Distribution Resources Plans (DRP)

Background

Welcome to the Public Advocates Office portal on the Distribution Resources Plans (DRP). Here you can find links to the many aspects of the DRP, including the Rulemaking, the CPUC's Guidance document, Utility proposed plans, and the various tracks related to implementing the DRP pilots. From these pages you can also reach the CPUC's docket, which contains all filings on the record in the proceeding.


In August 2014, the CPUC issued an Order Instituting Rulemaking to set policies that would guide the utilities in their development of Distribution Resources Plans (DRP), pursuant to Assembly Bill 327 (PU Code 769). The DRP proceeding is examining and modifying utility investments in the operation of the electric distribution grid necessary to accommodate and leverage ratepayer and customer investments in distributed energy resources (DERs) such as rooftop solar, battery energy storage, electric vehicles, demand response, and energy efficiency. The DRP proceeding also considers the impacts a lower carbon energy portfolio will have on grid operations as well as how the distribution grid can be managed to best accommodate future zero-carbon energy technologies. In an associated proceeding, the Integrated Distributed Energy Resources (IDER) proceeding, the CPUC is also examining ways to deploy distributed energy resources that provide optimal customer and grid benefits, while enabling California to reach its climate objectives. The Rule 21 proceeding is relevant to both the DRP and IDER proceedings, and is looking at efficient and cost-effective ways to interconnect DERs to the electric distribution grid. These three proceedings will work together to encourage DERs to be developed and interconnected onto the distribution system.

This page summarizes the DRP proceeding, provides links to key Commission documents, and provides links to the Public Advocates Office's official filings in the proceeding.

 

CPUC Guidance for Distribution Resources Plans
On February 6, 2015, the CPUC issued a Guidance for the utilities to use in the development their DRPs. The Guidance sets forth a new framework for distribution planning necessary to mitigate greenhouse gas emissions and enable mass adoption of DERs.

 

UtilityProposed Distribution Resources Plans
On July 1, 2015, the utilities submitted applications requesting CPUC approval of their DRPs. Each utility’s application can be found here:


On January 27, 2016, the Assigned Commissioner and Administrative Law Judge issued a Ruling that set out the scope of issues to be addressed in the DRP. The DRP issues are addressed through three concurrent proceeding tracks. Follow the links below to learn more about the different proceeding tracks and the Public Advocates Office’s positions on DRP.

 

On January 24, 2018, the Assigned Commissioner and Administrative Law Judge jointly issued an Amended Scoping Ruling that identified what would be addressed during the remainder of the proceeding.

Track 1: Methodology

This track addresses the development of analyses related to estimating the grid impacts of DERs, specifically the Integration Capacity Analysis (ICA) and the Locational Net Benefits Analysis (LNBA). The ICA helps determine the capacity of the existing distribution grid to accommodate interconnection of additional DERs while the LNBA helps identify locations where additional DERs can provide the most benefit to customers and utilities.

 

Track 2: Demonstration and Pilot Projects
This track addresses the design of demonstration and pilot projects related to Locational Benefits, Distribution Operations, and High Penetration of DERs.

Track 3: Policy Issues
This track addresses numerous policy issues raised by stakeholders in the DRP proceeding.


Energy Division Staff Roadmap Proposal
In November 2015, Energy Division issued a Proposal which sets forth a roadmap for the implementation of DRP pilot programs and analyses.

 

CPUC Proceeding Docket

See the Proceeding docket.

 
Visit the docket to subscribe to proceeding updates.


Other Resources

CPUC Distribution Resources Plan webpage.
Public Advocates Office Energy Efficiency webpage.
Public Advocates Office Energy Storage webpage.
Public Advocates Office Alternative-Fueled Vehicles webpage.
Public Advocates Office Demand Response webpage.

  

Distribution Resources Plans: Track 1 - Methodological Issues Development of Hosting Capacity and Locational Cost-Effectiveness Methods and Tools

Background

 

The purpose of Track 1 is to develop methodologies that will accurately estimate and value the location-specific costs and benefits of deploying Distributed Energy Resources (DER) portfolios. DERs consist of a variety of small, decentralized grid-connected technologies. DERs include Rooftop Solar,  Energy Storage, Electric Vehicles, Demand Response, and Energy Efficiency.

