changed. IREC claims that project financing will be affected. CALSEIA and Sunrun state that to design an inverter to not limit power production while providing reactive power support, a customer would have to increase the inverter size, incurring costs, or reduce the size of system. Stakeholders claim they should be compensated before approval of the transition. IREC suggests tariffs for grid services or reimbursements for energy production losses that exceed an established “reasonable limit.” CALSEIA recommends the Commission renew the scope of Rulemaking (R.) 14-10-003 to begin debate of market mechanisms to enable grid services. Sunrun proposes a pilot to study the effects of reactive power priority, the Volt Watt Mode function, and the Frequency Watt Mode function, which is part of the Phase 3 functions and are currently pending Commission approval in separate advice letters. Sunrun claims that the pilot would determine what is most effective at resolving grid issues while protecting customers that have invested in a DER. Sunrun also recommends that if the Commission does not reject the advice letters, it should exempt small systems (less than 10 kW) and non-exporting systems until the effects of the functions are better understood. REPLIES TO SDG&E responded to the protests on January 24, 2018. PG&E and SCE responded to the protests on January 25, 2018. II.A. The IOUs Respond that Discussions of Parties’ Positions Were Held in an Open Forum and the Advice Letter Process Is the Means for Seeking Commission Approval. All three IOUs state that discussions regarding the various parties’ positions were held in an open, public forum through the Smart Inverter Working Group and public workshops. The IOUs strongly object to Sunrun’s assertion that this Advice Letter process reflects a “closed-door discussions” between IOUs and Energy Division staff. The IOUs referred to the Staff Proposal issued by the Energy Division and the publicly posted informal comments on the Commission website that were received based on the proposal. The IOUs state that the SIWG has publicly discussed the reactive power priority setting for the Volt Var function in smart inverters for years.
changed. IREC claims that project financing will be affected. CALSEIA and Sunrun state that to design an inverter to not limit power production while providing reactive power support, a customer would have to increase the inverter size, incurring costs, or reduce the size of system. Stakeholders claim they should be compensated before approval of the transition. IREC suggests tariffs for grid services or reimbursements for energy production losses that exceed an established “reasonable limit.” CALSEIA recommends the Commission renew the scope of Rulemaking (R.) 14-10-003 to begin debate of market mechanisms to enable grid services. Sunrun proposes a pilot to study the effects of reactive power priority, the Volt Watt Mode function, and the Frequency Watt Mode function, which is part of the Phase 3 functions and are currently pending Commission approval in separate advice letters. Sunrun claims that the pilot would determine what is most effective at resolving grid issues while protecting customers that have invested in a DER. Sunrun also recommends that if the Commission does not reject the advice letters, it should exempt small systems (less than 10 kW) and non-exporting systems until the effects of the functions are better understood. REPLIES TO SDG&E responded to the protests on January 24, 2018. PG&E and SCE responded to the protests on January 25, 2018. II.A. The IOUs Respond that Discussions of Parties’ Positions Were Held in an Open Forum and the Advice Letter Process Is the Means for Seeking Commission Approval. All three IOUs state that discussions regarding the various parties’ positions were held in an open, public forum through the Smart Inverter Working Group and public workshops. The IOUs strongly object to Sunrun’s assertion that this Advice Letter process reflects a “closed-door discussions” between IOUs and Energy Division staff. The IOUs referred to the Staff Proposal issued by the Energy Division and the publicly posted informal comments on the Commission website that were received based on the proposal. The IOUs state that the SIWG has publicly discussed the reactive power priority setting for the Volt Var function in smart inverters for years.