September has been a good news, bad news kind of month for California’s efforts to map every circuit of its major utility distribution grids.
The good news came at the start of the month, when California’s investor-owned utilities unveiled plans for the latest version of their integrated capacity analysis maps. The new ICA 2.0 maps, set to be unveiled this year, will see real-world, circuit-by-circuit, hour-by-hour data across the state’s distribution grids — including data that’s good enough to feed into DER interconnection processes now under development for the state’s Rule 21.
The bad news came a week later, when utilities Pacific Gas & Electric, Southern California Edison and San Diego Gas & Electric abruptly limited access to the ICA 1.0 maps, even to people who've been using them since they were launched in 2016. These groups have found themselves locked out of the maps, unless they’re able to get a motion from a California Public Utilities Commission administrative law judge, allowing them access under strict NDA, on a person-by-person basis.
The explanation? Utilities have failed to meet a CPUC deadline for creating plans for how to redact sensitive data from the maps — namely, certain data about critical infrastructure such as substations — and have chosen to deal with the lack of progress on the issue by shutting down access to the maps entirely.
This one-step-forward, two-steps-back activity on the ICA front underscores a long-running conflict about sharing the valuable and sensitive information that’s being pulled from the grid edge. This tension is apparent in other California proceedings, in New York’s Reforming the Energy Vision initiative, and in many other regulatory efforts to share distribution grid-level data with non-utility parties.
In simple terms, utilities say they’re legally obligated to take every necessary precaution to keep sensitive or private data from getting into the wrong hands. But DER project developers and environmental groups worry that utilities are using data security concerns to delay progress on work that could open up new roles for DERs as solutions to traditionally utility-controlled distribution investments and operations.
A drastic step: When in doubt, redact it all
Sahm White, policy and economic analysis director for the Clean Coalition, has been closely involved in stakeholder groups working on nitty-gritty details of the CPUC’s ICA 2.0 developments. So he was surprised last week to discover that he and his colleagues had been locked out of the PG&E, SCE and SDG&E ICA web portals that they’ve had access to for years, without warning.
Instead of the usual sign-in page at SCE’s Distribution Resource Plan External Portal, for example, he found a splash page that states, “To obtain access, a user must first submit a motion to the California Public Utilities Commission requesting access. If such a motion is granted, SCE will then require execution of a non-disclosure agreement. Once the NDA is executed, the user will be provided access.”
Clean Coalition already had an NDA to use SCE’s website, he noted. But needing a CPUC administrative law judge to approve a motion to regain access was a new requirement, one that his group hadn’t yet been able to meet as of this week.
He knows where it comes from: a July 24 ruling (PDF) from the CPUC administrative law judge in question, dealing with the utilities’ long-running motions seeking confidential treatment and redaction of distribution system planning data.
In that ruling, ALJ Robert Mason set rules for what PG&E, SCE and SDG&E could and could not redact from the maps, White explained. For example, it denied their request to redact “market-sensitive” data, finding that the utilities had failed to meet procedural requirements for defining what this term meant. Mason also ruled that utilities could take steps to protect individual customer energy usage data, by aggregating data from parts of the grid that only served a small number of customers.
But on the vital matter of how to redact information about critical grid infrastructure, the July 24 ruling is “a little more vague about what should be public, and what should be private,” White said. The problem here is that, in most cases, “most of the infrastructure is right out there in the open.” Big substations and transmission lines can be found on Google Maps, or by anyone driving down the highway, after all.
And if utilities chose to “black out” certain of these sites on their map, that could highlight, instead of hide, which infrastructure is deemed the most critical, actually giving more information to would-be bad actors than if no redaction efforts had happened, White said.
This conundrum was left unresolved by the order, White said. “The ALJ asked utilities for proposals on what they wanted to redact, and we and other parties weighed in on that.” The order set a Sept. 1 deadline for those proposals, but utilities did not meet it, White said. Instead, they asked the CPUC to set up a hearing to work out the remaining issues, which is now set for Sept. 26.
But importantly, the utilities “didn’t ask for a delay in the requirement to have these things redacted,” White said. Instead, they chose the broadest possible way to withhold any data under consideration for redaction — “They just denied access to the maps in their entirety.”
As for the new requirement that anyone seeking access to the maps apply for and receive a motion from ALJ Mason, that’s part of the July 24 ruling as well, he said. “The judge recognized that for some of the information that was being redacted, just because it’s sensitive doesn’t mean nobody should be able to see it,” he said. “There could be exceptional, reasonable reasons why they should be able to see it.”
But because utilities have apparently determined that even the ICA maps they’ve hosted online for years may be subject to these redacted data concerns, they’re now applying this process to everyone who wants to look at them, he said. “That’s clearly not what the ALJ intended. But this is what they did — which is hardly user-friendly.”
UPDATE: Southern California Edison responded to questions about the change in its DRPEP with the following statement: "Southern California Edison is not reducing access to the ICA maps, rather SCE is complying with the California Public Utilities Commission's requirement to protect its critical energy infrastructure information, something which we take very seriously. The additional procedural steps, including a motion at the CPUC and a non-disclosure agreement with the utility, were outlined by the CPUC. All stakeholders who have a legitimate reason to access the ICA information will be able to see the full set of enhanced maps and information after taking these two new CPUC required steps. SCE is also committed to working with the CPUC and other stakeholders to further refine the approach to designation and redaction of critical energy infrastructure information, while sharing other information publicly without the two new steps.