 

On January 27, 2016, the CPUC issued a Scoping Ruling setting a roadmap for the implementation of utility Distribution Resources Plan (DRP) demonstration and pilot projects. The utilities submitted their DRP Proposals in July 2015.

 

The CPUC created 3 concurrent Tracks to separately address issues related to hosting capacity and locational cost-effectiveness methodologies, demonstration and pilot projects, and DER deployment and distribution system planning policy.

 

Track 1 is focusing on the development of the hosting capacity and locational cost-effectiveness methodologies:   

 

  • Integration Capacity Analysis (ICA) - determines the available circuit level capacity for additional DERs.    
  • Locational Net Benefits Analysis (LNBA) - values the costs and benefits of DER integration at different locations on the distribution grid.

Track 1 also authorized computer simulation demonstration projects, related to improving these methodologies:

  • Dynamic Integration Capacity Analysis (Demonstration Project A)   
  • Optimal Location Benefits Analysis Methodology (Demonstration Project B)

 

Public Advocates Office Position

Public Advocates Office supports the state’s goals to move the utilities to fully integrate DERs into utility distribution system planning, operations, and investments in order to leverage customer investments in DERs and optimize ratepayers' investment in smart grid technologies to help achieve the state’s climate change goals and grid management benefits.


Public Advocates Office recommends:

 

  • Integration Capacity Analysis (ICA): The CPUC should adopt a methodology that promotes increased transparency and uniformity across utilities. The utilities should submit detailed methodologies to the CPUC and stakeholders prior to commencing the computer simulation model (Demonstration Project A). This Demonstration Project should develop reference circuits for comparative analysis.
  • Locational Net Benefits Analysis (LNBA): The LNBA should consist of a comprehensive quantification of DER value and net-benefits at any location on the distribution grid for use in sourcing mechanisms and cost-effectiveness evaluations to help determine where DERs can be most cost effectively deployed on the distribution grid. The LNBA should continue to be refined over time to use new data and adapt to new uses.

 

ICA and LNBA Workshops

On November 10, 2015 the Commission held a workshop on the ICA and Demonstration Project A. On February 1, 2016 the Commission held a workshop on the LNBA and Demonstration Project B.

 

Workshop details can be found on the CPUC’s website.  

 

CPUC Rulings on Track 1 Methodologies

On February 18, 2016, the CPUC issued a Ruling requesting stakeholders’ comments on ICA and LNBA methodologies, on ICA and LNBA workshops, and on demonstration projects A and B.

On April 29, 2016, the CPUC issued a Ruling requesting stakeholders’ responses to questions regarding the collection, management, and sharing of data relevant to the DRP. The questions were applicable to the DRP proceeding as a whole but had special relevance to the ICA and LNBA.


  • See Public Advocates Office’s comments on the April 29 ruling.

On April 19, 2017, the CPUC issued two rulings regarding ICA and LNBA. One Ruling requested comments on the ICA and LNBA final short-term working group reports. The second Ruling requested comments on the long-term refinement process for ICA and LNBA.

 


On June 7, 2017, the CPUC issued a Ruling setting the scope and schedule for continued long-term refinement of the ICA and LNBA.

 

On December 5, 2017, PG&E, SCE, and SDG&E filed their LNBA cost effectiveness use case proposals.

 

On January 9, 2018, the utilities filed the Locational Net Benefit Analysis Long Term Refinements Final Report.

 

On March 12, 2018 the utilities filed the Integration Capacity Analysis Working Group Long Term Refinements Final Report.


On March 29, 2018, the Assigned Commissioner and Administrative Law Judge jointly issued a Ruling soliciting comments on the LNBA Working Group Long-Term Refinement Final Report and the utilities’ LNBA cost effectiveness use case proposals. 

  • See Public Advocates Office’s comments on the ruling soliciting comments on the LNBA Working Group Long-Term Refinement Final Report and the utilities’ LNBA cost effectiveness use case proposals.

 

CPUC Decision on Track 1 ICA and LNBA

On August 25, 2017, the CPUC issued a Proposed Decision on the ICA and LNBA. The Proposed Decision adopts use cases for ICA and LNMA, adopts a methodology for ICA, orders the IOUs to propose a methodological approach for calculating the LNBA at the Distribution Planning Level, and sets a regulatory schedule for the IOUs to implement the ICA and LNBA. Public Advocates Office supported the Proposed Decision with minor modifications.

