All right, everyone, I just wanted to make sure that we have the utilities here. Uh.
Yeas here from so I think we have the main speakers.
Present, so, Michael, can you confirm if we're waiting for anybody else from the utilities? I don't think so, but.
Let's go on my side Jose. All right. Sounds good.
All right uh, well, let's 90 am sharp, so let's start.
Uh, thank you everybody for joining today's, uh, 3rd, limited generation workshop per resolution. e5230 uh, the workshop is technically scheduled to run 9 to 4 with a half hour buffer. half hour buffer
Robert next slide please.
Yeah, from safety reminders, uh, make a note of just rounding and exit routes, reach out. If you need help either during the call or to an.
Uh, this meeting is being recorded and the recording and materials will be posted in the, uh, rule, 21 web page.
Uh, workshop participants are encouraged to ask questions during the presentations, although we have also dedicated Ed. Q and a session.
After each presentation just in case, but this is an interactive workshop.
Ah, please remember to keep yourself muted when not speaking and, uh, do not put the call on hold.
Ah, to speak, unmute yourself from the bottom at the lower part of the screen and identify yourself before speaking.
Although I think most of it, uh, I think we pretty much recognize each other's voices right now. Uh, if calling by phone used to mute.
Ah, button on your handset and unmute yourself to speak if muted by the host press star 6 to unmute.
To raise your hand press star 3 uh.
If you were forwarded the invite and did not receive it directly from energy division and would like to be added to the workshop distribution list. Please email me.
Future workshop invites normally include participants from the previous workshop.
So, um, it's better to be safe and just drop me an email.
Just in case, uh, next slide next slide. Please, Robert.
Just a reminder, uh, that's our, uh, what, where you can find all the recordings from this workshop and previous workshops.
Next slide. All right, so we, I think we have a full agenda today. Uh, we're going to pretty much start with, uh, the utilities presentations.
Then take a quick break around 1115.
Um, and then continue on with the presentation I do want to make a hard stop at 230 for lunch. 1230 to 130 in case. People have scheduled, uh, you know, meetings based on this schedule.
you know meetings based on this schedule
I noticed, uh, I think last workshop or the previous workshop, some people had already scheduled meetings during the lunch break. So I just want to be courteous and not.
Getting away with that, and then we'll continue the, uh, presentation, uh, the, you know, the timing on.
Topics, of course, is subject to change based on discussions.
Um, and then we'll pretty much open it up to general. Q. and a.
And wrap up in next steps, and, as I mentioned, we do have some, uh, you know, according to this agenda, we should finish around 330. but.
You know, we do have some buffer time next slide please.
So today's workshop number 3.
Uh, workshop number 4 is scheduled to be, uh, April 5th, the invites have already been sent out to that and they were.
Based on the attendee list from.
Oh, maybe a week and a half ago.
So, again, if you were forwarded the invite.
And are not and workshop number 4 is not on your calendar. Do you send me an email to ensure that you get invited to the 4th workshop?
Um, this, um, March, 16.
We do have a smart onboarded working group call.
And that you told us will be continuing a discussion on the section. E.
Next slide please, Robert, and this is just a quick list of the topics.
Um, from the resolution.
And will not go through with them. Everybody is probably familiar with them already.
Next slide, uh, next steps, uh, if there is anything that needs addressing.
In the advice letters and the 4th, and I stress final workshop, because I do not think we'll be able to squeezing it squeezed in another workshop. Um, after April 5th.
Please email me and CC Justin uh, by March 22nd.
At noon, so having said that, I think we can.
Move in to the utilities presentations.
Thanks, Jose. Uh, will the be able to present the slides? Or should I get that queued up?
Uh, new, um, yeah, will be able to present that.
Awesome. Great, thank you. Thank you. Bye. Bye.
Yeah, thank you. Francisco Francisco is the presenter.
Thank you Francisco and thank you, Jose. Good morning. Everyone Michael bring in with Southern California Edison here.
Um, I'll get us kicked off with topic and then hand it over to my utility counterparts for other portions of this presentation.
So, topic, 1 is on quarterly reporting, we can go ahead and go to the next slide. Please.
So, here, we have an excerpt from resolution 5,230 that comments on the use of advanced meter infrastructure or am I,
for projects with a nameplate of less than 1 megawatt and telemetry for limited generation profile projects with a name plate. name plate
Um, as stated over 1 megawatt, um.
As telemetry is already a requirement per rule 21. excuse me for project? Size? Above 1 megawatt.
Um, so slight clarification is, you'll see on the, when we make it to the next slide here is, um, the use of telemetry is for 1 megawatt or larger, not simply above or over 1 megawatt. So, including projects with size 1 megawatt or larger.
Um, so we'll clarify that on the next size slide, but as far as this goes.
The are directed by the resolution to finalize the details and Terra language during workshops, including this 1, um, and included in the subsequent advice letters.
Next slide please. So, here, we have the conditions for data versus telemetry to monitor the export of limited generation profile projects.
So consistent in many ways with the language we saw in the last slide where we have limited generation profile projects with nameplate less than 1 megawatt. The will use data where available.
If for any reason, the data is not available telemetry will be required for these projects under 1 megawatt.
For limited generation profile projects, with a name plate greater than or equal to 1 megawatt. That's the nuance. I was keying in on on the last slide. Telemetry will be required.
If the telemetry is monitoring only the generation output, then we may also leverage M, data. We're available to monitor the export at the point of common coupling.
And 1 other note on this side, as it's come up in prior discussions that, you know, data, it has the potential of serving as post event data point. It's not although designed to send data in real time.
So it's not considered an operational tool.
That offers real time visibility to utility system operators.
So, on the next slide, we have the proposed terrible language, but before we go to that 1, actually, I kind of want to pause on this 1 and see if there's any questions or concerns on this approach. So far.
They'll certainly be more opportunities to ask questions, but I don't see any any hands or anything in the chat. So let's go ahead and move forward. Please.
So, here we have the proposed tariff language for, uh, topic.
In the existing rule 21 section 5 title telemonitoring there's this paragraph we have in non bold text here.
I won't read that word for word, but the main takeaway here is the proposed edition at the bottom.
Which is for generating facilities with a limited generation profile, attached to their generator interconnection agreement.
If is not available, or the customer opts out telemetry at the point of common coupling will be required.
Any questions or concerns with this this is the last slide we have for topic. The 1.
Okay, so I would suggest oh, thank you, Michael I would suggest that, you know, since people, uh, may not have.
Thoroughly read this yet, you know, maybe, uh, at the end of the, uh.
Workshop if, you know, we can go back and make sure that there aren't any concerns.
Otherwise, uh, you know, 1 of the purposes of a.
You know, this workshop to the next workshop is to close out.
Uh, items, and, uh, you know, uh, get ready for the upcoming advice letters.
Sounds good, thank you. Michael. Thanks. Thanks. Bye. Bye.
All right, so, yeah, so jose's, uh, point the, uh, presentation slides have been attached to the meeting invites. So.
Um, if you'd like to take a moment to review the existing language, and, of course, towards the end of the meeting, or later in the meeting, if there are questions on topic, feel free to share those questions. Um.
Other than that, I think it's, I'll go ahead and pass it over to Alex, which is going to take us and he's going to take us into topic be to.
Hey, good morning. Can you hear me? Yes.
Awesome. So I will be going over to and topic topic. So the language is being shown, um, next slide. Please. Sorry.
Yeah, so this is, uh, straight from resolution 50 to 30. um.
I think we've included this language in several of our presentations before so.
I will not read the whole paragraph so.
Next slide please. So, as part of topic, um, we were asked by the commission to go over the existing.
Reverse power options or screen I options I use intend to add a 12nd option to cover as we feel like this would be more clear,
and it will minimize the number of required revisions and probably confusion when applying these screens during inter connection. So, what's being shown on the screen is the existing screen. I options. There's currently 11 of them.
The option 1 through 6.
Why existing prior to working group? 2 and 3 option 7.
Was in existence, but he wasn't.
Uh, clearly listed as an, as a screen I option, but the language is already in the tariff. So.
During the previous revisions we made that clear and added a specific option. This is for.
Projects that are using acdc providers and then options 8 through 11.
As a result of the turf changes stemming from.
Working Group, 2 and 3, so we plan to add a 12 option. Like I said, for that 12 option is going to mimic option. 9.
Closely with some additional changes that are specific to projects.
Are there any questions on this existing.
Screen I options. Okay.
Next slide please. So, as far as is concerned on the application of in rule 21 screening.
We went through all the existing screens through M.
For initial review as well as an for supplemental review and what would.
Trying to do here is, uh, specify which screens will use the values versus which screens will use the template and then also going a step further and saying which screens are not going to be impacted those screens.
You'd need the template or so.
I'll go through this very quickly, but if there's any questions, please let me know. So.
We've already presented this before as well so in previous slides, we went over some of these screens so screen a.
Has nothing to do with values or name.
Uh, that's the same case for screen B and C.
Screen D would usually use nameplate.
Or exploited values for purposes of.
Screen D will use the maximum value, so.
Whatever maximum export potential from the facility is what we will use to analyze impacts on screen the.
Screen E, neither of the 2 will be applicable.
And then screens f F1 g and H will all use nameplate are using an because.
They have to do with full studies edge is using template because there's a calculation.
I figured if the, uh, between generation generation versus.
Existing loading and then.
Screens I screen eye does not use either template or for, for purposes because projects.
Exporting projects, so, screen eyes question is whether it will be power exploited across the so because the projects do have exports.
It would fail and I, and then.
Screens. J. K. L. L. I use.
In the current carrier, and the 1 no changes proposed as far as, as as far as the is concerned. So those will stay the same.
And then screen M, for projects will be using the profile. So they will be using values.
Any questions on any of these screens squared sky.
Good morning Alex. Thanks everyone. Um.
So, I think that I disagree that J and K should be named I think they should be.
The Max export value, so sort of similar to what you have for.
And in as you look through the.
The slides the language that you're proposing for the URL. Um, certified is the same as screen as the technology used under.
Option 9, I guess, which is, um, and in that section,
it allows for the limited export value under those screens and I believe it should be the same because the export is being controlled.
Was that say J. N. K.
Uh, yeah, that's what you okay. Yeah I, I honestly don't, um.
Then that's what what going back and take a look at yeah.
Yeah, I'll just for others reference I can put in the chat, the language from section and then.
It's for people to reference.
I think we had a a lot of healthy conversation.
A couple summers ago I'm trying to figure out all that square section. 2.
Um, yeah, I think that makes sense to a call along with that.
Yeah, so the, the approach we took on this was.
Um, this, this, the screening for J. so okay, you take that back. So the screens don't change uh, J. K.
And L, I'm not changing the actual screening language for the specific screens. But I think what we did for 9 is say.
For limited generational projects, this is how you would apply, right? Right. Yeah. So.
Same with with D, so didn't change it just as referenced how it will be applied through the relevant section. I'll say, depending on which of the option eyes you're taking.
Yeah, okay, well, I'll, I'll check that box.
Thank you.
Any other questions alright,
next slide please.
So, for as far as screen, I mean, uh, supplemental review for screens N. P.
Uh, screen N, is the penetration test.
So, for the purposes of.
If a project fails screen M, there will be no opportunity to go into.
Supplemental review, so we'll cover this.
Concept radio in next slides, but.
If a customer is proposing project.
And the profile does not meet the requirements that will be given an opportunity to fix the profile.
If they do not fix the profile then screen and would fail.
In which case initial review would fail. So there will be an opportunity to go into supplemental review.
I see Scott has it opened up? Yeah, I think so.
Generally, I looked through your side and I know we haven't gotten there yet so we'll have to sort of back and forth a little bit but I agree that it generally, what's the approach that you're taking? The projects that, um.
If the profile isn't doesn't match the, that you'll.
Um, give us an opportunity to correct what happens, though if they decide.
If they don't correct is the.
Are you just going to study it as though? It's out? It's Max.
Limited export amount. No. So if they do not correct the profile, um.
Well, thought process is customer is going to propose an project. They understand they everybody understands what what needs to happen. Right? The profile has to be below 90% of and so.
If they propose a project that whose profile.
Does not meet that requirement and we give them an opportunity to fix it and they don't fix it.
We'll draw the project either have to reapply as template or.
Okay, it's not that the project isn't eligible for something level review. It's that the project essentially ends there and it's terminated versus having to go to study or something is what you're saying.
Yeah, because they I think that previously would say that we will start the project as template.
But then we're run into issues because there is material modification language in the tariff that says, you can't increase a project or infrastructure.
So, the project is proposed with project nameplate is above the.
L. G. P. values and you can't really start technically can stay on the template because then you'll be violating the material modification rules.
Yeah, I mean, it doesn't really make sense to me to study and under name play because that's all. We know what they would do. It would make more sense to study it under limited export. But I think I'm okay with that. Like, if they propose a profile and.
You're and they don't for some reason, get it right in the sense that it doesn't match the IC data that was that they had available. Then.
Then they should withdraw and resubmit if they wanna just do a traditional limited export is essentially what you're saying, right? Yeah, exactly. Oh, they can resubmit it as a again if they're wanting to. Yeah. Right.
Okay, I might digest that a little bit to see whether it makes sense for them to just be studied at the Max export versus name plate. But I think I think I'm inclined the same direction on that. Um.
I'll let you do then so.
So, and have pretty much the same language and the, the idea here is that if a project goes through the screening process.
Fails any other screen by screen M.
Then we would proceed into supplemental review and once you get into self mental review, the language that's already existing will be applicable to projects as well.
Meaning, you know, uh, however, we detailed.
That will status and will be similar to how we would study a profile project. And so if, uh, for project passes screen, em.
Which basically will be looking at comparing the profile to 90% of profile and you go to submit to review.
Then you're basically going to 100%, right? Uh, I think so. It would be 100% of profile.
For screen, and for the penetration test and then obviously, if 1 screen.
