first working group meeting. pg. 22. Pleadings We agree, however, with PG&E’s suggestion that the Commission should establish a working group to further consider these complex issues. [Reply Comments, 6/30, pg. 3.] GPI agrees with an approach that provides more opportunities for dialogue and consideration of various proposals. It is important to create prudent and workable rules and better to it even if it requires “do right,” some additional delay, than to rush rules to completion. [Reply Comments, 6/30, pg. 8.] The PD describes a number of ongoing policy issues to be delegated to a working group that has already been established. GPI supports this decision, as we did in reply comments (p. 3) on the staff proposal. [Comments on PD, 11/28, pg. 5.] 3. Station Power Related Decision Verified Issues. Second, storage companies that The GPI has consistently develop behind-the-meter projects – supported the development of Stem, AMS and Tesla all stated in – rules for energy storage comments on the Report that projects of all varieties that permitting a non-exporting storage are simple and device to charge at wholesale is either understandable, and that not desirable or not a priority issue at contribute to grid stability. this time. GPI also took this position With respect to MUAs, we in comments. Given both, we decline argued for rules for station to further pursue this matter, but may power that are consistent with do so in the future, as and if single-use storage systems, appropriate. [D.18-01-003, pg. 24.] and with other market Pleadings participants that utilize similar First, we note that this hypothetical is services. We also pointed out extremely unlikely. The question asks: that the concern that storage how do you prevent a customer's units would pump energy into
first working group meeting. pg. 22. Pleadings We agree, however, with PG&E’s suggestion that the Commission should establish a working group to further consider these complex issues. [Reply Comments, 6/30, pg. 3.] GPI agrees with an approach that provides more opportunities for dialogue and consideration of various proposals. It is important to create prudent and workable rules and better to “do it right,” even if it requires some additional delay, than to rush rules to completion. [Reply Comments, 6/30, pg. 8.] The PD describes a number of ongoing policy issues to be delegated to a working group that has already been established. GPI supports this decision, as we did in reply comments (p. 3) on the staff proposal. [Comments on PD, 11/28, pg. 5.] 3. Station Power Related Issues. The GPI has consistently supported the development of rules for energy storage projects of all varieties that are simple and understandable, and that contribute to grid stability. With respect to MUAs, we argued for rules for station power that are consistent with single-use storage systems, and with other market participants that utilize similar services. We also pointed out that the concern that storage units would pump energy into Decision Second, storage companies that develop behind-the-meter projects – Stem, AMS and Tesla – all stated in comments on the Report that permitting a non-exporting storage device to charge at wholesale is either not desirable or not a priority issue at this time. GPI also took this position in comments. Given both, we decline to further pursue this matter, but may do so in the future, as and if appropriate. [D.18-01-003, pg. 24.] Pleadings First, we note that this hypothetical is extremely unlikely. The question asks: how do you prevent a customer's Verified
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