expressing concern that customer domain facilitates this goal, transferring megawatts in and the IOUs should be permitted the out of the customer grid flexibility to do so. Each of the IOU domain would reduce energy recommends allowing shifting of storage procurement in other megawatts into and out of the customer areas, thereby undermining the grid domain and allowing all of energy storage procurement customer-connected storage to count targets. Sierra Club urged the toward the storage targets. We find this Commission to avoid proposal reasonable, if combined with undercutting the important role the and ‘floor’ ‘ceiling’ limits … served by customer grid Specifically, so that customer domain domain, and to protect its targets are not significantly undercut by ability to enhance the a single transmission or distribution integration of rooftop project, we establish a minimum floor of photovoltaic technologies (See 100% deployment in the customer Sierra Club Comments on domain (i.e., T&D systems may not be Track 1 Issues at 9, July 8, used to fulfill the minimum customer 2015.) In addition, Sierra Club domain (D. 16-01-032 at 32.) targets).” explained that because storage powered by “[e]nergy renewables on the customer provide[s] electricity to side … customers during the most expensive period, during peak it plays an important hours …” role in addressing concerns related to the “duck curve”; and that electricity “since storage located in the customer domain does not need to move through the transmission system, this electricity does not incur additional transmission (See id.) line losses.” Finally, while “[e]nergy storage devices sited in the customer domain will also have a lower GHG emissions factor compared to one sited at a transmission-level domain,” because there are “existing incentives for customer storage to be deployed, the procurement allocation should remain the (Id. at 9.) same.”
expressing concern that transferring megawatts in and out of the customer grid domain would reduce energy storage procurement in other areas, thereby undermining the energy storage procurement targets. Sierra Club urged the Commission to avoid undercutting the important role served by customer grid domain, and to protect its ability to enhance the integration of rooftop photovoltaic technologies (See Sierra Club Comments on Track 1 Issues at 9, July 8, 2015.) In addition, Sierra Club explained that because “[e]nergy storage powered by renewables on the customer side … provide[s] electricity to customers during the most expensive period, during peak hours …” it plays an important role in addressing concerns related to the “duck curve”; and that “since electricity storage located in the customer domain does not need to move through the transmission system, this electricity does not incur additional transmission line losses.” (See id.) Finally, while “[e]nergy storage devices sited in the customer domain will also have a lower GHG emissions factor compared to one sited at a transmission-level domain,” because there are “existing incentives for customer storage to be deployed, the procurement allocation should remain the same.” (Id. at 9.) customer domain facilitates this goal, the IOUs should be permitted the flexibility to do so. Each of the IOU recommends allowing shifting of megawatts into and out of the customer grid domain and allowing all of customer-connected storage to count toward the storage targets. We find this proposal reasonable, if combined with the ‘floor’ and ‘ceiling’ limits … Specifically, so that customer domain targets are not significantly undercut by a single transmission or distribution project, we establish a minimum floor of 100% deployment in the customer domain (i.e., T&D systems may not be used to fulfill the minimum customer domain targets).” (D. 16-01-032 at 32.)
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