Rule 21 Working Group 2 Issue 6 subgroup Conference call July 11, 2018 415-429-8160 Remote access: http://www.uberconference.com/gridworks/ https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Agenda Discussion of scoping memo and finalize meeting schedule Discussion: how does this translate to necessary forms and agreements? Discussion: What existing forms and agreement could serve as an example? (e.g., DER Provider forms and agreements?) Proposed homework: finalize definition of DER aggregator (offline) between interested parties (PG&E, SCE, Tesla, and others) https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Introductions and purpose R.17-07-007 considers refinements to the interconnection of DERs under Rule 21. The Scoping Memo directs Working Group 2 to develop proposals for Issues 8, 9, 10, 11, and 6. The Working Group is to submit a final report no later than Sept. 15, 2018. Issue 6: Should the Commission require the Utilities to develop forms and agreements to allow distributed energy resource aggregators to fulfill Rule 21 requirements related to smart inverters? If yes, what should be included in the forms and agreements? [added via February 14 Email Ruling] https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Scoping memo Comments received: Solar Edge Proposed schedule: July 11 (1-2pm) August 1 (11am – 12pm) August 21 (1-2pm) September 12 (1-2pm) October 3 (1-2pm) https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

California Smart Inverter Profile (CSIP) documents IEEE 2030.5 Implementation Guide for Smart Inverters: https://sunspec.org/wp- content/uploads/2018/04/CSIPImplementationGuidev2.103-15-2018.pdf CSIP Conformance Test Procedures: https://sunspec.org/wp- content/uploads/2018/05/SunSpecCSIPConformanceTestProceduresV1.0 .pdf https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

IEEE 2030.5 Common California IOU Rule 21 Implementation Guide for Smart Inverters https://sunspec.org/wp- content/uploads/2018/03/CSIPImplementationGuidev2.003-02-2018- 1.pdf “This implementation guide was a required outcome of Phase 2, which prescribed IEEE 2030.5 as the default protocol for Rule 21 smart Inverter communications. This guide, along with the IEEE 2030.5 specifications, is also intended to be used to develop an IEEE 2030.5 Client conformance test plan and certification program, which is required in California … it is important to note that while this guide intends to describe the full set of Rule 21 and IEEE DER Client requirements, much of the actual implementation details and requirements are expected to be derived from utility interconnection tariffs, Utility Handbooks, contracts, or other regulatory or pram-related vehicles.” https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

DER Aggregator - Definition Comments received: SCE, Tesla, Solar Edge From CSIP – on Aggregator Mediated Communications “In this scenario the utility communicate with an Aggregator back end management system rather than directly with individual DERs. The Aggregator is assumed to be managing a fleet of inverters that are distributed across the utility’s service territory, rather than having a single point of common coupling. The Aggregator is then responsible for relaying any requirements for DER operational changes or data requests to the affected systems and returning any required information to the utility. https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Next steps Next meting: August 1, 11am -12pm - Sunspec presentation Offline homework: Finalize definition of aggregator

Appendix https://gridworks.org/initiatives/rule-21-working-group-2/

Scoping Issue 6 From SCE informal comments Aggregator is discussed in 2 sections of Rule 21: Section 5Hh.5, communication requirements: (“The communications requirements herein shall be between (i) the Distribution Provider and the individual Generating Facility’s inverter control or energy management system; (ii) the Distribution Provider and communication to the Generating Facility through an aggregator not co-located or part of the Generating Facility or (iii) other communication options as mutually agreed to by Applicant and Distribution Provider.”). https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

https://gridworks.org/initiatives/rule-21-working-group-2/ Scoping Issue 6 From SCE informal comments Section Hh.5(b) (“Additional communication protocol requirements shall also apply to Generating Facilities utilizing inverter-based technologies as provided in the following documents: … i. Distribution Provider Generation Interconnection Handbook, which shall include: … C. Generic device communications registration management requirements, including how to register individual Generating Facilities, Generating Facilities with energy management systems, and aggregators (these requirements additionally or alternatively may be included in the application-level protocol implementation guide).”). Section Hh.6, Scheduling capability Requirements (“Scheduling capability requirements may be stored at an aggregator not co-located within the Generating Facility. The aggregator shall communicate the necessary commands to the Smart Inverter within 15 minutes of the aggregator receiving the scheduling information.”). https://gridworks.org/initiatives/rule-21-working-group-2/

Scoping Issue 6 Identify parameters governing the provision of aggregator services, including necessary forms and agreements - Communications function capabilities and requirements between 1) Generating Facility, 2) Aggregator, and 3) Distribution Provider Scheduling capabilities and requirements Dispatch command capabilities and requirements Other operational capabilities and requirements Other performance requirements Type of data needed, level of information needed Insurance requirements Cybersecurity protocols and requirements Compensation for service? Technologies in scope: inverter-based only? https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Scoping Issue 6 – out of scope? From SCE informal comments: “Aggregators performing Smart Inverter functionalities or other energy services or distribution services” https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Definition of DER Aggregator Tesla straw proposal: An aggregator is a non-utility entity that has the capability to monitor and communicate key data related to the state of inverters, pursuant Phase 3 requirements, both individually and in aggregate, to the utility. The aggregator also needs to be capable of receiving commands/schedules from the utility and delivering those commands/schedules to the inverters. https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Definition of DER Aggregator SCE straw proposal: An entity that provides the communication capability functions required in Section Hh on behalf of one or more Generating Facilities that utilize inverter-based technologies. An Aggregator is intended to perform a role that would otherwise be performed by individual Generating Facilities. The Aggregator shall act as a conduit, sending commands from the Distribution Provider to a Generating Facility and sending information from a Generating Facility to Distribution Provider. https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Definition of DER Aggregator SCE straw proposal (Cont). Rule 21, Section Hh.5 establishes the communication capability requirements for Generating Facilities with inverter-based technologies. This section provides that the communications may be between a Distribution Provider and an Aggregator, where the Aggregator will bear the responsibility of maintaining the direct communications with an individual Generating Facility. Rule 21, Sections Hh.6 and Hh.8 contain inverter function requirements that must be performed in response to communications made by the Distribution Provider. Rule 21, Section Hh.7 contains requirements relating to information that an inverter-based Generating must communicate to Distribution Provider. Per Section Hh.5, an Aggregator can offer the communication capabilities to transmit this information between the Distribution Provider and the Generating Facility. https://gridworks.org/initiatives/rule-21-working-group-2/ https://gridworks.org/initiatives/rule-21-working-group-2/

Schedule