term activities defined under ACR Section 3.1 for WG consultation

A high-level summary of recommendations for the interconnection use case, modified from the methodology tested in Demo A, is provided here: [SCS: ? is something supposed to be filled in here? or are you referring to the section below?]

Use Cases

At the beginning of the WG process, it was agreed that the WG should identify the specific uses of ICA and make recommendations on ICA methodology based on these concrete use cases, to the full extent possible. It is expected that methodological considerations, with regards to frequency of updates, hourly profiles, and other modeling options, may change based on the use of ICA.

Through multiple meetings, the following use cases were discussed:

1. Informing interconnection siting decisions and fFacilitating a significantly streamlined interconnection process

ICA results can be used to streamline the interconnection study process, decrease costs of interconnection, and improve project certainty by providing information to customers and third parties about the amount of DER capacity that can be interconnected at a specific location, and the specific factors (thermal, power quality, safety/reliability, protection) limiting hosting capacity at that location. It is expected that the development of ICA will coordinate closely with the separate Rule 21 proceeding. Thus, the WG proposes that an interconnection use case to be adopted by the Commission include the following considerations.Utilities also specifically point out a need to coordinate the application of ICA with regards to timing, configuration, and equipment. [LW9][BS10] [SCS: I am not sure I understand what is meant by the last sentence here]