The CPUC voted out a final Decision (Decision 17-09-026) on September 28, 2017.

 

Next Steps for Track 1 ICA and LNBA

The Public Advocates Office is engaged in the following ongoing policy and analytical issues related to DRP Track 1 ICA and LNBA:

 

  • Commission is expecting to issue a proposed decision on ICA and LNBA long-term refinements, specifically for using ICA for planning distribution system modernization and DER deployment strategies and using LNBA for calculating system wide transmission and distribution avoided costs for DERs. 
  • The ICA is being discussed within the Rule 21 workinggroups and proceeding for use in the interconnection process.  A final working group report will be issued on Oct 31.
  • Energy Division Integrated Resource Procurement Planning (IRP) staff and the IOUs have proposed using LNBA distribution avoided cost estimates to refine the IRP procurement models beginning in 2019-2020.
  • In August 2018, the CPUC Executive Director granted the IOUs an extension to December 31, 2018 to make the ICA system-wide data available on publicly accessible maps, pending resolution of data confidentiality and security issues.

CPUC Proceeding Docket

See the CPUC Proceeding docket. 

Visit the docket to subscribe to proceeding updates. 

 

Other Resources

 

Public Advocates Office's DRP Portal

Public Advocates Office DRP Track 2 Webpage

Public Advocates Office DRP Track 3 Webpage

 

Distribution Resources Plans: Track 3 - Policy Issues


Background

 

On January 27, 2016, the CPUC issued a Scoping Ruling setting a roadmap for the implementation of utility Distribution Resources Plan (DRP) demonstration and pilot projects. The Scoping Ruling creates 3 concurrent Tracks to separately address issues of methodology, implementation, and policy.

 

The purpose of Track 3 is to address policy issues raised by proceeding stakeholders related to implementation of the utilities’ Distribution Resources Plans (DRP).

The policy issues raised by proceeding stakeholders include the following:

 

  • Clarifying definition and terminology;
  • Addressing ownership and competition;
  • Barriers to deployment;
  • Grid modernization investment and deferral;
  • Dispatch control;
  • The role of Community Choice Aggregators and Electric Service Providers;
  • Utility role and business models;
  • Coordination with other state agencies, related to climate issues;
  • Coordination with other CPUC proceedings;
  • Maximizing ratepayer benefits and value;
  • Barriers to DER deployment;
  • Disadvantaged communities;
  • Safety Standards;
  • Access to data and confidentiality;
  • Accounting for DER GHG reduction benefits;
  • Load forecasting and DER growth scenarios;
  • DER portfolio optimization;
  • Frequency for updating distribution resource plans;
  • Relationships to the IOUs’ general rate cases (GRCs); and
  • Integration of DRPs into utility distribution infrastructure planning.

 

Public Advocates Office Position on DRP Policy Issues

Public Advocates Office supports the state’s goals to move the utilities to fully integrate Distributed Energy Resources (DERs) into utility distribution system planning, operations, and investment in order to leverage customer investments in DERs and optimize ratepayers' investment in smart grid technologies to help achieve the state’s climate change goals and grid management benefits.

Public Advocates Office’s key recommendations for Track 3 policy issues are below:

 

  • Grid modernization and General Rate Case (GRC) coordination issues should be resolved in a timely manner.
  • Research, development, and demonstration (RD&D) projects related to distribution grid modernization should be leveraged before grid modernization investments are approved by the Commission.
  • The utilities should file a Grid Needs Assessment (GNA) on an annual basis that includes an inventory of distribution grid needs and proposed distribution grid investments to meet those needs.
  • The GNAs should include a complete catalog of all substations, circuits, and distribution upgrade projects currently covered by the utilities’ Distribution Planning Process.
  • The utilities should submit a Grid Modernization Plan (GMP) requesting a final budget authorization for distribution grid modernization investments as a volume of their General Rate Case (GRC) Transmission and Distribution testimony.
  • Distribution grid modernization investments intended to maximize the benefits of policy driven DERs should be evaluated using a comprehensive benefit-cost methodology.
  • The Commission should continue to evaluate load and DER forecasting methodologies with the goal of making annual improvements.
  • The Commission should explore alternatives for developing distribution circuit level net load forecasts, as well as disaggregation data and methods to facilitate more accurate disaggregation of system level load forecasts.
  • The Commission should require the IOUs to submit detailed evaluation plans and conduct ex-post evaluations that compare circuit level DER forecasts with actual circuit level net load conditions.