So, if it's, uh, based projects, that is.
As a of 1.2, then you would pass if 1, because.
As long as the project is below the protection and then the other sprints will be the same.
So, the key here is that if M fails.
And they don't fix the profile, then they have to withdraw and reapply.
If impulses and some other screen fails, then we'll proceed into segment review and study at the same way. We would for a limited generation.
Project, so it just occurred to me what's wrong with the proton in 2?
So, project proposals, a limited generation profile, um, and it fails.
Any of the screens, um, including, um.
And in the same screen, right? So, and actually.
The 100% of the profile is that correct?
Yes, so is there a reason why you're not proposing to allow the project to go to.
The screen, and even if they, if the profile is not correct.
So, the, the study would be similar, but the language in, and I think would be 90%.
For projects, and what's the reasoning behind that?
The same reasoning why we are using, um.
90% in screen, don't you think that the commission might make the same decision between.
But we have the same debate about screen them for, for flat profile projects.
Well, I would hope they don't, because, because we're now using 1, single provider, right? We're not using 1 single value and G. is.
Way less conservative than or have so.
Right. We're using multiple values to study a screen m or N and then we're not using.
You know, or if we're using, so I think then we're going to go back to the same issue we've been talking about with.
1 single value versus strong versus 288, right?
Okay, I'm going to pause that I guess whether that's something that.
I work at least as comfortable for obviously lots of others participating. What about if you fail the other screen? Um, so it seems to me, like.
So, what if you, if you fail, you know, any of the other screens, whatever.
Shouldn't there still be an opportunity for supplemental review if you got the profile, right? Yes, yes.
So, did I misunderstand that then? So, yeah, you did so they.
For purposes of going to submit a review, you have to resolve screen M, issues.
Screen M. M. passes.
But any other screens, I would normally push the project to supplementary review files.
Then you can go to the right sorry?
That's okay. Sorry. I was cutting you off. So I, what I'm asking about is why does the current language apply as opposed to the same treatment under 2, which would specify for different? Um.
Aspects of the review under that the max.
Export value, for example, the applied to the same question was asking me over the last slide.
Yeah, so they I think we'll have to include tariff changes under the specific screens and the.
So, for example, if you go to the current and.
For the penetration test, it tells you like, you know, projects that use nameplate or projects. They use typical generation profile. So we'll have another paragraph of projects to use the.
And then for I think there's an check for N. so if everyone passed.
And the initial review, then that would obviously be a pass so probably a way to segment review. And it was I don't below 90% and was good. Then end would pass.
And then you would go to screen or.
And all you still look at the same whatever on that. Oh, and then he specifies that, you know, you would use.
Uh, whichever screens are applicable for studies to study them, you know, uh, separately oh, differently.
So, I think what you're asking is waiting to include the specific language and.
The minimum Paul or the.
Screen that we're going to use so, let me pull up here. Hold on a 2nd. Um, so, 2, um.
The again, so we're using the same. I'm talking about using the same um.
We just paste it in here, so it's clear to everyone. So the 3rd.
The final section in 2 is.
In the chat, which says that screen piece will be applied using the generating facilities growth nameplate rating for evaluations, but use fault current calculations for other evaluations under screen. P. the value identified into above may be used, which would be.
For it was the Max expert.
The requested limited export value. Okay.
Yeah, so the reason why we did think we did not include that in the the new option is because we wanted to only talk about M.
Uh, sprints M, and D, because of this, no one's going to submit review only if the screen and passes.
So, the difference between the new and the existing M2 is because you would go to supplemental review if you failed any screen, right?
You do not do an evaluation under P relevant for screen D. I'm asking. I don't know.
We do not so screen the screen deal will be evaluated and the screen.
And the screen D, right. So so, failure by itself would not require the project to go to supplement review.
So, if you feel screen D, and you pass, em, and you pass all the other screens, you could resolve that initial review.
Because it's meaning you determine if the transformer needs to be a screenshot or something through something before you can go into something all review. Exactly. Yeah.
Which is great by the way. Very few states do that. We appreciate that. So the only thing that really are gonna push you to submit, or you're gonna be your screens f and edge.
Those are the ones that are going to require additional sort of review. Um, and mostly because they have to do with.
The full studies, which require, you know, like the actual study, rather than just a screening. Um.
Process right so those should be used.
Nameplate or actual current at the very least right?
Brian, does that make sense to you as well? I'm not 100%. Um, okay.
I guess I'm trying to figure out, you know, with screen. Oh, it'd be applicable.
For failure of those screens, and I guess it just.
It would make me feel more comfortable if we just had the same language than anything applying to false current.
Would utilize the nameplate rating and anything applying to.
Not applying default current basically look like what not would would utilize the maximum output. Yeah.
In the schedule, I'm trying to figure out. Yeah, I.
I don't know, I can't follow whether there's never going to be scenarios where you.
Wouldn't need to look at the are never going to be scenarios that you would look at the.
Reading or, you know, or the export limited rating for low slow purposes, basically, or some other evaluation that.
Is not really related.
So, Brian, if we added a paragraph at the end of the new proposed option, that said.
You know, it's this basically the same thing that we said in the previous slide, uh.
Whatever slide I covered before as far as, like, which screens use the template or not if we added a progress that covered that that would.
Get rid of it happen for you.
Yeah, I think if it is so similar to the language that I paste it in a 2nd ago regarding screen.
Yeah, I, I'm still questioning. Oh, because I'm not certain.
I would assume, I guess for hope that you would never use nameplate. Um.
So, again, like, the, I think I would just follow the same. Yeah. As I think that was 2 paragraphs essentially.
Sorry go ahead. Right yeah. I don't know where.
Would utilize the maximum level where appropriate, or just use the maximum level and then.
He would use the maximum level where appropriate and the, the nameplate gradient where appropriate.
Yeah, we can clarify that I think. Yeah.
Thanks, Alex. This is helpful. Um, like I said, I want to.
To think a little bit more about, em, and maybe confer with our N, sorry.
And confirm with Brian about it, but I do see the, the important difference between the, and the sort of.
Buffer and so on there, so.
Um, I'm just noting that I kind of need to think give a little bit more thought to that.
Yeah, so.
We will clarify based on the previous slide on which screens use, but since which ones are going to use the value.
By adding a paragraph at the end of.
Can you propose carrier language to say which screens.
With regards to we'll use an employee versus which ones would not.
Yeah, and I would ideally use as close of like you guys did in the proposed estimate if we can go go to that screen next.
It was a similar as language as possible to things could be as clear as, you know, it's very difficult to follow those sections already, but that would make it as consistent as possible create confusion.
Okay, so, uh, Skype, when you see when a, um, you know, uh.
Talk with Brian more about this, uh.
You know, given time and basically, uh, when would you want to bring this back up at the end of the workshop, or maybe devote some minutes to it during this part of our working group on Thursday? Yeah.
Let me confirm with Brian a little bit, um, on the bar and see, um, maybe we can talk a lunch. I just want to I need to kind of think through it with, uh.
Clear understanding now. Okay. Yeah. I didn't I didn't want to have a different time.
Um, I didn't want to put you on the spot, but yeah, I, I just wanted to, uh, I'm thinking timing here.
So, yeah, I appreciate that. Um, if I, if Brian and I are able to connect during lunch or something, I will.
Maybe I'll could make that call and if not, we can talk about that.
At the swag or the if I still have for the questions.
Okay, yeah, sounds good. Just let me know.
All right. Go ahead.
Okay, there are no other questions we can move on to move to the next slide. Please.
Okay, so this this is the.
Uh, these 2 slides, the next 2 slides, uh, what we're proposing to be included in the new option 12.
Also known as, and this will be the limited export.
With limited generation profile, utilizing certified power control systems.
So, for those who are familiar with the existing.
Language in, uh, option 9, which is.
The big beginning slide is pretty much the same language.
Because this is this is talking about what the.
Has to meet to be able to be used for option 12. so the requirements at similar.
I don't think there will be any questions on this, because we didn't really make, um.
Any changes to it, but take a 2nd to see if anybody has a question.
I guess 1 question is, um.
I appreciate that this way, we're just parallel with him too. Um, but I guess the question is, does it need discuss any specify anything regarding the scheduling capability with the SRC?
I'm not sure how the devices are going to work instance of well, they all just be certified and the same thing. Or do we need to specify that? It.
Has been certified with the scheduling capability. I don't know if, um.
If John is on or Brian, if you know.
No, that's that's a very good point. Scott, I think I think we missed that. Yeah.
We should specify that it has to be.
It has to be approved for scheduling as well. Yeah, Brian or or John if he's on. Um.
I guess the part that I'm not clear of is will all divide all systems that are being certified under that.
Tests has to have the scheduling capability is such that it's not necessary to restate it.
Or or will it be an added functionality that some will have? And some won't have under the 741.
Now, that would be added functionality in it.
Would be I don't exactly how it's going to be described to be honest, but.
It is an export limiting scheduling basically.
Yeah, we can probably want to pull.
Whatever language is similar to what's being discussed in the working group um.
For for that yeah, optional functionality and as well describe, you know, how many.
How many values should that schedule export and I don't know if they're.
Potentially other parameters involving the schedule that the working group is discussing that might need to be specified, but.
It seems like the beat, the minimal thing.
Okay, speaking.
It didn't oldest, we can't here. Barely hear whomever is speaking. If somebody gets Christian.
Yeah, Christian could you get closer to you, Mike? Please.
1 moment actually sounds better.
Okay, is it yet or is it better now?
It was actually better when you said 1 moment.
I don't know what changed, uh, how is it now?
Okay, 1 on ones, it's marginal at best.
Does it work now?
I think we can understand you, can you hear us.
Water broke now.
Um, probably, I just try to write it.
Would you just said sounds great Christian.
Now, he's got on mute.
Yeah, Christian you actually your volume was perfect, right?
At the last part, when you said you were writing it.
So well, Christian come back, um.
I guess when it sounds to me, like, maybe, um.
The, and.
Brian, and maybe the folks that are participating in the.
I'm wondering if they can work offline to.
In the next couple of days to work together on that language that needs to be added.
Unless we think we can hash it out here.
I have a session for the 1st, kind of 2019. audio is also super.
You know.
So, you may need to lower your mic a bit.
John has a Mike, so it's my computer.
We'll try again. Is this right?
It's better. No, no, that's pretty cool. That's better.
Okay all right let me go back again. Um.
I guess my question is that just the f*** it's referencing the 29,019.
And my understanding that we're in the process of updating a 2023 PCs.
Is the exact kind of the name of the standard will be able to finalize before the advice letter or.
Do we have to, like, agree on a high level language and come back in.
Update the exact reference to the standard. Does that make sense?
Yeah, so if you look at number 1, it says, 2019 you will standards, but then the next sentence.
Saved me says, may use a PCs that passes later published revisions. So I think we included this language here, just to cover our bases in case. This standard does change.
Okay, it's the Steve, a Christian put a.
A clarification in the chat, but the will not.
Contain scheduling.
Information it'll be the 741 supplement when we get it finished and we'll have the scheduling.
So, the 1st, number number 1 probably covers a.
Okay, thanks, Steven but I think we should still, um.
That's good to know. We'll still add something there just to clarify and that's totally John bertner's note as well.
In that chat, I think he can't speak right now, but he's having something to the chat.
John burner says, well, the best is on schedule.
Is this a major part of the revision underway?
The group is the task group on.
Is somewhat on board ending our solution, or to schedule that this proceeding.
So, that that work that's underway is to format the into 741 supplement.
And that would be 741 itself, not the cod.
Right. It'll be the, the, what exists as a now.
We're, we're revising it cleaning up some stuff. Um.
Adding scheduling information and all, that will be published in 741 as supplement. Uh, the, the will not be updated.
What we're doing now with the project, John talked about is all improvements and revisions all that's going to be pulled over into supplement.
And no changes. Okay. Yeah. So we could eliminate that language around. The seems like.
And I tried again, maybe it's better now.
Yeah, you're you're good Christian. Okay. Uh, and all this functions, which are in there, uh, will be optional. So it's, uh, there may be our systems out there, which are certified and which are not certified.
Of the manufacturers to status in their, in the documents.
Yeah, so this I, I guess what Brian said is a good point.
Um, if this is specific to limited generation profiles, I scheduling.
Um, and you're, you're drafting language specific for that, then there's no use mentioning the, because there's nothing in the for scheduling you might as well just say, supplement 741 supplement se.
Well, the supplement as he include the basic export.
Control capabilities rolled together the covers. Okay. Got it.
Yeah, so okay. So yeah, if they're right now the does have export control as part of the 1 of the use cases that you can certify to.
So, yes, if you're trying to say, you can use a type of export control that's not necessarily scheduling. But, you know, maybe some P limit or load tracking or self supply that can be covered under the existing.
But if you're talking specific about scheduling, that is not in the.
And won't be in the this is John so I was having audio difficulties earlier. I just point to the last 4 words in bullet 1. I don't think we do.
Yeah, that's what I'm wondering John. If we just can't.
It looks fine it says, or you will publish standard.
So 1 supplement today would be.
And once supplement publisher would be, or you all published standard.
Yeah, I don't think we need any change.
But we still need to note the scheduling capability if it's an option right? Because not all things certified under SC will necessarily have.
Have the scheduling capability is that right? So I agree that that.
The reference to the standard makes sense, but this doesn't refer to actually having the scheduling.
Is that right? John? Well, I'm.
I'm confused because I'm in 5 applies generally.
Right. To all system and yes there will be a certification to scheduling.
As part of I see, which would be the relevant URL published standard. So.
So, I don't know what what we're proposing to change on the slide. That's on the screen.
So doesn't exist today we're proposing Alex jumping here. We're proposing to add 5 specific.
To capture not just limited export, but limited export with scheduling capability.
