Over the past few months, we’ve been covering the controversy over how much data California utilities need to share in their distribution resource plans (DRPs) -- the regulatory framework that could open a multi-billion-dollar market for distributed energy resources to support the state’s grid.
July’s DRP filings by Pacific Gas & Electric, Southern California Edison and San Diego Gas & Electric opened up some important data to third parties and customers. But it also left a lot out -- and now groups ranging from fossil-fuel power plant owners to environmentalists are demanding that they cough it up.
In a first round of comments filed with the California Public Utilities Commission this week, groups including the Environmental Defense Fund, the California Energy Storage Alliance and the Independent Energy Producers have asked commissioners to push utilities to provide more data -- and thus open up more opportunities for competition -- in their DRPs.
Without some radical data-opening, these groups warned, utilities could end up contracting for, or even owning, the majority of investment into “non-traditional” assets like rooftopsolar behind-the-meter batteries, smart thermostats and plug-in electric vehicles that’s going to be required under the DRPs. These systems can stand in for traditional grid investments, like replacing transformers and upgrading circuits. But they can also destabilize the grid and increase costs in certain areas, utilities say.
Just where, when, and how much distributed energy resources are deployed, and how they are controlled, will have a huge effect on these kinds of calculations, which is why companies active in California’s distributed energy market, including SolarCity, Nest, Stem, Enphase and Advanced Microgrid Solutions, have been demanding more distribution grid data for years. Now that utilities have finally submitted their plans, we’ve got more specifics to argue over. Here are some highlights from this week’s filings.
Independent Energy Producers Association
Members of the Independent Energy Producers Association (IEP) “collectively own and operate approximately one-third of California installed generating capacity, which includes renewable products derived from biomass, geothermal, small hydro, solar, and wind, producers of highly efficient co-generation and owners/operators of gas-fired merchant facilities,” according to the group’s website -- with particularly heavy emphasis on the last part. The IEP represents the interests of California’s fossil-fuel generation industry, one whose interests can often conflict with those of renewable energy, battery and demand-response groups -- such as in the instance of the CPUC decision on SDG&E’s plans to replace the shuttered San Onofre nuclear power plant.
But the IEP’s comments indicate it shares concerns over lack of data from the utilities’ DRPs -- or in some cases, an open hostility toward sharing it. Of the three, PG&E’s approach is the best, the organization states:
Of the three large electric utilities, PG&E alone seems to embrace the intent of the Guidance to maximize access to data related to distribution resources. PG&E’s proposed policy includes “maximizing the amount of data available from the utility, customers and DER developers...without violating customer privacy or utility or third-party physical or cybersecurity. [...] To be sure, PG&E’s DRP does not provide much detail about how PG&E intends to accomplish these goals. But at least at a policy level, PG&E appears to take the position, consistent with the Guidance, that information relevant to the development and integration of DERs should be made available unless good reason is shown to withhold the data from the public. At the same time, PG&E acknowledges that concerns about grid security, customer privacy, and fair competition may require the aggregation or anonymizing of certain data.
In contrast, “the DRPs of SCE and SDG&E seem to focus on how to restrict the flow of information to interested members of the public,” it states. What’s more, they indicate that the utilities will demand that third parties enter into contracts before getting access to certain “sensitive” data -- a significant problem for attaining the kind of open data resource that the CPUC has written about. Here are some of IEP’s specific concerns, leveled at SCE’s call for a “Distribution Planning Review Group” to determine which data requires contracts and which doesn’t:
· What sort of "DERs performing grid functions" does SCE intend to acquire? How can acquisition of DERs be reconciled with President Picker’s vision of the utilities as technology- and operationally neutral electric distribution system operators (DSOs)? How can SCE function as a DSO and a "neutral marketplace coordinator" if it owns or is seeking to acquire some of the DERs?
· What sort of market-sensitive information does SCE think its distribution planning and analysis will produce? How does SCE think this information be used to manipulate the market? How does SCE define the market that is the focus of SCE’s concerns?
California Energy Storage Alliance
CESA represents companies involved in every aspect of energy storage, but unsurprisingly, it focuses a lot of its time on batteries. According to its comments, the DRPs are a “major advance in transparency for distribution system operators,” with such new features as the utilities’ circuit-by-circuit maps that indicate how much more DER capacity each holds.
But these maps don’t yet include the underlying data that goes into making them, CESA noted. They don’t necessarily come with expedited interconnection processes to make use of them, the group has stated. Finally, they don’t yet offer representations of “dynamic capacity” -- that is, how each circuit changes over time, whether over the course of 24 hours or 365 days.
CESA recommends the DRPs be upgraded to provide these new features:
1. Avenues to faster interconnection processes in areas with known available capacity, in conjunction with Rule 21 rules and enhancements
2. More durable information and data on distribution system challenges so that DER deployments can act on the information to provide and receive value, potentially for years into the future
3. A basis for customer decisions (e.g., demand-charge price signals and incentives) regarding how or whether to pursue on-premise DER solutions
4. Standard contracts, tariff designs or compensation mechanisms that facilitate plug-and-play DER applications and DER solutions that help resolve known and identified distribution system challenges outside of utility requests for offers
CESA also highlights that the DRPs are only one of several proceedings underway that are going to have a big impact on the value of storage, as we’ve been covering over the past year. One big one is the integrated demand-side resources (IDSR) proceeding launched last month by Commissioner Florio, which could set actual monetary values for the assets to be procured under the utilities’ DRPs. “IDSR pathways, valuations, and related rules should synchronize with and provide value to distribution system planning efforts directed through the DRPs,” CESA wrote.
Environmental Defense Fund
In its comments, this grid-involved environmental group doubles down on CESA’s requests for better integration of different state policies on distributed energy -- and warns that failing to open the data to inform this grand unified effort will shut out the natural growth of green technology in the market.
“EDF believes that the DRP pilots, in coordination with time-of-use and integrated demand-side resources demonstrations, ought to explore multiple utility business models,” the group wrote. But as it stands today, “the DRPs are preoccupied with the traditional compensation model, in which the IOUs dominate and control DER deployment.”
The first thing EDF wants to do is make sure that the utilities' DRP pilot projects won’t remain exclusively utility-owned or -controlled, as almost all of them are right now. “With the notable exception of the SDG&E New Utility Business Model demonstration, the proposed pilots are aligned with the Utility Command and Control model,” something the group worries “will result in a stilted approach to the elements of DRP planning (i.e., capacity analysis, locational net benefits analysis, data access, pricing/tariffs/contracts, and demonstrations).”
To fix this problem, “the Commission should direct DRP efforts to begin advancing new models and exploring transition strategies while learning by doing,” it writes, following up with a long list of policy suggestions that should be familiar to students of EDF’s concepts for an integrated grid.