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's (the Office) Position

The 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.

The 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 the 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, 2017, the CPUC issued a Ruling releasing an Energy Division Staff Proposal on a Distribution Investment Deferral Framework 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 Proceeding Docket

See the Proceeding docket.

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