So that's so the discussion we had about the different ways, the screens that apply and stuff are going to be captured in that. But what what would distinguish 5 is that it's not just that it has the limited export capability, but that it has.
Scheduled limited export capability essentially. Yeah, so that, that would maybe be an additional bullet.
Uh, here right you want to mention scheduling? Yeah, exactly.
Okay, that makes sense. Yeah, I think even without it is probably.
Um, it's probably we could probably call on it right? Cause there's language in here that says.
You know, like, for example, in the 1st, paragraph facilities into connection study process, meaning additional technical requirements that are not explicitly noted here. But I think it's better to just state it since we already know that scheduling is required.
I think we'll add language to that effect. Um, just so there's no questions. Yeah, I think it should be because otherwise it's going to be confusing. Yes. Difference between is and I would also change the title of option 12 to capture that scheduling.
Oh, yes, it does already started. The limited generation profile aspect is captured.
Yeah, no good suggestion. Yeah, we'll add language in there that specifies that scheduling is a requirement of option 12.
And, but I also agree that the language as written right now, kind of, you know.
Gives room for additional standards or revisions to the standard. So.
And I think for this important this role, because at the moment, um.
The scheduling function has different certification levels.
Or where it's up to the, um, manufacturer to which level they are certifying.
For example, only 12 failures, 24 hourly values or 208 up to 288 values. So, this is probably something what should be specified in there as well. But it's probably difficult because so the standard.
probably difficult because so the standard
Uh, it's not published yet and, uh.
Probably takes, uh, still some work, uh, to finish this and, uh.
This rule is, uh, input to this document as well.
I do see, kind of a chicken and egg problem here.
Until we know what the schedule looks like. It's very difficult.
To determine what the test needs to be.
We're only talking about 12 per year.
I would propose you just do it with 2032. 5.
From the cloud, why would you do anything.
With a local PDFs so.
If it's 12 hours, only that's already supported.
We would need to change to.
Support that command, but if it's only pro values, then there's really no need.
You could schedule 2 years worth with if she said, supported an expert on it.
So, it kind of depends on what the resolution, how we decide.
What the grant granularity you have to schedule needs to be.
Before you can figure out what tool to use.
And once, you know, what tool to do is you can write terra language. So.
It's a little bit of checking in. I, I think.
Hey, John. So so the 208 is kinda, already decided I believe it's just a matter of, is it going to be 208 different values or is it 12 different values? So, if the schedule can accept.
288 different points by the.
The only represent 12 different values.
Would that change? Is there any different than 288? Different values?
From a testing perspective, the the issue Alex is is today and the, there's requirement for 24 scheduled values.
Problem is that, um.
It doesn't as Josh just pointed out and agree. He said it doesn't support today.
Export generation 1 no, I'm sorry, John. My, my comment was, it does.
Support sorry? Yes, yes. Okay. So if you, if you have a.
A compliance system with export generation limit.
I think the problem Josh supports export generation limit.
But it's a static value. It doesn't support it as a schedule.
Right. Uh, no, it it can be scheduled. It's a, it's a.
Dvr control can be scheduled. Um, so you can create.
Um, continuous schedules with a, they, um, 2035 server. Um, if desired.
So that's possible. Um.
So, yeah, I mean, I, I thought we looked at rule 21 and.
Brian, brian's on the call I taught the conclusion was it didn't support that. So.
That would be a new. Yeah, that was that's my recollection as well. Um.
That wasn't, I wasn't I wasn't part of those conversations, so I'm not sure what what that's referring to but see.
23.5 supports an export generation limit.
It can be scheduled as a control and so you can schedule continuous controls regarding the comment about 24.
so, the requirement in is that clients, um, she'll be able to store at least 24 scheduled control events. So I think that that, at least is. least is
Key there, but, um, so, yeah, you I don't think at least from my understanding isn't, um, eliminating part of this thing at 2030.5 was used.
And this is Christian, and I think in our prior discussions, we have set that it supports, and it can be done. That's why I think.
Roger Roger shared all the.
Documentation and architecture, and that it concluded that it supports.
And it is possible, it's only how you do it that was a question.
A remote yeah, the architecture is a different thing. The, the protocol is fine.
I I don't think it's an either or a situation here.
You know, it's if we are willing to support.
Offsite communications as a part of the schedule that would be.
A separate set of requirements, right? So.
The requirements that I think Alex is trying to list out here are the requirements for a standalone PCs.
Yeah, good point. Plus communications. So, you know, we might need a M6 if we want it to support it.
Yeah, thanks. Thanks for bringing us back. Yep, so.
Yeah, these requirements are PCs. I think Josh is right Roger did have some options. I forget how many options have listed possible options for doing this. Right right.
That is a separate discussion. Yeah. Sorry right. Maybe the solution is to just.
Require a general put in a general reference.
For you must have a scheduling function that meets the requirements to the.
But then specifically call out, it could be.
A recurring schedule, uh.
From 741 supplement.
Supplement or a C for scheduling function and then you leave all the doors open.
But you have a way to say yeah, it's, it's included in it too.
So, a manufacturer might include a 288 value.
Register for 2013.52 set schedule function.
Which would work, or they could use an offsite server that and the onsite supports only 24.
On the server periodically updates, I mean, all those are possibilities, right?
Yeah, I, I.
Personally, like this, you know, specific PCs.
Uh, using, rather than mixing it up with what else is.
Valuable possible. So, um.
I will take your recommendation and I think I personally think we should just keep it this way.
Tackle the requirements when when customers would like to use PCs and then if there's any other option address that separately.
What do you mean by address that separately? How would that be addressed under a new under a new option?
Okay, are you open to doing a new option? Are you saying, and having this? Well.
I think I, I don't know how what the conclusion was that discussion I think what I remember was that we ended up landing back on PCs use of, and the other systems. I mean, the other options were not viable.
That's my recollection. So, at this time, I'm not sure if this.
Any other alternative that can be can.
Meet the same requirements in the same timeline as a PCs.
Because of the with these different pieces, like, for example, there's a server and maybe you use that with the PCs. But then.
There is no test for both systems together. There is no certification protocol or certification.
Testing for both systems. Right? So that's kind of what we do this either. You still need a PCs to do the schedule is that what I remember or? I didn't think that would.
I think the will have the schedule, but I'm not an expert in this. Maybe Josh can chime in, but.
But the PCs is what's going to be needed to do to do the controlling.
Is that right? John hey, sorry we do.
Do we want to do we want to divert this conversation to the topic E, discussion? Because I think it's kinda hard to not.
Discuss architecture when we talk about these options.
Yeah, let's do that. I think we can wait until topic. If everybody's okay with it.
Yeah, does that work for everyone? Yeah, we'll just have to go back then if we need to if we decide to use 1 more than just the.
You all or the, I guess it's not going to be the it's going to be the 741.
Option? Yeah, fair enough.
All right, thank you for all the questions. If there's no other questions on this slide, we can move on to the next slide. So can I just just so we don't lose what we did so it sounds like the takeaway is, is that, um.
For the, for this year, for the 1741 option, we need to either add.
To paragraph 1 here or a separate paragraph that does identify still, but it has the scheduling capability. Not just that it's certified under 741. um.
And I think that was the only language we identified that need to be changed, right?
Yes, that's correct. And Alex, do you want to take a crack at that language? Or do you need support from our.
741 wisdom in the in this room, so to speak.
We'll take any help. We can, but we'll, we'll try to do it on our side as well but if anybody on the call.
And you suggested language, you can either put it in the chat, or you can send it to us and we'll, um.
Included okay.
Okay, there's no other comments or questions we can move on to the next slide.
So, this slide is, uh, the slide that covers the changes that we're proposing. Um, so.
For option 12, uh, it looks slightly different from the language in.
And I actually quite a bit different and.
The idea here is that we wanted to identify the screens that.
We will be reviewing and what they'll be using, you know, as far as an input or.
The controlled export value, so.
For for the purposes of projects, we'll use.
To analyze screen f screens.
G and screen edge. So this is.
Consistent with the previous slide that we covered as far as which screens use 1.
And then what screens? D and screen M.
Sprints decent Sprint and will not use template. Um, so the language below goes over.
How we will review a screen, em, and how we'll, we will review screen B.
So, for screen M, we're introducing this steady state value. I think it was also in the previous.
Option 9, so if the maximum steady state value is greater than 1% of the controlled template.
This is, uh, based on the testing.
We will use the requested values so basically the profile has provided.
Uh, plus the maximum steady state value of the PCs.
Multiplied by the PCs controlled nameplate. What's name?
So, if we get a a.
Test report that tells us that the status state value is.
2% and the customer, let's use 1 hour proposals 1 megawatt as a controlled export.
So, we will take the 1 megawatt for that hour and then we'll take 2 times in the project template.
And add those 2 values, and that's how we would look the value that we would use to evaluate that our, that we're looking at.
This is for screen name so I'll pause here to see if there's any clarifications needed.
So, I'm gonna.
Ask can we, as I said before, can we do this.
If you said you were going to take it back to look at.
What is it J and K the same essentially the same treatment be given to those screens that it.
And, um, oh, and P.
Yeah, so we'll take it back to see if we can include the same language as for option 9 for and then.
Add the program for, in, in, on P.
P, specifically it can be added to the previous, uh.
Slide so they I think that's what no, no, you're right. It was in this section, I think. Yeah. So I think we may add another paragraph or something or another number.
Specifying how we will look at P.
So, this John, I had a question, um.
We're using the term PCs controlled nameplate.
Is that defined somewhere? It's just kind of important to understand that.
What what you meant by that? Mm. Hmm.
I don't believe that is defined in.
In the current tariff, um.
But our interpretation is that it's the.
It's the name of the project, I think this this language is included in to join and it was a result of the.
Discussions that Brian mentioned that we had before.
So, if that's not a correct interpretation, please let me know.
But what we're talking about here, is that the project name.
You know, 10 megawatts, they control the export limit.
Is a profile is 1 megawatt will will take 1 Mega time. I mean, .
2% of 10 megawatts. Right? So PTs controlled name really is a setting.
Is that correct? Because it is a setting in the controller for export limiting.
Similarly, it might be if you were to use a, a relay.
It would be the setting of the really not the total.
Rating of the system that would be the setting so.
I think it may be may be good to.
Be a little more specific here. Um.
In terms of what we're talking about, if we're talking about the setting or.
Uh, capability, just time for.
Okay, so John, do you mind.
Providing, I think it's good to include to include the, uh, the definition in the term.
So this is something that we probably should be fine.
Do you mind providing the definition for this? So we can include it.
Yes, I'll take a shot at it. I'll try try to put my.
Okay, thank you. Okay. Any other questions right? This 1.
Okay, and then as far as the screen D.
We would basically do the same.
As far as figuring out the maximum potential export and then.
On the profile will pick the largest value and that's the value that we would use to analyze whether there is any impacts on screen.
So, the same month, as far as they.
Profile or the controlled export limit.
Plus the 1% times, the PCs controlled template.
And so would come up with, however, many values are in the profile. If it was 12, there will be 12 different values and so for screen D will take whichever 1 is the highest.
Have any questions about.
Okay, and then for to be.
If the maximum steady state value is less than or equal to 1%.
Then we would just use the value provided on the profile.
So, there will be no additional, you know.
Kilowatts added to the proposed profile values, we just use those values as provided and then for the purposes of screen D, we would still use the maximum of the profile.
So, again, if there were 12 values would pick whichever 1 was the highest.
What screen? D and then Nick sorry.
Question and just this potentially the same for for.
The other screens are going to consider K. I'll oh, and P.
Yes, yes, yes. So basically.
Um, J, and K, um.
I think in an all be what would be added here because PE would be by itself, right? So.
Well, he is a combination. So P is it would be for P. you want to review the.
Felt current where, you know, the nameplate essentially work all cards being reviewed, but for other analysis you would want to use this Max export. Yeah. Calculation, which is slightly beyond my head. Yeah. Yeah.
So, I think before we had P at its own paragraph, but you're right, it was just specifies that if there's anything that's using.
For current calculations, use nameplate and then imply that everything else should use.
You know, the export limit and then 4 for J. K. and then all those were included in essentially number 2 here.
Right. So yeah, we'll take a look at that and see.
Whether we can add them, and if we can't add them, then we'll provide a reason why.
Okay, so so I want to go ahead, Alex. No, no, no, I, my questions are the later bullet, so.
Okay, so for number 3, once we've determined the profile to be used, we'll compare the profile to 90% of profile.
And all the values on the should be below.
90% of profile if if if the above, then the project would fail.
Would M, and therefore would also fail initial review.
And then if a project fails, the initial review, then the customer will be offered.
An optional results meeting at which they will be told why they are project failed.
And given an opportunity to fix the profile so, if there's a whole profile is below the or 90% of, or if it's just 1 value, that will be discussed during the optional results meeting.
And then the customer will have 5 days to fix the issue and resubmit.
A new profile and so.
When we get a new profile, then we will study.
We studied the project on the initial review we we wanted to point out here is that.
Based on the current tariff, the material modification rules.
They do not allow any reduction by more than 20% of the original request. Um.
And then, yeah, the issue here is that projects cannot be in Christian size during.
Crosstalk study so so basically.
You can only reduce the profile. It cannot increase it.
And the customer would have 5 days to do so, and resubmitted for study and the initial review if they do not do. So then they have to withdraw the project and reapply either as, or nameplate or.
Just limited, uh, export.
Go ahead, sky you anticipated before I went through my, my thought. Um, so.
So there seems so when a, if a customer, what are we envisioning in terms of when a customer with us.
Essentially use this, so the 1st is if they made.
A mistake essentially, they were intending to use the.
I see a profile and they accidentally, I'm going to assume a value that was about the profile for 1 or more of the hours.
And that this all makes sense to me for for that scenario, or they didn't understand the rules and.
Whatever, I guess thought they couldn't do that. Um, what is that?
