In their response, SCE explains that energy storage systems exporting energy to the grid are subject to the terms of their interconnection agreements and that its proposed restrictions are meant to reflect jurisdictional requirements of these devices’ interconnection agreements. SDG&E clarifies that exports from behind-the-meter resources are not prohibited from participating; however, it should be in accordance with their interconnection agreements and all applicable rules. SDG&E also states that it will not compensate any excess power these resources export to the grid. We agree with Tesla and CESA. The Commission understands that there are current interconnection rules (i.e., Rule 21, WDAT) in place for resources that connect to the distribution system. However, the Commission is not aware of any specific prohibition against Rule 21 or WDAT resources from also providing distribution services. Section D.3 in Rule 21 establishes that interconnection under Rule 21 neither provides nor limits a producer’s right to utilize the utility’s distribution or transmission system for the “transmission, distribution, or wheeling of electric power. We reject Sunrun’s recommendation in its comments to the Draft Resolution E-4889 to delete Ordering Paragraph 18 which requires utilities to explain jurisdictional or other regulatory barriers for behind-the-meter solutions that export energy to the grid that would prevent the them from entering into a contract with. Sunrun explains that since the PRG is made up of Energy Division staff, ratepayer advocates, and utilities, it is very unlikely that someone present at the PRG would advocate for the fair treatment of resources. D.16-12-036 specifically created the PRG to allow for review of contracts following the solicitation process. The PRG which include Energy Division staff will review the Independent Evaluator’s summary and ensure that the utilities followed the elements adopted in D.16-12-036 and Resolution E-4889. Therefore, the Utilities should not categorically exclude or prohibit solutions that export energy to the grid from participating in the solicitation process. To the degree that these bids may be cost effective relative to other bids received, the Utilities should explain in the PRG meeting any jurisdictional or regulatory barriers that would prevent them from considering the contract. The Independent Evaluator should also include findings on the Utilities recommendations in its reports to the PRG.
In their response, SCE explains that energy storage systems exporting energy to the grid are subject to the terms of their interconnection agreements and that its proposed restrictions are meant to reflect jurisdictional requirements of these devices’ interconnection agreements. SDG&E clarifies that exports from behind-the-meter resources are not prohibited from participating; however, it should be in accordance with their interconnection agreements and all applicable rules. SDG&E also states that it will not compensate any excess power these resources export to the grid. We agree with Tesla and CESA. The Commission understands that there are current interconnection rules (i.e., Rule 21, WDAT) in place for resources that connect to the distribution system. However, the Commission is not aware of any specific prohibition against Rule 21 or WDAT resources from also providing distribution services. Section D.3 in Rule 21 establishes that interconnection under Rule 21 neither provides nor limits a producer’s right to utilize the utility’s distribution or transmission system for the “transmission, distribution, or wheeling of electric power. We reject Sunrun’s recommendation in its comments to the Draft Resolution E-4889 to delete Ordering Paragraph 18 which requires utilities to explain jurisdictional or other regulatory barriers for behind-the-meter solutions that export energy to the grid that would prevent the them from entering into a contract with. Sunrun explains that since the PRG is made up of Energy Division staff, ratepayer advocates, and utilities, it is very unlikely that someone present at the PRG would advocate for the fair treatment of resources. D.16-12-036 specifically created the PRG to allow for review of contracts following the solicitation process. The PRG which include Energy Division staff will review the Independent Evaluator’s summary and ensure that the utilities followed the elements adopted in D.16-12-036 and Resolution E-4889. Therefore, the Utilities should not categorically exclude or prohibit solutions that export energy to the grid from participating in the solicitation process. To the degree that these bids may be cost effective relative to other bids received, the Utilities should explain in the PRG meeting any jurisdictional or regulatory barriers that would prevent them from considering the contract. The Independent Evaluator should also include findings on the Utilities recommendations in its reports to the PRG.
201961781.docx