Limited Generation Profiling A plan to Take full advantage of the Integration Capacity Analysis Tim Mc Duffie PE Director of Engineering – CalCom Energy Chairman – CALSSA Smartgrid Committee

This is NOT DERMS DERMS will happen, and it will solve a lot of problems, but not as part of this working group. The proposed solution is the compromise position as defined by Heather Sanders in her presentation to WG2 on May 30th 2018. This was deemed in scope by the Commission as part of Issue #9.

Lowest Common Denominator Approach The current engineering review process, including the ICA, runs a distribution system model through an iterative process that simulates worst case grid scenarios. The very bottom of the curve is then used to define hosting capacity for the entire node.

Lowest Common Denominator Approach

Issue #9 States Proposed Approach In reality, hosting capacity changes dramatically over the course of any period of time. Using the results of the ICA, we propose a system of conditional operation during predefined periods that allows generation customers to take advantage of periods of expanded hosting capacity. Issue #9 States “What conditions of operations should the Commission adopt in interconnection applications and agreements to allow distributed energy resources to perform within existing hosting capacity constraints and avoid triggering upgrades?”

Proposed Approach (Assumes 4.2MW-AC System)

How would this work? Many of the mechanisms needed are in place on current non-export systems. Generator Data Acquisition System would be installed with pre-loaded generation profiles that prevent over-generation during pre- defined low periods of hosting capacity. Inverter production would be curtailed during specific, pre-defined, time intervals. Installer would submit 288hr. programming profile to IOU for approval with interconnection application. Interconnection Agreement and Permission to Operate documents will articulate that operation is conditional based on pre-defined operating parameters.

Fits the Remit of Issue #9 Precisely How would this work? Failure to follow Interconnection Agreement would result in punitive measures for the generation customer. Similar to if they installed more generation without approval after PTO Larger Systems could be fitted with a similarly programmed reverse power relay that acts as a backup to the system curtailment mechanism. Fits the Remit of Issue #9 Precisely “What conditions of operations should the Commission adopt in interconnection applications and agreements to allow distributed energy resources to perform within existing hosting capacity constraints and avoid triggering upgrades?” Proposed Solution utilizes both conditional operation and generator agreements to ensure systems operate within ICA defined boundaries, thereby avoiding upgrades in most circumstances.