Is the other scenario? Um, so the issue with 1 of the issues is that it's only updated monthly, right? So the profile could change.
Between when the applicants submitted their application, and when you do the review, because I can't remember what section that's in but there's that period. When you start in the short, you check the profile.
Yeah, so the, the profile can be different. So when we get when we get a project.
Under of group 2 and 3, we are allowed to change it if we, there's a reason why we think it could be different whether these other projects that have been proposed since the last, you know.
I see Iran or whatever the reason. So, this would also include that scenario. So we include.
If I scenario where the customer just, you know, provided.
A wrong profile, and then it also includes this scenario where they provided a profile, but because we had to rerun now, their profile is above the profile.
90% of profile remind me so put aside project. So 1 of the current rules.
What happens when that is the case when do you notify the customer that the.
That the ACA is incorrect, or has changed, maybe they'll put it that way.
So, we don't, we just we fail the projects so for customer provided an application for.
Initial review using a profile, and we find out that not profitable.
And they failed, they would just spell initial review.
And then there would have an opportunity.
To modify the project if.
To be in the carrot, but you're saying they can only even if the had changed more than 20% either.
At the flat level, or along somewhere along a profile that you're not going to allow them to reduce more than 20%.
Because it seems I don't want to make this too complicated. So I'm just playing this out. So I understand it. 1st, to be clear. But.
It does seem to me a little bit kind of again without putting normative.
Language you're unfair to not allow the project to just modify to match the profile whatever it is and it doesn't seem like a.
I guess that's what I'm kind of playing out here on 1 hand. I don't want to make this rule super complicated. On the other hand the applicants submitted an application following the icaay that was publicly available. The has changed and we're basically saying.
They have to go back re, submit if they want to match their IC approval, but the IC profile might change again. So it's kind of like.
Chasing your tail off of it if you can't just match it when you're in the queue and you have that sort of locked in opportunity to get it. Right?
What do you think about that? Yeah, I see your point, but I think what we're trying to do is be as consistent as possible with existing projects and existing tariffs. So.
You know, my take is if we allow projects to.
You know, be able to reduce their profile by more than 20.
Then when allowing any other customer to do, so, then he's in that basically.
Trading customer is different from other projects.
Yeah, and what I'm saying here is not necessarily unique to it seems like, um.
It seems like an a broader issue. That's why I was thinking it out. But, um.
How often do you have a sense, Alex? You guys have been doing this only for a few months now but I guess since, like.
Or, maybe as TG has actually been doing the longest, but.
How often is this change in the between application and review happening? Do you have any sense of that?
Um, I don't have a percentage, but it, it, it happens.
Yeah, yeah, that's expected. Yeah. Yeah.
Um, okay, I guess I'm going to have to think about that a little bit. I understand the trade offs here.
To some extent, I also think that we're trying to give applicant some level of certainty or opportunity to at least fit within what the limitations are. And.
It's a little difficult with the frequency of the update, I guess, but.
Okay, yeah, the other issue too that we're contending with is.
If we allow changes, you know, like multiple changes during the study process, then.
Is this, you know, we're running out of time right? We have we only have 15 days to complete.
Initial review within the term guidelines, so well, we're not talking about multiple changes. We're talking about when change to match the profile the new ACA. Um, but.
Could the utilities, like, when you start to study and you realize that the has changed can you just immediately before you start the studies contact the customer.
Uh, the IC has changed your, the 90% level is at another level. Now, would you like us to, you know, and provide that information?
Because you, you would have it provide that information to the customer and just say, uh, you know, would you like us to proceed with the studies? Or do you not want to proceed now? Because the levels have changed?
I mean, could that be no option somewhere?
That the, maybe or maybe the customer can save the values have changed.
Check box yes. Proceed with the new values.
Even though I realize that they may be less than the values I originally submitted.
So, the challenge Jose, is that, um.
The profile should we can't we can determine a profile for the customer, right? Because they're the ones that can tell us whether the new, whatever profile is being used for their project works for them. Right? So, I don't believe that we want to go.
Down the road of coming up with the profile, then.
The 2nd point is, you know, during the application phase, we don't usually know that the profiles different.
The engineer that gets the application.
Um, they have to trigger an IC area, they have to know for some reason based on projects that they've been reviewing, or changes through the system that.
This new is is required, right? So we have certain thresholds that would automatically trigger.
I see a rerun, but sometimes he has it can be a manual.
Uh, trigger so, and then the 3rd piece is.
It's not always instantaneous, right? So if we get a project, and we decide that we need to run it again for to get a new hosting capacity.
We may, we may not get the results on the same day. Right? It depends on what else is going on with the systems that are doing the ACA calculations. So, and then the other piece is also there's a workload issue, right?
So, it depends on what else is going on. Right? So, let's say the person doesn't get to the project until, you know, 3, 4, 5 days.
Since we got the project they asked for IC it to be run.
Then there's an issue with the tools, so they don't get the results back.
Now, we're pushing against this 15 day tariff requirement, right? So.
Um, you know, we got a report on the, you know.
19 timelines and this potential for this project or projects to be late. So that's why we would want to leverage the section that's already in the.
And then then we're more consistent with other projects as well.
Does that answer your question, Jose? Ah, yes, it does looking for the decision language.
As I thought the decision shed the a time of application.
You mean, or just the section.
Uh, no, I'll, I'll get back to you on this uh, when I, if, if I'm.
That's fine once the decision. Okay.
I'm also taking a look at the actual language general, 21 on how the update.
Of the ICF values is provided.
It's, it's not super clear. I think again I'm reading this really fast, but.
How you actually notify the customer that the IC has changed? I'm looking at section.
To a in the initial review, but I'm not sure if there's a section that defines this more clearly.
Yeah, I don't think there's any section that specifically talks about it changes.
In the tariff yeah, maybe I'm.
There is looking at it. That's what I'm saying here. Sorry.
Yeah, so it really does not it doesn't say how there's no notification. Yeah.
Yes, is pretty much.
Well, don't say there's notification that says distribution provider shall share the results of any.
I see it updates with the applicant, provide an explanation of changes.
Blah, blah, blah, I think, is doing is with the results with, with the initial review the results.
Doesn't actually say that, but maybe yeah.
Okay um, Jose to your comment, I guess the reason I was, I'm.
Struggling with this is and again it's really not specific to really, but.
Is that it's sort of unclear like when these theatres are changing, how often.
How projects actually do get to submit an application knowing what they're interconnecting under if we're kicking them out because the changed and not letting them modify around it.
They go back to the beginning of the queue and you're sort of repeating the cycle there but.
I I guess I need to think about whether.
There is a, I'm not really sure there's a good reason to limit it to the 20%. Um.
Per se, because it's really just an reapplication, um.
Like, what, Alex from your perspective?
In this context. Mm. Hmm.
Because you're doing it, you're allowing the change within the period of the of the initial review. Why limit it to 20%? I know. That's because that's what the tariff says, but we're here to talk about getting it, right?
Is there a reason beyond just that that's what the tariffs says.
To limit it when it's directly in response to the.
Well, I don't think that it, it it should matter whether it's or if it's a project using nameplate or using a different profile, right?
If we're going to, I mean, if we're going to change the rule, then the rules should apply to all projects, the changes should apply to all projects. Right?
So this is the, I think it has to do with impacts to other projects.
But you could have an impact to other projects where they're using the template where they are using the, or they're using a single value.
So, I guess to answer your question is, would changes under 20% would those be okay probably, but if we're going to go down down the road, then we need to make changes in the tariff that apply to all projects.
Well, we may or may not that's kind of what the commission will decide, whether it does or not, but you're already proposing changes to the tariff specific to that right here. So.
It says reduction in each hour of updated must comply with table at 1 and then it defines how that applies specifically. So if each hour, it may not be reduced more than 20%, which is different than what table 1 envision. envision
Yeah, but if 1 is already in existence today.
Right. So you're modifying it. We can change that sentence. Modify it differently. Just 1 is there, but we can add language. You're, you're proposing to modify the language. I'm not Alex. I'm.
I need to think about this. I understand why you guys are doing this. I also want to make sure that we're not.
Sending you guys through this endless cycle of re, looking at a project and and project again, and having them go back and forth. So.
I I just think this is understandable and.
Related to the complexities of the updates, but, um.
Need to give it a little bit more thought as to whether this is the most logical way to actually optimize the ability of applicant to.
Fit within the existing hosting capacity, it's not really that helpful to say well, it affects other projects they're all going to be impacted as well if the, by the same theory the changed if anybody else is in queue behind them, it will have changed for them as well,
so it's does that make sense?
Well, it could actually be, uh, projects that I had right?
So, if you, um, uh, think about this.
So, if you allow projects to reduce.
Actually, mostly projects that are behind, right? Because reduce more than 20%. Then if they.
There would have been any mitigations associated with that project then.
You know, this project, the project that's being reduced, may not have to bear those costs or indications anymore. So they may end up falling on a project that's behind them.
Right, yeah, and what I'm saying is that the, the projects behind them are going to be essentially being the same.
Bucket right. I mean, it depends on what they were proposing. They guess it's a project behind them is just proposing a very small.
Project the may not change their ability to pass.
So, when I'm when I'm yeah.
I think, you know, probably there could be room to make changes, but there's no other new 1 says, you know, days. So, like, the tariff would say, if you're going to be reducing your size, you can't reduce more than this size.
And then you have to accept whatever mitigations have been identified. So.
I guess if you're going through initial review and you identify some mitigations and the only thing that's.
We already know what else it needs to be mitigated and then Sprint and fails and the project says, yeah, we'll keep covering.
You know yeah, I think there's, there's probably a room to think about this. Yeah it seems like just the 20% thing is the part. I'm kind of stuck on.
Like, if the had changed more than 20% either overall, or within any hour, not sure what the benefit of saying is, you can go down to 20%. You could do 18, but not 22%. Like, what are we accomplishing with that? Here doesn't make sense. To me.
I don't remember I understand the later cute projects. understand the later cute projects
But I also think yeah, so let's give this a little more thought. I was. I'm happy to correspond with you further about this. I appreciate.
That the tariff already has that 20% language, and that you guys are trying to fit in with an existing process. But I also think.
It doesn't seem terribly logical to me to just.
Say, you know, pull 20% out as opposed to just letting the project.
Respond to what the current yeah. And I know that there's a lot of discussions that went into coming up with this 20% number. I wasn't intimately involved in those discussions, but, you know, the is, you know, if we say.
22% okay. Then, what about 32% and 42 and then by 100% right? Well, I think up to 100% is what I'm saying is they're just responding to the, um.
So, we didn't participate heavily in that the creation of, um, I assume it was for the reason you noted, which is.
Later key projects, but then again, you know, 5% can affect later projects. So it's sort of.
Obscure right maybe I'll check with Brad and see if he remembers.
Yeah, I my recollection is, I think they I use 1 at 10% and then stakeholders.
Settle on 20% or something I'll do my homework to, um, and see.
Where it came from, but I'm, I'm glad you saw the point that we're trying to be consistent with the tariff, and, you know, basically minimize changes. If we already have a framework that works, then we'll just fit within that framework. So.
20% is already there it makes sense to just within 20%.
Let me jump in here real quick. Uh, uh, just an observation that I have is, you know.
Um, it, it changes, uh, I mean, it's, it's, uh.
Dependant on demand levels to a great extent. And, uh.
They changed not because of, uh, any fault of the developers. So, uh, I'm, I'm, I'm just glad to hear that there's some collaborative, uh, thought going on between everybody.
But, um, I, I think this can be improved.
Yeah, thanks, Frank. Any other questions on this slide.
So, no more questions just circling back to my understanding is that you are going to keep saying this just so we're out there on the same page that you're going to take a look at these, this language in the context of the J.
Okay. Oh, N. P. and ideally you modify accordingly, especially, I guess 2 and then maybe whatever we need to do with that P language whether it goes here or above.
Is there anything else that we had said is going to change other than.
Digesting was 20% issue. No, that's all. I remember.
Um, and and then 20%.
Thank you.
Okay, if there's no other questions, we can move on to the next slide.
So, this next steps of slides are addressing topic C, um.
So next slide please this.
Graphic was shown last time during, uh, uh, last presentation.
What's changed here is, uh, the.
Staffing blue at the bottom, the interconnection study process.
Section right at the bottom. So that's what's changed.
And the reason this change is because the previous 1.
Was not as clear based on the language that we've discussed thus far today. So, what this is saying is that.
You know, if you pass screen, em, and you pass all other screens.
Then you can go to simplify the connection or inter, connection agreement.
If you fail a screen M, there's 2 things, you can either fail initial review and, you know, require the project to.
Withdraw and reapply if they do not address the screen and failure so that would be the profile right? So we just clarified here that.
If a customer passes all other screens, but they fail screen. Em.
Then they have the opportunity to to fix the issues.
That caused screen aim to fail if those issues are addressed.
And the project would pass would connect the simplified into connection, or they would proceed to in the connection agreement.
If they do not ask screen, em.
Then they would have to withdraw the project and reapply. So we already kind of talked about this, but this is represented in this graphic. So.
Just 1, clarifying question I think this makes sense. So.
If I think you told me this. All right I'm just confirming my memory. So if you fail in the other screen, then screen M.
You were saying that essentially any of those other failures could be addressed through that customer results meeting or is that not? Right? So, that is correct yes.
Even if it was a fault current release. Yeah. Yeah, exactly. So let's say, for example.
So, I already addresses protection.
Assuming that the full current contribution is 1.2 per unit right? Right. So.
If the project, let's say, for example, did not provide that, or there was an assumption that it was actually higher and that's why the project failed and during the results meeting the customer clarify say no, no, it's actually 1.15 then.
Yes, that would obviate the need for supplemental view. for supplemental view
Okay, so let me just what about the line configuration? The screen? Um.
I don't actually know what happens if you fail like, if there's what the fix is that screen so.