"We’re back to flying blind again"
Tim McDuffie, engineering director for California solar and energy services developer CalCom Energy, was also shocked to find that his company had been locked out of the utility ICA maps last week.
“It’s a huge detriment to us,” he said. While the ICA 1.0 maps have their limits, they are critically useful in guiding his company toward circuits that are largely free of the kind of interconnection constraints that can sink a project, he said.
CalCom does that by looking at the maps’ different color codes — red, orange, yellow and green — and finding the green areas, where there's "95 to 99 percent certainty that if you propose a project there, you won’t get hit with upgrade costs,” he said.
These upgrade costs can cripple solar projects over 1 megawatt in size, and not just because they have to be split between the developer and the utility, he said. More significant is the time it takes to get them done, which can stretch from months into years. “And if you’ve got a project that’s financed through a bank, they’re not going to wait years.”
“This kills projects all the time,” said McDuffie. In the five years he’s been working in solar development, the number of projects delayed due to upgrades has gone from 5 percent to 85 percent, he estimated. Using the ICA maps allowed CalCom to avoid these problems — “and now we can’t do that. We’re back to flying blind again.”
McDuffie, who serves on a CPUC working group dealing with ICA issues, said he’s frustrated by utilities using data security justifications for limiting access to the existing ICA maps. “They’re delaying real progress based on some paperwork that didn’t get filed for extension, or whatever. It’s completely unrelated to the intent of the ICA.”
White said that the Clean Coalition and other groups are working on resolving the lack of access to the ICA maps. First off, they've added the subject to the agenda of the Sept. 26 CPUC hearing on ICA issues, he said. The topic was inexplicably left off the utilities’ list of items for discussion, despite the clear importance it has to stakeholders in the process.
During a Tuesday phone conference to address the ICA map restrictions, “I proposed that we have an interim solution to go back to the pre-September 1 status until we work out the new data redaction standards, especially since we don’t yet have a physical security ruling,” White added. The response from utility attorneys on the call was “pleasant and open to discussion and hearing concerns, without making any commitments to anything."
Doug Karpa, Clean Coalition’s policy director, noted that the decision might also run counter to the CPUC’s intent in its order. “The initial utility proposals for redaction, the judge said those were over-inclusive,” he said. “There was an entire category of items that the judge’s order says should not be redacted,” but that has now effectively been redacted by the act of removing the maps.
Specifically, the order noted that its purpose is to create “uniform criteria for identifying data that should be classified as critical electrical infrastructure information for redaction purposes. It will be incumbent on each investor-owned utility to show that every data set it wishes to redact fits within the criteria” — a burden of proof that Clean Coalition believes has not been met by shutting off ICA access;
ICA 2.0: A major improvement
All of the conflict over access to the existing ICA 1.0 maps has clouded the real and significant progress that utilities have made on ICA 2.0, according to CalCom’s McDuffie. “There’s a vast, vast difference between the Renewable Auction Mechanism maps, which are essentially ICA 1.0, and what’s going to come out.”
The ICA 1.0 maps were created before utilities and regulators had settled on a common way to measure and estimate actual grid capacity at the circuit level, limiting their flexibility and usefulness, he said.
First of all, they use years-old data, which fails to account for anything that’s happened since then. Second, they use snapshots of total minimum and maximum load, which fails to capture the critical data on daily or seasonal peaks and valleys across different circuits.
Third, White added, none of the utility ICA methodologies yielded data that could be used for the actual interconnection process under California’s Rule 21. “It was based on modeling and assumptions, so they’re not always that accurate.”
But under the plans released on September 1, ICA 2.0 will solve all of these problems, White said. First, the new maps won’t be estimates, but “detailed power flow modeling that hits every circuit and every line section, and every node on the grid,” he said. For SCE, that adds up to about 600 nodes per feeder, or about 10 billion data points to track, he said.
Second, “we’re modeling 576 hours,” giving developers and utilities temporal data on local demand peaks, distributed generation peaks, and other critical factors that can influence hosting capacity.
Third, “we can process data at gigabyte rates now — and utilities agree now that they can update their model on a monthly basis,” making ICA 2.0 about as up to date as a developer could hope for. “Unless something has changed on the grid between the time it was published and the time you put in your interconnection request, you know the data there is the exact same data," said White.
All of these improvements mean, finally, that ICA 2.0 data should be usable in Rule 21 interconnection processes, which should add significant efficiencies to the process of applying for and receiving approval for new projects. Today, “it will cost you generally at least $50,000, and easily a couple hundred thousand dollars, if you’re talking about anything in the 1-megawatt size, to get to the point where you can file for interconnection,” he said. Adding ICA 2.0 data should make it “much more predictable, so that if you know the constrictions on the grid, you can design and site your system for any location to work within the existing grid constraints.”
White is a member of the CPUC working group tasked with coming up with the Rule 21 tariff changes needed to implement the ICA, which should take roughly a year to complete, he said. But “use of this by the utilities in interconnection won’t be held up by this delay. Utilities already have this data — they don’t need to wait.”