 

Track 3 Workshops

On December 12, 2016 the Commission held a workshop to discuss parties’ proposals for a Distribution Investment Deferral Framework (DIDF). The DIDF will define procedures for the utilities to identify opportunities for DERs to defer or avoid distribution infrastructure projects, to seek authorization and cost recovery for DER solutions, and to ensure that the savings from deferred or avoided distribution investments are accounted for in GRC filings.

On January 24, 2017 the Commission held a workshop to discuss the development of a framework to evaluate grid modernization investments that are primarily aimed at increasing DER penetration, integration and value maximization.

On February 10, 2017 the Commission held a workshop to discuss methodologies for developing load and DER forecasts and the locational disaggregation of load and DER forecasts.

Workshop details can be found on the
CPUC’s website.

 

 

CPUC Rulings on Track 3 Policy Issues


On August 9, 2016, the CPUC issued a Ruling  requesting comments from parties on a proposal to consolidate and prioritize the Track 3 issues identified in the January 27, 2016 Scoping Memo. The scope of Track 3 was finalized in an October 21, 2016 Ruling. The October 21 ruling determined that Track 3 will consist of three sub-tracks: Sub-track 1 DER Adoption and Distribution Load Forecasting, Sub-track 2 Grid Modernization Investment Guidance, and Sub-track 3 Distribution Investment Deferral Process.

DER and Load Forecasting

 


On February 27, 2017, the CPUC issued a Ruling setting a schedule for the utilities to submit DER growth scenarios and distribution load forecasts. The ruling established a working group to clarify the DER and load forecasting use cases, develop methodologies and assumptions for DER forecasts, and develop approaches to disaggregate forecasts to the distribution circuit level.

Public Advocates Office staff participated in the DER and Load Forecasting working group meetings, which were held during April and May of 2017.

The DER and Load Forecasting Working Group meeting material can be found on the
DRP Working Group website.

On June 22, 2017, the CPUC issued a
Ruling requiring the utilities to file an addendum to their DER and load forecast Assumptions and Framework Document by June 28, 2017 and requesting party comments on the Assumptions and Framework Document by July 10, 2017.

The utilities submitted their
Revised Assumptions and Framework Document on June 9, 2017.

  • See Public Advocates Office’s comments on the utilities’ revised DER and Load Forecast Assumptions and Framework Document.

On August 9, 2017, the CPUC issued a Ruling that provided the IOUs with direction on DER and load forecasting for the 2017-18 planning cycle in order for the utilities to plan for their 2018 summer peak grid needs. The ruling also identified the issues that will be resolved in a final Track 3 Decision.

 

Distribution Grid Modernization


On May 16, 2017, the CPUC issued a Ruling releasing an Energy Division Staff White Paper on Grid Modernization and requesting comments from parties. The Energy Division Staff White Paper on Grid Modernization provided a foundation for evaluating proposals for grid modernization investments. Parties provided comments on the White Paper. The Grid Modernization process will be resolved in a final Track 3 Decision.

 

 

Distribution Investment Deferral Framework

 

On June 30, 2007, the CPUC issued a Rulling releasing an Energy Division Staff Proposal on a Distribution Investment Deferral Framework (DIDF) and requesting comments from parties. Energy Division Staff Proposal on a Distribution Investment Deferral Framework that built upon Public Advocates Office’s proposal for distribution deferral in the Integrated Distributed Energy Resources proceeding and in Public Advocates Office’s workshop presentation on the DIDF. The distribution deferral process will be resolved in a final Track 3 Decision.

CPUC Decisions on Track 3 Policy Issues

On February 8, 2018, the CPUC adopted a process to determine the distribution load forecasting and the DIDF. The distribution load forecasting process adopts the CEC system level distribution load forecasts and distribution load forecast disaggregation methods for use in distribution planning.  The CPUC also adopted a process for identifying and implementing a DIDF.

 

The CPUC adopted processes for load forecasting and distribution deferral (Decision 18-02-004) on February 8, 2018.

 

On March 22, 2018, the CPUC adopted a framework for Grid Modernization Guidance to inform future General Rate Cases (GRCs) (Decision 18-03-023).

CPUC Proceeding Docket

See the Proceeding docket.