Engineers help me out, but I just want to make sure that.
If a project passes anything, other than that, we're providing them the right pathway short of the full study.
Yeah, so it's it's.
So the line configuration screen is checking, whether these.
Potential for overvoltage so, if a project, you know, the scenario where this could be addressed during the.
Optional results meeting would be.
If a customer was connecting to for wide distribution system, um.
And they, you know, if you look at in the tariff, and let's say the, they're proposing a project for our system, and they are gonna use a Delta high side Transformer.
And they would fail a screen edge, but during the optional results meeting the customer could say, well, I'm actually going to use a different.
Configuration of a transfer 1 so if they provide a single and that shows that showed this new transfer, if that was the only issue, then we would not need to go to submit for that specific screen.
So, my understanding Brian, I'm going to.
You up here is that maybe that screen isn't.
Using the most current understanding of inverter grounding capabilities and that.
That could be addressed through supplemental review, rather than just saying they need to do a different configuration. Brian. Can you help me out here?
What essentially what? I'm trying to get out it's, I'm not proposing to change the screen. I'm trying to make sure that it's appropriate to say they can't go to supplemental review and that every, I'm happy to have things addressed in the customer results meeting, but I want to make sure that we're, we're.
Thinking through what are the scenarios of types of issues that could arise and whether they all can be addressed through customer results meetings or if there does need to be an opportunity to go to supplemental.
Yeah, so just to clarify if we have a resource meeting, and we tell the customer which screens failed, usually what we tell them the reason why the screen failed. So.
Can you screen that the customer can address if they can say oh, no, this is not how this is, can be addressed, but we're not going to.
Not give him an opportunity to go to supplemental review if that's what they desire. So, if there's a screen that fails, that cannot be addressed. And the project will go to supplemental review if it fails.
But if there's things that can be addressed, then, obviously, if you can resolve it, there's no need to go into this additional study. But I don't know if that clarifies all. I think it does.
So, yeah, like I said, obviously I do want projects to go to, to get everything resolved in a results meeting instead, but.
Where there is additional technical evaluation required, um.
As opposed to a project, just changing a project so that it matches the screen or something.
Then I think that's the purpose of supplemental review, a little less clear on exactly what that technical evaluation is, which is what I was trying to think through what the screens are actually looking at.
Right. Uh, I think you asked Brian a question, right? Yes, I'm not I'm not clear if we need to address the grounding thing.
Directly, but, I mean, it could be potentially addressed in supplemental review. It seems as those are the pathway regardless. Right? So absolutely. Yeah. I mean, we, we do that quite often actually.
Yeah, so that's I think that's what I was saying. So I think as long as we're saying that they still can go to supplement review to resolve those technical.
Does require further technical evaluation. That's fine. What I thought you were saying earlier was, is that.
Essentially, nothing would would end up in there, but I think it could definitely be cases where a project might end up and benefit from being in sacramental review.
Um, even if it matches the screen.
Yeah, so the, the only time.
That a project would not be allowed to go to submit review is if they fail screen M, and they cannot address screen, it will not be allowed to go to submit review as an project.
Thank you.
Any other questions.
All right next slide please can we go on to the next slide?
Francisco, I'm sorry, I lost everyone.
You're still here you're still here, Alex? Yeah. Okay.
Yeah, just go next slide please.
Thank you. All right. Thanks.
So, this slide is talking about phase 3, the technical evaluation phase.
We have a series of questions, I think the next 4 slides addressing previous things that we had presented on with additional clarifications. So.
Sorry, go ahead, Alex. I just remembered a question I had on earlier. Slide. Do you want to go back now? Or do you want me to do it? Yeah, we can go back.
Francisco, can you go back to.
Let's see 1 more 1 more.
This slide so I guess I had a question.
For consideration of, so in 5 here we're proposing.
An explanation of how the process will go.
In a, just not just how the screens would be applied.
Um, you know, particularly in section by and number 5 here.
And again, I don't have a yes or not expressing a firm opinion, but I'm wondering if that's the right place to put this in terms of.
The process detail, I think what you're kind of getting at is more of that and I'm just sort of wanting to make sure that.
This explanation of how the project will be reviewed does it belong in.
And then 5 or.
Elsewhere in the terror for purposes.
Yeah, I think I think for for number 5, we could easily just said.
Modification rules apply or something, but.
Just because of the discussion, we want it to be explicit on what.
What actually what we're trying to do, but, um, is that what you're saying, Scott? Like yeah, I guess I was thinking, like, should this actually be in.
Or another part of where we're describing the actuals.
Process where the project goes through.
The steps of the project goes through if it's, um.
I think that the language that we were about to get to, which is why I remembered that I had this question.
Get to that, but, um, the concern again, we're, we're willing to this problem already with the terrorist structure but and then 5 is like, at the very end of the tariff and it was like this.
Thing that's supposed to be just about your controls, but then we're building in all this process.
Changes within it, it just becomes very confusing, but it may be confusing either way. Um.
I just want to make clear that, like, somebody's able to figure out what their process steps are in the clearest way possible.
Yeah, so I, if I understand what you're saying correctly, so, in in 5, we can just say.
Identify during optional results meeting as per section and then in then include this additional language.
I would say for projects this is, you know.
What's allowed? I guess it's 34 and 5 when.
Is there going to be another part of the terrorist that explains.
So, like, normally, screen M, would say, or a screen would say, if you fail, then you go to option 4 or if you fail, you go to screen 5 and and then.
There are existing if we're referring to an existing process.
Again, I'm not super articulate here because I haven't given it a ton of thought as to where else it would go. Why don't we go on to the other language but with that in mind, it's just a question of.
Again, I'm not necessarily disagreeing with the the process. I just want to make sure that wherever.
That is clear where the process steps.
Our best explained, and I, I see your point. So basically.
In screen, em, we'd have to add the language for projects and wait normally says, like.
If you if you fail a screen and go to supplemental review screen, and if you pass do this, and we have to add language, there are specific to right and then maybe it may be.
If you fail screen now yeah. Like, where, where does that cross that C section X or whatever? Is that.
For project is what it was. Okay. Okay. Yes. Yes.
Okay, thank you. Next slide please.
What was there any other question on that graphic.
Before we move on. Okay.
All right, so slide 15 please uh.
Next 1, so for this slide, um.
We are asked to discuss or clarify how customers will be given an opportunity to update the values of 1 or more values does not comply with 90%.
So, we wanted to clarify this is also.
Similar to the 12 already discussed before.
And we wanted to clarify that this, uh, our response has changed from.
The very fast response we provided in this section.
And that at this time is consistent with.
While we talked about before, so basically, uh, customers who fail.
Will be given an opportunity or to provide a new. They'll have 5 days to do. So.
They would not be allowed to have more than 20% reduction for any hour.
The not allowed to increase the values.
And then wanted to also clarify that.
If the reduction impacts screen D and the cost and timing or re, steady be based on table.
And then, uh, there's a scenario here.
So this scenario customer submits values with 1 or more values, exit, exceeding 90% of.
So the project would fail screen M.
Uh, the customer will be informed of the discrepancy during the optional meeting and then have 5 days to submit.
Revise the values if they submit those values within 5 days.
We will study the project and the initial review if they do not.
Then the inter connection request will be withdrawn.
And the customer could apply either based on input or just, uh, limited, uh.
Export so.
I, we've already talked about this previously, but if there's any other questions, please, let me know.
Is the 5 business days the same amount of time that's in the material modifications.
Or, I guess there isn't a time frame there, right?
These are material verification, but there's a time in.
Well, actually, the time it needs to be is just for to convene a results meeting, but we are proposing actually adding this time for, uh, submission of a revised profile. So, this is gonna be a change to.
I'm just quickly looking it up to the.
And obviously we may actually add it to instead I don't know.
Yeah, um, what I'm just contemplating is 5 days is pretty fast, but I also appreciate the need to keep things moving. Um.
I don't know that we actually have any.
Project developers do we have any project developers listening today?
Yeah, the reason for it.
The reason why we chose 5 days sky is because I believe these other sections in the tariff that govern the additional information requests, and they all have this 5 day timeline. So.
That's not quite just additional information. It's actually having the project redesign be redesigned essentially right?
No, it's just a profile it's just a it's just a new profile.
Right. Which may require some economic analysis to determine if the new profile is viable. Um.
Again, I understand that there's some value to moving fast here so.
But it's not just a, it is just a profile, like, actually updating the numbers is easy enough. But the decision of whether it makes sense to proceed, or is viable is a different, sort of a different.
Consideration I'll just take that back and give it some thought. Um, I, I appreciate you guys putting this language together and.
Maybe that that's what applicants have to live with.
Yeah, uh.
I understood, I didn't mean to minimize the they are the impacts, but I was.
I was assuming, you know, my limited knowledge that.
Customers would already know, like, you know, the constraints, right? Like.
Anything under 1 megawatt it doesn't make sense, you know, something like that. So, but.
Thanks for the additional because we, it's going to depend on.
Well, okay, so this is wait. Yeah so, under this scenario, where they made a mistake, I'm not sympathetic again. You can't see me, but I'm doing air quotes there for mistake, but where the had changed.
Is the scenario that I'm kind of thinking about kind of goes back to that earlier problem I guess, but, um.
Yep, we'll think about it.
Yeah, I echo skies concern on the 5 days, just because.
As we get into more, um.
Storage couple generation systems unlimited under.
Not billing the.
It's a multi variant optimization to understand what's going to work under that scenario. Whereas before.
Before they changed, the name was a little.
A little more straightforward so I echo the concern on the 5 days, but I also.
Excuse me maybe raise my hand.
Was the reduction of more than 20% and I don't understand why.
Why we're eliminating the reduction and share skies conservative.
If the change in ltp is coming out of a change in values of the customer.
Could not have anticipated.
Getting to an that meets the new.
May necessitate more than a 20% change, so.
I don't know if you can speak to that, but Alex no. Uh, uh.
I think I think I need to take this by Justin. Um, we, we settled on 20% because that's the current, um, percentage included in the material modification section.
Of the tariff, but, you know, I understand.
Sky's concerned and your concern. So what I'd like to do is take this back to the team and have a discussion on.
You know, do we need to align with that 20% or is, uh.
Is there I need to come up with a different number or allow an unlimited.
Reduction and, you know, that sort of thing so yeah thanks. So I, I think that the.
Um, if.
To expect you guys have been doing this.
Where a customer applies into the just a plat limited generation profile or limited export profile or non profile or whatever.
I'm curious just there may be some insight from what the reaction is under that language that where you come back and say, actually the has changed, as you said, this does happen. And so, um.
It might just be helpful to think about what has been happening when you notify a customer that the has changed. Are they just withdrawing.
Or are they proposing modifications or how is that being handled?
In general, because, like we talked about the language and the tariff isn't terribly clear right now, it says you have to notify the customer and provide the reason. Um.
Again, it doesn't say specifically within the initial review results, but I think that's a reasonable interpretation. And that.
I just said, well, what what are people doing when they get that answer today?
Yeah, so yeah, for projects that are using, like a single they, if they fail initial review, then they will proceed to supplemental review. Right right. And usually it's.
It's not usually the, the, I don't think there's any.
Um, there's been any issues, uh, meaning that.
Customers are not questioning why.
Why did I go to supplemental review? Because the understanding is that we have an ability to.
Calculate updated IC values. Well, it's also because you're reviewing them under thunder. M right now.
Right, exactly. Okay. Do you guys have.
On that point, do you have proposed language in here for screen em, because we are going to have to.
I can't remember if we looked at that already, we are going to have to clarify that screen M is applied differently for right?
Yeah, we do not and yeah, you call this earlier so we'll have to come up with some language at least clarify what happens for. And then what happens if you fail, we have to include that language in.
Right. So, for in specifically that it's not that it's applied using s. G. instead of that, right? Exactly.
Thanks any other questions.
All right, so next slide please, uh, this is also some clarification that we will ask to provide.
So, clarify how project is studied if customer does not respond within 5 business days, or being notified.
That the does not comply with 90% of at each hour.
Um, was asked to.
Correct its language to reflect at or below 90% instead of only below 90%.
Um, the response is confirms that it it will make the change.
And then we also, this 2nd, paragraph is sort of related to the previous slide.
And we were saying is that the previous language that was provided the response that was provided under 3 D.
At 3, um, is not valid anymore and the.
Previous slide and the process diagram that we already covered is the new process that I use are proposing.
And then, for this next 1, like, I use should also clarify any additional changes required for this step.
Based on the outcome of discussions towards resolving issue 2 and abide by previous direction regarding material modification.
So, we're not proposing any additional changes required in reference to issue 2.
And then we're also not proposing any changes.
As far as much notification 521 at this time. So.
If we do go through and make changes to then.
That will be new, but at this point, at this time, we will not propose it to make any changes.
Any question Justin is do you have your hand up now? Or did you forget to put it on.
Sorry, I forgot to put it down any questions.
Okay, there are no questions you can move on to the next slide. So this is still under the technical evaluation phase.
We're kind of clarify when customers.
Do not need to respond within 5 business days, uh, but still request into connection and justification of the 5 business days. So.
And then the 5 business day, um, we mentioned before, and I've also mentioned it today that.
It's used in other parts of rule 21.
So, for example, E5, but be, so that's why we felt like this was.
It made sense to use 5 days, but, um, if there's.
On sans, and I'll take it back to the team and see if we can.
Clarify why we would want to maintain.
5 days of we're able to adding additional time.
And then, so the 1st, part of this response is just clarifying that.
The previous response is outdated and.
I will provide it today is the position are you position moving forward?
And then for 3 D5, um.
We provided additional statements that are applicable to.
All 3, so they tools and or enhancements to existing tools will have to be developed to efficiently valued projects.
These tools, the software hardware or enhancements necessary to efficiently extract the most updated profile.
Input the customer provided LGB profile.
