1. Responses and Suggestions for Distributed Resource Plans Sky C. Stanfield September 17, 2014 CPUC Workshop – R.14-08-013 1

2. About IREC For 30 years the Interstate Renewable Energy Council, Inc. (IREC) has been known for connecting people, ideas and technology to produce measurable results in the renewable energy field. IREC’s programs and policies lead to: easier, more affordable connection to the utility grid; fair credit for renewable energy produced; best practices for states, municipalities, utilities, and industry; and quality assessment and credentialing for trainers of our growing clean energy workforce. 2

3. Changing the Paradigm Traditionally distribution planning = load- centric In most cases circuits have not been upgraded to respond to DG or other DER except in response to an individual interconnection application or when they alter load patterns Utilities lack the technology to enable easy visibility into their systems to enable proactive planning Wires-based solutions are the norm, some consideration of alternatives but no evidence of a consistent practice. –Possibly due to economic incentives. 3

4. Re-Envisioning the Distribution System Safe, Reliable and Resilient Low-Cost Operation paired with High-Value Service Improved Customer Choice and Control Integration of High Levels of Renewable Energy Utilization of New Technologies to Expand Functionality 4

5. Foundations for Effective DRPs Specific DER Integration Goals and Metrics Clear and Consistent Methodology for Evaluating Cost and Benefits Multi-Level Data Transparency to Enable Achievement of Goals Procurement Mechanisms to Encourage Innovation, Lower Costs and Use Optimal Locations Identification of Interconnection Process and Cost Allocation Changes 5

6. Determining Optimal Locations Optimal for what? –Available capacity or opportunity to serve load without triggering significant upgrades –Opportunity to address reliability, avoid capacity upgrades, etc. through use of DER Forecast/Plan for anticipated load and generation growth Maintain right for customers to manage their loads through full range of DER 6

7. Integrated Distribution Planning (IDP) Proactive planning approach, not reactive based purely upon interconnection applications Through advanced identification of the hosting capacity of lines/substations –IDP can identify optimal locations (of both types) –Inform the processing of subsequent interconnection applications –Give the utility advanced noticed of upgrades likely to be required to maintain safety, reliability and power quality Identify opportunities for variety of DER applications This could be done in conjunction with investment in better system mapping technology 7

8. 8 1 2 3 4 5 The 5 Steps of IDP

9. From Optimal to Actual What is needed to direct DER to those locations? –Data Sharing (maps or other methods) –Procurement vehicles (adders, other markets?) –Simplified interconnection process Process should be created to enable utilities to proactively upgrade circuits to accommodate additional DER How will costs and benefits be evaluated in this context? 9

10. 10 For more, see the full paper: Integrated Distribution Planning: A Proactive Approach for Accommodating High Penetrations of Distributed Generation Resources, by Tim Lindl and Kevin Fox, IREC; Abraham Ellis and Robert Broderick, Sandia National Lab Available at: http://www.irecusa.org/wp- content/uploads/2013/05/Integrated-Distribution-Planning-May- 2013.pdfhttp://www.irecusa.org/wp- content/uploads/2013/05/Integrated-Distribution-Planning-May- 2013.pdf Sky Stanfield Keyes, Fox & Wiedman LLP (510) 314-8204 sstanfield@kfwlaw.com