ICA for Rule 21 Crawl – Walk – Jog – Run

Overview Issue 8 and 9 ask how the ICA can improve the Rule 21 interconnection process. Figure this out in Stages. WG job is to figure out what’s technically feasible and estimate benefits and costs of process changes in each Stage. Decision on whether changes are worth paying for is out of scope of this WG. CRAWL: Nameplate capacity of generator(s) compared to full-year ICA limit value (horizontal line at ICA minimum for the year) WALK: Stated output max compared to full-year ICA value. Applicant states max output that is lower than nameplate of generator(s) Speed Walk: PV Nameplate compared to fixed PV ICA values – may be a Detour with little benefit JOG: Stated output profile compared to ICA 576 values RUN: Stated output profile with option to curtail compared to ICA 576 values

Approach Above work through Run Stage is in scope for Issue 8 Pick a simple starting scenario that can be used across stages. Address variations only after the main scenario has been fully fleshed out. Example Scenario 1: Application for new installation of 1 MW PV system with 250 KW battery. Located on a circuit that was studied in the ICA. Document in detail how process steps will change with the use of the ICA. Include processes for publishing data online, pre-application activities, study process through PTO, and implications for ongoing grid operations Clearly note exceptions and branches of process for special situations. Document includes estimate of how many applicants could be affected by each change From documentation, estimate benefits and costs. 4 Types of Benefits all leading to ratepayer savings: Steps skipped; Steps sped up; Increased applicant certainty before application; Potential avoided overbuild Costs are measured in time and money for the utilities to change processes, implement technology, and ongoing operational costs Above work through Run Stage is in scope for Issue 8 Issue 9 is an overlay on each Stage, answering the question: “What contractual and technical requirements are necessary for utilities to be comfortable with the stated output in the application? (final note: after above, WG then examines additional changes for charging/demand increase direction)

WG Status: CRAWL Disagreements and proposals regarding FastTrack eligibility, Screens F & G, and Screen M show that WG is still in CRAWL stage. Simplistic Example: Application of ICA to Fast Track Eligibility (FTE) check Step # Step Name Who Data Execution FTE 1 Fast Track Eligibility Check Grid Contracts Generator Nameplate; Full-year ICA value at location If nameplate > ICA Value go to Detailed Study If nameplate < ICA Value go to Step ICA-Up1 ICA-Up1 Check ICA Value Freshness ? Date of last update for ICA Value If ICA updated < 10 days before application, ICA Value considered ”fresh”, go to Fast Track process; If ICA updated > 10 days before application, go to Step ICA-Up2 ICA-Up2 Update ICA Value Circuit Location Run ICA tool to get updated ICA Value for location; If Value has not changed or has increased, go to Fast Track process; If Value has decreased go to step ICA-Up3 ICA-Up3 Check Against New Value New ICA Value If nameplate > new ICA Value, notify applicant and go to Detailed Study If nameplate < new ICA Value, go to Fast Track Process

FTE Example: CRAWL Impact Benefits Costs How many applications will have nameplate lower than ICA? Benefits Steps Skipped: Where ICA is > 3 MW, more applicants will avoid detailed study However, utility staff is now adding steps to check and update ICA Value Steps sped up: None. Applicant Certainty: If published ICA value is fresher than 10 days, applicant has greater certainty that project with nameplate below ICA value will avoid detailed study Avoided overbuild: N/A Costs Additional software to update old ICA values as needed?

FTE Example: WALK Instead of using nameplate, use applicant’s stated max output Output Validation: Before FTE process, obtain assurance that generator will not exceed stated max output. WG Issue 9 Question: What is required for assurance? Is it enough to commit to a number in the Interconnection Agreement? Process Change: Same as FTE process in CRAWL scenario, except replace “nameplate capacity” with “Stated max output” Impact: How many more applications will be FT eligible by using max output instead of nameplate? Benefits: Same as in CRAWL scenario – could work for more applications Costs: Same as in CRAWL scenario unless there are extra tools, steps needed to validate stated max output Speed Walk: Unclear how PV-ICA values would work here. Only if applicant has the same tilt and orientation as PV-ICA assumptions? Process steps need to be detailed

FTE Example: JOG Now using submitted output profile and 576 ICA Values Step # Step Name Who Data Execution PrValid Profile Validation ? Submitted output profile TBD: process for validating commitment to submitted output profile FTE 1 Fast Track Eligibility Check 576 ICA values If any output number > that hour’s ICA Value go to Detailed Study If all output numbers < corresponding ICA Value go to Step ICA-Up1 ICA-Up1 Check ICA Value Freshness Date of last update for ICA Values If ICA updated < 10 days before application, ICA Values considered ”fresh”, go to Fast Track process; If ICA updated > 10 days before application, go to Step ICA-Up2 ICA-Up2 Update ICA Value Circuit Location Run ICA tool to get updated ICA Values for location; If Values not changed or have increased, go to Fast Track process; If Values have decreased go to step ICA-Up3 ICA-Up3 Check Against New Value New ICA Values If any output number > that hour’s new ICA Value go to Detailed Study If all output numbers < corresponding new ICA Value go to Step ICA-Up1

FTE Example: JOG Impact Benefits Costs How many more applications will qualify for Fast Track relative to WALK scenario? Benefits Steps Skipped: Where output profile always below ICA, applicant will avoid detailed study Steps sped up: None. However, utility staff now does 576 comparisons instead of 1 comparison Applicant Certainty: If published ICA values are fresher than 10 days, applicant has greater certainty that project operational profile below ICA values will avoid detailed study Avoided overbuild: N/A Costs Relative to WALK scenario, staff needs tool to do 576 comparisons