Compare each hour of the profile and determine if the profile or the project meets the criteria of each hour.
Additional enhancements to planning tools and process may be needed to enable efficient and automated integration of into the interconnection process.
In addition, distribution, modeling enhancement will be necessary to reflect the projects.
And then once an project connects.
A unique output profile must be stored maintained and referenced consistent planning.
In the connection, and during ICS studies.
So, this, this is just going over what enhancements the I use feel unnecessary to efficiently or effectively deal with projects.
Any questions about this.
Do you guys have proposed time.
So, we know the changes need to be made. I guess the commission is going to need to know how long you need to.
What you're thinking about how long it will take you to do that from when the commission.
The order or the resolution is issue, right?
Yeah, I think, um, speaking for PG E, we're proceeding with the understanding that LGB implementation is 9 months after.
Forget the exact language, but.
Um, essentially, 9 months, let's say, 9 months after the.
Yeah, you think you'll be able to do it within the 9 months essentially that's the plan.
Um, I would not that.
You know, for those who have looked at the PG E results, they downloaded the results right now they do include.
A column that, uh, has the.
At this time monthly, I see your values so.
So, basically say the minimum of.
All the hourly, you know, ESG values. So customers can basically look at that but of course, you know, if we're gonna go to 288, then.
Different values, and that would require additional changes, but if it's 208 values with.
All of unique values, then that is easily identifiable on the.
Downloaded by results today, uh, for the PG E.
Well, for all the utilities, it includes the full 28 gate profile.
Yeah, well, I think the, we're proceeding under the understanding that we'd have to do 12, and we will try to simplify it.
Right. Okay so I don't know if you want to.
Chime in on the timeline for system tools changes.
Yeah, thanks, Alex. This is Michael at. So the response we got from our internal teams that are developing these capabilities, gave us the timeframe of 2025 quarter 3.
With approximately 60% confidence in that timeframe. So they're still working on documenting the capabilities and adding them to the road maps and evaluating the work. That's going to be needed to implement them. But that's not to say that.
We're not going to be able to do this until that time frame, we would utilize, you know, manual mechanisms where we need to to comply with the 9 month timeframe. Uh, with that time frame, 2025 refers to is when we're starting to see a more automated, more efficient approach to these projects.
efficient approach to these projects
I'm sure if there's any question from Michael that, uh, this is, uh, I think we talked about earlier, uh, given the number allocation typically get as a smaller amount.
We're planning to mostly just handle it in our existing process with the addition of some Excel sheets and possibly automation, depending on how many profiles we'll have to evaluate and how many points.
Et cetera, and obviously open to exploring a further if we get more application, needs to further advance efficiency.
Thank you, Michael. Thank you. So, are there any questions.
So, in conclusion, what I understand is that each of the utilities believes that they will be able to process interconnection applications for within, or by of the 9 months.
Deadline whether you're you fully updated your tools, or you're doing it on a more manual or.
Process, but that you will be able to.
Start processing the GP applications after 9 months.
Thumbs up. Cool. Thank you. Thanks next. Slide. Please.
Can we go to the next slide Francisco? Thank you.
So, for this slide, um, this is in phase 4, which is interconnection agreement PTO phase.
Uh, discussion below provides clarification.
Of the requirements for filled performance verification.
Uh, relationship to certification testing and.
The process for developing commissioning test procedures so.
I think during the last presentation, there was a question that I had to do with whether.
I use a requiring additional.
Testing or commissioning for projects above and beyond what's required for other projects. So.
We wanted to clarify, uh.
That the purpose of I use field performance verification is to verify the operational performance performance to ensure that they install equipment.
Has been set to meet the intended, need, configured and configured consistent with the customer proposed values and the operational requirements of role 21.
So the main thing here is that, uh, feedback or response directly to what Justin had.
As I use is that our testing or commissioning will be consistent with row 21 section.
Um, we will conduct field performance, verification, commissioning testing for projects.
Consistent with how it is conducted for non projects, including remote, remote inspection, if permissible.
And we would follow what was already approved in.
The SC, PG E, sdg advice letters that are listed on the screen.
Any questions about this? Yeah, we also wanted to clarify that.
The full performance verification, commissioning tests.
Differ from the certification testing in that these are operational test for equipment that have been installed in the field.
As opposed to lab tests, using to verify that the equipment.
Being tested meets the requirement of the standards such as.
I triple a 147 or you are 741? Um.
So, we're talking about field testing rather than, you know, lab testing.
Alex, what are you doing today with.
Projects using PCs. Are you field testing all of them?
No, we're not testing all of them. We are testing a select number of projects.
And then once we, once we verified performance and any subsequent projects, using the same equipment for the PCs, we don't test them.
Okay, so do you anticipate the same thing once you've tested a few with the scheduling that.
You won't need to do field tests for all of them.
If we exist if it's the same piece of equipment yes, I anticipate the same fall in the same process.
So, if the PCs is satisfied to a U s standard.
And we perform verification for an agreed upon number of devices or installations, then, which we should not be able to. We should not be required. We should not require testing for subsequent installations.
Any other questions.
You need is that consistent with you as far as testing?
Yeah, this is done with us.
Thanks Alex. Same.
Okay, thank you. All right so.
There are no questions for this other section. Like, the question was sorry back to the previous slide. Please. Sorry?
I use check. Sorry was that question?
Yeah, it sounds like you try. Are you.
Tests the 1st of each type of equipment.
Do the share with each other which ones they haven't haven't tested it.
Seems that, I mean, it seems that testing for function something that has been certified to function as.
It was a bit of overkill, but I, I understand why you're.
Doing that, but testing in it and all 3 seems a bit wasteful. I don't know.
If you share with each other manufacturer X model, why.
As faster or commissioning testing and, you know.
Need to run that with the other 2.
Yeah, so in the past we have shared information.
What happens is, sometimes we get projects that come in. Let's say we, all 3 get a specific.
Around the same time, right? So if we have customers that.
You know, want to proceed into connection and then now willing to wait then.
We may not be able to wait for, you know, for example, if you need to complete the testing before we can issue PTO for up for the PG E customer.
So, in those scenarios, then we may we may end up doing testing at all 3, utilities differently, the same time, or, you know, close together. But if we have a project that's already connected.
In 1, then we may be able to leverage the testing.
By that answer, I was going to add a little, but.
Go ahead. Go ahead, Gary. Gary, it is. Um.
It's still it's incumbent upon each utility to.
To feel comfortable with their testing procedures, so.
They should be sharing best practices for sure.
But they don't necessarily have to be the same.
Let's make sure we understand that. Yeah.
Agreed yeah, I know during the.
You know, unrelated notification, only process. There was a discussion.
Of potentially maintaining a list across the use that could be shared.
Um, for so I kind of answered that question.
Based on knowledge of the previous discussion, but you're right Gary.
Are there any other questions? Okay.
So, for this for this next section, um.
We wanted to clarify that field performance. Verification, slash commissioning test will ensure that the project is set up to comply with requirements.
And that we already addressed the issue of.
Quarterly reporting, uh, in previous discussions and.
We would like to clarify that I use will use data and telemetry for projects greater than or equal to 1 Mega to verify performance requirements.
And then the last point is by section 21.
Read the question, so PG states that it will review discussion or discuss and agree on the verification process procedures.
More clarity is needed, whether this is only at PG discretion, or it, it involves the customer should lc and also adapt similar language when aligning the process language.
They should also, they shall also abide by this requirement.
So, we did want to clarify that our rule 21 sections I use may require written commissioning test procedure to be provided by the interconnection customer.
10 days in advance of the commissioning piece the.
Coordinate with the customer on the development of the commissioning test procedure.
Any question on this clarification this is the same as the language that's in the already you're saying.
Yeah, it's already a section 5 in the term that covers commissioning.
Test requirements. Okay.
Procedure and so how do you do this today? So it says I use, may require written commissioning testing procedure. Do you.
When do you typically require that? And how do you think that will.
Be the same or different for. I don't think it will be different. So typically, what happens is if we, if we get a project that comes in.
That's using a controller or PCs, you know, we would ask the customer to provide us.
I just procedure that, you know, basically test the function of the PCs or if it's something that's limiting export or.
Limiting import then they would say, you know.
We would, we're gonna if they're going to use that, if it's going to be a live test, then they would essentially detail.
What what system's going to be on the PCs? What's going to be on if it's, you know, PV, storage, customer loading what brick is going to be opened?
And when how they anticipate the PCs, uh, reacting to that, right? And then.
It would cover things like communication and our tests.
A communication, failure of communication, so they're using communication to reduce export then we would.
Test what happens when they lose communication and essentially, where the process works is customer would provide us with a description of operational. Let's say this is how the system works.
You know, if we have export values, exceeding X, this is how the system's going to react to reduce the export to.
And they approved export limit and then.
If we lose communication, this is how the system's going to react it's not going to export anything. It's going to cease to operate.
And then, once we get that, we would review it if it's something that.
You know, make sense then customer would either in addition to that, or at the same time, provide us with a.
Procedure that essentially verifies what they've detailed in the description of operations.
We would review that procedure if we have enough information and, you know, it looks like something that can be verified in the field. Then we would schedule.
Uh, inspection or weakness testing.
And then that testing would be to verify what the customer says the system does.
I don't know if I answered your question. Sorry? I guess what I'm understanding from that, and I'm not pushing back.
I just want to make sure I'm understanding is that essentially for the is going to be a little bit more complicated because of the profile to come up with the test procedure.
Is that a correct understanding? I, I'm not sure that it's going to be more difficult. Uh.
Maybe the testing, because I'm not sure if we have 288 values, whether we would want to test all 208 right?
We may specify a certain number of hours to check to verify that the whole profile would work correctly, but that's still TBD.
Um, yeah, I guess this just seems like 1 of the ones, you know, once we get out in practice,
that it might be helpful for the once the utilities have done a few of these to be able to provide good guidance to customers and what they're looking for if it turns out to be.
You know, what they, what they actually want to have tested, but I guess that the tariff already provides for that opportunity. But so every customer is not having to go through the same back and forth learning curve will be good to here.
Yeah.
And for what what it's what we usually provide customers, like a framework of what we're looking for. Let's for PGN. You would say we need we need.
You know, this won't tell him, we wouldn't give him the test procedure, but we'll tell him, like, you know, this is what we're looking for based on your.
You know, a description of operation, we want to check X Y, Z. so, tell us how X Y Z is accomplished kind of thing.
Yeah, that's helpful. Thank you any other questions.
All right, thank you very much. All right. Thank you. Alex.
And, uh, so I think before we move on to topic key, it's a good time to take a 10 minute break.
So, let's or 9 minute break. So let's be back, uh, here at 1130.
And then we'll resume the key.
All right I'm just making sure that, um.
Utilities are back can I get confirmation from the utilities? Please.
Michael's here I'm here. Hey, Michael.
Was starting on topic E who's a presenter?
It's me, Jose. Can you hear me? Yes, yes. Oh, okay.
I'm not yelling again right sorry for that, right? Yeah, yeah. Yeah.
All right perfect. Uh, thank you. Francisco.
So, I think, uh, 1130 sharp. So I think we can get started.
It sounds good Francisco if you don't mind goes to the next slide.
So, as a recap, we already start talking about the different kind of options for a topic. E.
Uh, just a clarification aren't, you know, early slides.
We didn't feel like there was a ton information between workshop, 2 and workshop 3. so.
Hopefully today can be an open dialogue on collecting more thoughts on this topic and if needed, we can further discuss this at the.
Sidewalk discussion this Thursday, but just to provide a recap on what was previously presented by Roger.
Based on industry member inputs, which Thank you very much again.
Uh, essentially we discussed, um, 7 options, including the, uh, PCs with integrated schedule, which was the original.
Well, that was specifying the resolution.
So, just to connect the dots as far as what Alex was presenting earlier, part of the.
Option 5, and the option, the new option 12.
That corresponding with the green 1 in this table, which is the use of.
With in the greatest schedule, obviously a few other options, which involves PCs device also is dependant on.
Pts, the answer is being available, but, uh, just want to point that out. So.
It's clear to folks that that's what's that about?
So, as a recap, in summary, we have 3 operational option 1, 2, 3.
And method a through method.
So this is my understanding of previous discussions. Yeah. Workshop, and maybe some follow up conversations, uh, between team and the industry member.
It appears that the most practical master slash option is still to use the standards with integrated schedule,
which means I'm talking about the number method g option 3 in this table.
So, as far as the timeline update, our understanding is that right now, uh, the team is still on track to finish the standards by the 2nd, quarter of 2023 again.
I know a lot of folks who are leading that is on the call so feel free to jump in uh, if you feel. uh if you feel
Oh, you went on mute. Oh, don't know what happened. I guess I'll mute myself.
So, it's just you forgot where I mute myself. Really? But what I was saying is that.
I heard you the whole time you and I don't know if others heard I didn't hear you, you.
Okay, maybe Francisco caught me before I keep going. So thank you for that.
Just a recap because that based on what we're hearing, the standard is actually being developed and anticipating to be completed by the 2nd, quarter of 2023. we felt it's still the most practical approach to implement. practical approach to implement
Waiting for the standard to be available. So, with that, I'm gonna pause and see if anybody has any question or wanted to jump in and add some additional thoughts here.
So this is guy, I guess, um.
I certainly agree that methodology should go in the roles as we've discussed about. Um.
I'm also interested in making in making sure that we discuss.
Whether it's possible to do.
Any of the options that do not require a.
Because of the size limitation issues for those, it looks to me, like, those would be.
The message the operational options number 1 is that correct?
A little more than that, but before we go there sky, I just want to key on the size limitation issues.
So, I'm not a technical expert, so I was asking a few others after the workshop discussion. My understanding is that the PCs is designed in a way to allow.
Sighs no size limitation whatsoever.
So does it is there actually a size limitation issue with the PCs standard?
My understanding, and, of course, the engineer should speak to this. 1, to me is not that the PCs has a size limitation.
It's just that the way that the projects would have to be configured, they're likely to use multiple devices and so getting the certification for the whole system is the problem once you get above 1 megawatt.
So, this certified concept is problematic. Brian did I characterize that correctly?
I think so. I mean, it's basically it's just that.
A larger system might be more likely to use.
More equipment that may not be certified together because if you use a PCs.
If the PCs were a separate box, which it may not always be, but it, it might be a separate box that controls inverters.
And you may be more likely to have inverters from manufacturer a plus inverters for manufacturer. B.
Especially if it's a PV plus storage system, that is AC coupled. So.
Those aren't, they won't be certified together unless, you know, the manufacturers work together to get those things certified together. And so there's kind of infinite combinations that 1 might have to certify.
Right. Is there a way that could be worked around in our work here by doing additional testing and, or commissioning simply of those systems if the utilities were open to that?
If they've got maybe exposing my ignorance on exactly how the certification for the PCs component works, but.
I know that that's what I really do think we need to spend some time trying to figure out options that are safer reliable but also, um.
Feasible for those larger projects, and I'm wondering if that issue of having multiple different inverters or something could be.
Tested in the through the commissioning testing process.
If not viable, uh.
So, yeah, you could you could have a non certified.
Quote, unquote, power, control system that works. That does all the things that, you know, we want it to do.
And it's not certified. I don't know if you're asking if I was asking is could you use a certified +?
Additional inverters, or how does that work? Like, is there some middle ground between an entirely non certified PCs?
And again, I, I just, I don't understand that. There's not enough. That's a silly question.
I, I would have to ask the manufacturer as whether there's any likelihood of.
Cross compatibility, but it it seems.
At least 50%.
Unlikely that you'd be able to take a PCs from manufacturer and make it worth with inverters from manufacturer be.
Um, because some of them may be using similar communications protocols to accomplish the PCs function. Maybe that's a possibility.
But it may equally be a possibility that someone's just using other.
Methods to accomplish that and there would be no way for somebody else's inverters to work with that.
Okay. Um, so that was.
Does that just that basic explanation of why what the size limitation is makes sense to you?
Not exactly so just let me let me make sure I understand. I'm also not clear. What what was.
What Brian was describing as alternative to.
Is that matching any of the methods we're discussing here? Because.
Looking at, like, Mr. A. through f which are outside of G. right?
Each of them will still require some sort of inverter with.
A Gateway testing, right? And it looks like you're gonna have the same issue where you use multiple inverters you have to make sure the gateway.
Or a server also work these multiple.
Right How's that not an issue with the other approach?
Uh, I'm not sure if I followed the question, but there's.
The, the, the methods that are spelled out here.
Are utilizing community.
Communication protocols that are.
Well, specified basically and so.
You can leverage those to talk to any inverter system that has the ability to.
Bring in those communication protocols.
And, yeah, so they're therefore you're kind of.
You can talk to that's the whole reason why 547 specified these protocols is that you'd be able to talk to manufacturer A's inverter in the exact same way. You talk to manufacturers.
And murder and so, yes, that that could be done. It's.
I mean, you're essentially doing the same thing you're setting up a power control system, but you're using specified communications.
Methods, so.
Yeah, if we were to implement 1 of methods a, through f.
Maybe we would add on the methodology, but the, the thing that I just described might be somewhat similar.
To 1 of these methods as well, you've got a server or you've got something that stores.
A schedule and it sends out power commands to inverters and those are the essential ingredients.
And this is doing that the method a, through f is doing that.
And on top of that, specifying what communication.
Um, protocol must be used, right?
Suggest this just to add, I think the difference is method g, if you are doing above 1 megawatt and you using multiple in waters, the schedule is stored in the.
And the through communication protocol to all the inverters and 1 to, or 8 to f, um, the schedule is coming from a server.
To the gateway, and then the Gateway is doing the same thing. So.
The main difference is 1, is how are you getting the schedule.
And who's storing the schedule? So, um, but the communication.
More or less pretty much. Would be the same. So.
Ideally, if you have a method g that supports, like, John's.
Chatting if it gets the schedule from external sources, it would be the same as a.
Protocol the PCs gets the, the file through an external interface and can be uploaded.
Can you can say that it's as well as the PCs plus gateway.
Okay, I'm, I'm a bit slow. So, let me see if I actually understand that. So what are we saying is that.
It sounds like the master g, which is in use of with integrated.
What work and there may be optionally for incorporating additional flexibility in future revision to allow.
Primary control here the cloud am I totally crazy saying that our.
I'm just trying to understand, you know, before we.
Say that there is other option trying to understand what problem we're trying to solve and.
Is it 1 of those methods is better than the G, which is what are recommending we continue with.
It's not necessarily just I'm not just we're not saying 1, only 1 method is should be used. We agree. The should be possible. We're looking at whether we need another method. I would say.
But is it because the existing method definitely doesn't work or is there just it's just complicated to get it tested, which may be.
The same scenario for any of the other mess or 2.
Yep, that's what I'm trying to explore with you here. Yeah, I'm trying to understand. So I'm looking for help, like, funding this Jasper on like, what exactly is the issue and what we're trying to solve here.
Yeah, I think about 1 megawatt, even with the PCs, you end up with having multiple inverters. So the.
Uh, the PCs will have to send commands or communication protocol to the inverters. That's, uh, and these are certified in motors with certified Protocol interfaces. Like, as in the.
A good. F, right so they are.
Certifying water, so you can send command, um, for export limit. The PCs can sign with a schedule store and stored inside. So, um.
So, the issue is, as a science increases.
You don't have like, 1 in a greater.
Solution that does you still will end up in an architecture that is.
Similar towards describing a. B. C. D. so.
So, that's kind of the issue. Um, and so you have to use the communication protocol. I certified.
Slip into phase to send commands, um.
To make the whole thing work, so.
What Brian was saying is that we don't have like, 145 that will meet the requirement. It's still allowed to send commands to meet a measurable 1 megawatt. It is doable. It's but it will look similar to 1 to ABC or.
one to abc or
Yeah, and so what, I guess what the effect is, is that the.
Um, the testing for certified systems is done as a type test so it's done.
You know, for 1 piece of equipment that represents everything that's ever going to be shipped, right? Or everything that's going to be put together in a, in the field. Whereas there there are going to be instances where you could come up with a design.
That does not fit any of those tested scenarios and so that would shift the testing burden to commission in rather than.
Um, rather than type testing, you know, perhaps some.
Desk level evaluation, plus commissioning, but in general, you know, that's what it means. If you can't have something certified to fit a standard then that means.
You know, you need to do the testing elsewhere that, you know, typically just winds up being in the field at commissioning.
Right. Are you able to maybe like, similar to what.
We had previously discussed, you know, in the last workshops. Are you able to, like, draw the architecture outs or, like, explain that to.
To the group here like I mentioned, we, we didn't really have much to present on this topic.
For today's workshops, so it's going to utilities are open to.
See, that if you have additional information, because based on what we know so far, we, we don't feel like there's.
Uh, needs, or there's enough sort of driver to explore additional.
Alternatives.
Yeah, I could try to draw something up. I mean, um.
I think the the other options have been well explored.
And I guess what we're saying is that we just need to continue down the line of potentially exploring the other options as well as, uh, PCs.
Just to add to that, I think, in the, um, diagrams that Roger may or June.
If you replicate the gateway with the PCs and the.
Export monitoring from the, like the sorry, the BCC collect the export net generation data.
I think that would be the architecture so it's pretty much the same architecture project name, but yeah minor changes.
Now, if we didn't have BCS architecture, where, in which you have multiple models that you.
Dealing with sorry what what it, what equipment is going to be monitoring.
Add the the so the difference would be that, uh, the pieces will still be monitoring and the PCCC, but there will be still be multiple inverters shown in Rogers.
Diagrams for that will be the, and the PCs will be connected.
Through protocols to these multiplying order steps would be pretty much the.
John John. Go ahead.
Yeah, um, I, uh, I put some notes in chat.
But, uh, PCs does not allow primary control to be done.
Through the cloud specifically prohibited.
So, the controller that's actually doing the primary control.
Must be at the site that is not to say that you couldn't use a communication base method on site.
It also does not prohibit the scheduling function to occur in the cloud.
But the actual control of the export moment must be at the site.
The specific requirement, so, um.
The other issue would be, how do you evaluate the equipment from different.
Vendors today within New World, you have to specifically evaluate that equipment and type testing.
There are there are options for fear bursting.
Where you take a equipment from manufacture a, and.
Uh, different equipment for, uh, from manufacture B, and you evaluate it at a given site and you get, you would get a PCs listing for that site.
But that that listing is not transferable.
It is for that type only I need it if you were to take the exact same combination.
Of equipment and move it to a different site you would have to do another field listing for that 2nd site.
Or 3rd type or foresight.
So I, I only, I don't see an easy way to do equipment from multiple vendors, other than onsite commissioning testing, or field listing. And both of those are a bit.
Um, uh, uh, difficult the.
You know, how are you going to run a variation and load test? I guess you'd have to bring a big load bank out.
In order to evaluate the operation of PCs so.
It's not trivial. It's not easy. Also, John if the PCs is receiving schedules, um, like from a cloud or from remote, then should it be also certified.
Because it's getting schedules remotely.
I understand a controlled by buddy. So, remember that response time is a critical element here.
So you can't just say, well, we have a communication system.
And it supports this protocol and something else supports the same protocol. So, everything is fine. You have to validate the response, right?
So, I guess, um.
The, uh, site testing would be primarily for the client. The person who owns the site once the PCs is certified, because the.
Would be certified to manage whatever is within the site.
So the site testing may not be needed by the once they're comfortable.
With that the PCs is truly compliant and certified.
I I think that's the distinction I'd like to make.
Yeah, Francis, uh, however, um.
The PCs control function, wherever it may reside.
Has to be evaluated with to quit and it's intended to control.
You can't just say, well, I have a controller and it runs a PCs function.
And sends out my voice commands, and some other device receives my best command that may all be well and good, but you can't get that certified at the normal.
You would have to test that controller with the specific piece of equipment that is being controlled.
But is that needed for the use because all their.
We lost your Francis. Yeah, we can't hear you. Francis.
Not sure if you I mute it. Can you hear me now?
Yeah, go ahead. Okay so again, I, I'm separating out what would be needed by by the noodle testing it for the DC for the client.
As opposed to what the I O, use need.
Uh, from the PCs, and if you will, 741 is.
Uh, good, uh, it should have any default actions taken by this PCs. Um, you know, with the, um, the equipment within the site is not operating correctly.
So, again, so I think there there are 2 different things as.
Trying to say, yeah, if if you if you type test it, then.
Equipment from manufacturer equipment from manufactured B, they reevaluated to work properly together.
You can't then take equipment from manufacturer.
Fee and say, well, that works as well. That's not how tight testing works.
So, that would not be an option and at least what we looked at earlier in the proposed modifications.
Uh, to, um, uh, the terror.
It says it has to be, uh, listed.
So, if we want to say, well, it has to be listed, or I use, can do their own own on site testing.
Um, we'd have to go back and modify this stuff we saw earlier.
Because I saw what it's like now, John, the 4th time is for the PCs to react.
Right. Or or is it the communication how do you define that? 2 seconds?
Hang on, I need to put it on my headset. I'm having a hard time hearing just a minute.
I can answer that the 4th time response is that the power is actually reduced within that, or reduced within 90% of the total change within that amount of time. of time
So, the entire communication system works as well as the power electronics take action.
Or complete their actions, but it's, it's from what trigger what triggers that, like, from an minute, monitor something on the and then.
Sense and controls it to bring it down in 2 seconds as our.
Right from the start of the inadvertent export condition.
Okay, so in schedule, the scenario would that happen? Because you're any way schedule and you have the.
Um, so that's.
Technically though, yeah, how will it happen in the schedule scenario? Because you already have scheduled it, you know, ahead of time. That would still fine. Yeah.
It's not, I mean, it's not a problem for changes in the schedule. It's just a problem for the limit.
Maintaining the limit itself. I think that's what John John was pointing out. Is that.
You've got if you've got 100 vendors on site that you have to communicate with to reduce power in real time in response to changes in load.
That may be more challenging than doing that with 1 or 2 inverters basically, in order to stay within that 4th response to it. to it
Okay, so yeah, it's not not the changes.
In the values of the schedule that is concerning here.
And the excursion on, or the changes, um.
Beyond 2 seconds is a, does the regulation says that? Is there any requirement on that? Is that similar in 2 seconds to 3 seconds?
Merely by way of communication delays does that mean that a client is a.
Um, not combined to L. GP.
Or the MVP, like, since it's data, you're monitoring.
There I think you're, you're looking at more of a aggregated 15 minute data, right? So well, let's.
No, so so this is Alex from PG. E. so the data that we're leveraging is only for us to be able to confirm the export value.
After the fact, am I, information or system has nothing to do with, you know, uh, in real time, right?
So, the requirement is that the is able to control the open loop response time, which is what Brian just, you know, defined a few minutes ago. Is 2 seconds and then time to steady state is 10 seconds.
So the has to be able to control to.
Ah.
10% within 2 seconds and then 25% a lower within within 10 seconds.
Okay, so the, uh, option, um, uh, 1 and 2, since there's no load is not included this because anyway, the next generation will be lower than the load.
The issue this issue is not there only when it's BCS monitoring the.
Control ensuring that between the load and the generation we won discussion, uh, the the control to be within 2 seconds. You need to make that timeline.
So, I think option, uh, method C is the 1 that.
Let's see was more conservative, right? Because it's measuring at the inviter terminals, but there's actually loading. So, the assumption is that that number is going to be lower than what would be exploited. Yeah.
Yeah, so all the, I think both ABC D. F. all are measuring and we voted on.
Yeah, no, a BC invalid terminals. D. E. F. G.
Okay, yeah, yeah. So ABC there should be a problem.
Shouldn't be a problem, but, uh, so for, let's see.
Yeah, it just depends on if there's no loading on site and you're, you're basically setting the export limitation and measuring at the invited terminals.
Then they will be the same value minus any losses. You still have the issue, right?
Because if you, if you, if you lose any loading, then you may end up exporting more than you're supposed to. And then it just has to do with, you know.
What the difference is between what the terminals are measuring plus what's going across the, and then you have this.
Time when you have to react and reduce it to that export limit.
So, I, I, I don't know if I'm prepared to say there's no issue. Um.
No, sorry, ABC, you're not measuring load.
So you are, if those load, it will always be lower than it.
Yeah, uh, but since you're not measuring low, um, you just setting the inverter violence to whatever is the.
A GP value, so you always be at the value or lower.
Because you're not measuring low. Yeah. The assumption that I think is that the reason load on site, if you don't have any loading on site, then even.
Yeah, even then you, you're still not considering Lauren ABC at all. So you're just setting the inverter output value at the.
It should be yeah, but the issue, I guess what I'm pointing out is that if you have no loading and you're measuring the exports are invalid terminals,
then what's flowing across would be that value less any losses between that point in the BCC. Mm, hmm. Yeah. Right.
So, if whatever reason, I don't know what, maybe there's a failure schedule something happens and you need to control that export.
Do you still have.
You know, the 2 seconds and the 10 seconds, right? I understand that it's more an issue when you have loading.
Because then there's more chances of that, you know, experts to be export limit to be exceeded if you lose some loading or something happens, it will be slowing but yeah.
The concern is in 100 go away. I think that's what I'm trying to say.
So, we had discussed that with Roger at that time and so once we set the inverter at 1.
The, the only condition where that will happen, is that the.
The next hour value's lower and there's a communication failure and you didn't set it in the next time. Yeah. Then you will be exporting more because for some reason, the gate within.
Was not able to send the value to the.
In water right now, but.
That's the only place where it will have an issue.
But then that applies to wherever there's the communication. So we have that concern everywhere.
Yeah, so part of the communication so, yeah, I think that's why John can correct me if I'm wrong, but I think there's, there's going to be requirements to address that issue.
If you lose communication, you default back to the, you know, the lowest value in the schedule or, you know, that's why these standards for testing are very important.
And that's why we have to wait for those to be in place because we have to have those sort of failsafe systems in place. Right?
You what happens if you don't have any communication do you just go back to the lowest value in the schedule? Do you go to the previously scheduled value? What are you doing in that case?
So, there are 2 communication 1 is the local communication so this failure happens only the local communication fails, but the external communication fails um, or from the server to the gateway fails. The cables still.
Work with the schedule it has and what what is on the inward will continue. Um.
So the defaults, which won't happen, because in 1 respect to a parameter till a new limited That'll continue accidents.
Um, in the interest of time, uh, we discussed these issues every week.
On the call, and we have discussed local com versus.
Remote calms all of that has been discussed. I would say.
If we're interested in that discussion, you know.
Folks can contact me, can attend the call. It's an open call.
And we'd be glad to go through it. It's, uh, Tuesday mornings at 830.
So, I, I do have a question, um, for the stakeholder on the call here so that we understand.
How did you move forward? Because, as you know, we, this is the 3rd workshop we have another workshop, and we do have to put in the advice letter. The sort of the approach.
Um, is it is it being discussed is that some stakeholder are willing to pursue, like, site specific testing.
And pay for that expense, whatever that is.
Instead of going through a certification testing is that kind of what's being explored here?
In this discussion, I believe that's what is being discussed and there are a couple of paths forward.
If we look at the language that is being proposed for the tariffs for the screens, which we saw earlier.
It says you'll have, um.
Or, uh, relevant your standard.
It is possible to get that listing on a safe by.
Through equipment testing in the field.
Whether people want to pay for that or not uh, it's a whole separate question.
But it is, there is a mechanism that is commonly used today.
Called field listing and that would be possible.
So, you hired the test lab to bring test equipment out into the field.
And run the test protocol for a given standard in the field.
And then you get a listing, or, you know, it'd be a full piece of listing.
The caveat is, it's only good for that site.
If you say, well, I'm building that exact same system 2 miles away.
You have to get another field listening.
So, John, this is also, I think, I think that's an excellent proposition because 1 of the reasons why we, we went down the path of was.
Because we used to receive all this custom.
You know, control systems and he takes.
Quite a bit of time to come up with a way to test them, approve them.
And for projects, especially projects that can do, can get listed as, uh, under the.
It makes sense for them to do the in testing.
Yes, certification and then propose a project. It speeds up the process for interconnection.
Helps all parties involved, so, for the few projects that can't do that. I think what you're proposing makes sense. You know, they would still be listed, but it would just be the project or customer or developer would.
Permission to do a field commissioning test and then a program it will be listed and then they can provide that information as part of the interconnection, uh, request.
Is there any reason, Alex or or other? I use why we wouldn't.
Also be able to pursue.
You know, 1 of the communications based methods here and and have a.
You know, commissioning test on site and then.
You know, ongoing monitoring.
That the utility plans to do via the telemetry.
You mean, like commissioning test by the utility rather than by the.
Yeah, they could be witnessed by the utility or.
Attested to, um, so, yeah, some, some sort of additional.
Commissioning tests that that validate the.
Ability of the the system to control power to a certain limit.
And then, you know, the, this sounds like the systems are are already going to be monitored to ensure that they comply with the schedule over time anyways. So.
Yeah, but the issue Brian, is that the monitoring is is not real time. It's, it's based on. It's not very reliable. Um, meaning that, you know.
Um, those systems are typically not readily available to planning engineers or even operations engineers. So it's gonna be like an, after the fact thing.
And I think that what John's proposing, if there's a pathway for and to do the testing, I think that's probably.
Just, because this is going to be best on the PCs standard or test protocol.
I don't think the utility personnel is really the best people to be doing this testing or witnessing this testing and, you know, if they can do it, then we should just have that done that way. And then the customer can schedule it at their own convenience.
And then once it's done, provide the information to the utility.
Yeah, I agree with Alex. Um, the, the distinction here is that we can, uh, we will be amenable to a field specific listing.
Done on sites, arranged by the customer to show it meets the requirements, specify the standards, but we are not in the business. We're in the appropriate position to perform, like, any certification testing. We just don't have that.
The ability to do.
I do think that is 1 option. I, I'm curious whether that's the best option. Might have to think about this a little further and come back to it. But, um.
Yeah, I'm not I don't don't love, you know.
Just completely going away from the communications based approach. Um.
But, uh, yeah, I understand the idea of.
Testing complicating validation, um, if the utilities have to be the ones witness. Mm. Hmm.
And then there's also the issue with liability, right? If we utility does the testing we say it's okay then back and the shifts, the liability to the. So.
But for 1 megawatt nearby, you have telemetry at the site, right? For largest systems. You're getting real time data right? So.
The communication based options, you already have control as well. It's not just online. No, we don't.
We just just because we have visibility doesn't mean we have control and even if we had control, most of it, most of the control is is not autonomous. Right? Somebody actually has to detect an issue and do something about it.
We, we, we don't nobody. There's no, 1, that's kinda like monitoring these systems in real time to see whether there's an issue and then react to it.
Right. So as much as we do, have the ability to query the aside and see what's being exported, we would rather set it up correctly from the get go.
That way issues are like nothing, you know.
We don't want to just say, okay, because we have visibility into the facility would like to make sure that the control system is designed correctly will work correctly before we can allow the project to connect.
And the only way to do that is to verify the system based on these prescribed protocols.
Would that applies to the other system the options um.
1 and 2 as well, right? It's, it's supposed to work. It is the each recommend is independently certified and each equipment works and you're monitoring it in real time. So.
So, there is an imply thing that each of the commanding water as well as the gateway certified to work as expected. So, usually they are certified. So they should work as expected. So, and you have real time monitoring.
So this is so there is no requirement that you.
Monitor it continuously and taking your action, it just gives you.
The confirmation that these products are certified, and since they have certified, they're supposed to work.
The only difference is there are 2 separate certifications right? That's the only thing. But.
Theoretically, they should work and.
So, what's the I don't fully understand the difference there between that and the other 1.
So, maybe I can just add a little bit on the.
Um, communications in the telemetry.
Um, it seems to me that if you're asking a site to meet requirements, uh, it would be.
Good a good idea.
To add the communication telemetry in which case that would be a non issue for those above 1 megawatt because they don't already have it.
But also to add the ability for the, the utility to monitor, or at least, um.
Determine, uh, in near real time, if there is, uh, something that is anomalous, namely above the export limit.
Uh, it seems to me that if you are asking for.
Um, then it should be also important to ask, uh, the utilities to monitor the situation.
Yeah, so so that's why, I think what we were asking for telemetry and, uh, settled on information. Right?
And also, I mean, what this is gonna happen, what's gonna happen is we're going to do this confirmation after the fact, right for you to be for you to be able to monitor the site and.
Figure out, whether the export limit is being exceeded.
whatever's being the monitoring also has to have a schedule in it.
Right, because how do you know, you're violating something that, you know, so it's not just enough to say it's export because if facilities are allowed to export were saying,
are you exporting more than it's been has been approved and for you to do that check with the utility installed telemonitoring equipment that also has to have.
Scheduling it to check against the expert value so.
What would be? Well, we, we're going to be using the has no ability to even do that. Then it won't be a real time monitoring system.
I realized it's not there right now, but it seems to me that this could be something that would simply be a part of the whole process, uh, that it would be good to.
Require the communications and the monitoring of the communications based on the scheduled values, as part of.
That would be ideal. Yeah. So for instance, if I understand you correctly, your, your.
Suggesting we're proposing that we should have something at the that in real time.
Looks at how much power is being exported, and in real time verify that that is consistent with they allowed or approved export limit and is also capable to do something.
If there's a violation, meaning like, control the, you know, either the breakout control, the generation system or something.
I get that correctly. Um, well, I think there are 2 issues.
The PCs are the PCs is monitoring the PCC at all times and should have the ability to, um, take actions,
whether it's to cease to energize if it's not controlling its own. If there's a problem at the PC, see, the PCs ought to be able to do something about it. Yes. However, if you want to monitor.
From an perspective, maybe you can ask the PCs to provide you with the real time data, whether you're 1 megabytes.
Megawatt are not large of size.
Um, and that way, you would know what is happening at the PCC in near real time. I, I don't suggest seconds it's not a.
But, um, something in near real time, and if something is happening that the PCs itself is still not taking care of, you can give a phone call. Uh, I agree with John.
You, you don't want to actually do something.
Um, uh, automatically there, uh, if all you're seeing is that the is not quite handling things correctly.
Uh, I, this John, I put something in the chat and we discussed it, uh, at 1 point. Um, and that would be if you have an uncertified PCs.
From the customer perspective, it's going to control the export and they may feel comfortable with that.
Typically, for large sites, it may make sense to say well, you have an uncertified PCs.
Using, you know, equipment from different vendors that meets the functional requirement, but is not certified.
In that case an option would be to require a directional recurrent relay.
In addition to the uncertified and that becomes, uh, your, uh, secondary method.
That ensures if something misbehaves.
The system doesn't create a hazardous condition on the grid and for larger systems that may not be a significant cost.
So, the concept of a relay is okay join but the issue is.
Is that really? Is it is it, um.
Um, does it also re.
Monitor decide based on a schedule and use that schedule.
Does it get an input from the sip gateway for example, as far as what the schedule is? So it can know.
When the schedule's being violated, because we're not, we're not talking about 1 single limit at this point. Right?
Uh, right I think I think these are available to do that. I, I can look if you want specific part numbers, but I believe you can have time variant, uh, settings in release.
Yeah, you don't mind providing that information, John I'm not aware of any relay that is capable of having. I least not up to.
288, um, or even 12 I'm not aware of there might be some out there, but I don't know if any and then the other thing too, you know, this might be utility specific, but if you're going to use a relay, they send requirements as well.
It really has to be, for example, for PG E, that really has to be approved for specific functions. So we have a list that shows relays that are approved for non export or 30 to function or over current or under voltage.
current or under voltage
Our voltage, so if we're going to be using a relay would have to go through the same process. And.
Um, if there's a, I, Tripoli function for 10 variant.
Export limiting like you referenced, John, then you would have to be satisfied.
Approved for that function, but then once it's approved once it's good to go for the for the rest of installations in the future. So.
Alex, I think that we'd be using the same relays, but you would be adding on an automation controller.
This is a separate controller in addition to the real estate internal to the relay, right?
Right. But, yeah, so, like, if it were a Schweitzer, whatever relay, you know, 751 or whatever you want to use for the 32 functions.
They also make a really a real time automation controller that can control those limits.
Yeah, so now back to using a real within our tech, right?
I believe so. Yeah, I believe that's the way it would be implemented. Normally.
I really will be.
Uh, okay to use an approved relay for.
Non export or limited export if he was just looking at 1 function but once you introduce this.
You have a profile then it's not as as clear cut.
So, are you saying that there would be no way to.
For the utility to support you utilizing attack.
With a, with a relay that they've already certified.
Um, it's not 1 of the options that are listed on here. Right? I don't I think it's something that was discussed.
Before I think Roger had it on 1 of these options. I don't see it on here. It might be it may just take out 1 quick look.
That's what I what I mean is the idea of using the relay to couple with the PCs or to replace the PCs.
It would basically be enforcing. I mean.
This is done today, sometimes that, you know, a relay and forces.
Certain parameters that the system is maintaining so, you know, a system might have yeah, the relay isn't actually acting as the power control system. In most cases you're gonna have a power control system in place that.
Manages the output of the inverters right. To maintain a certain level of control, but since they're not certified.
Then you would add on this relay to basically be a replacement for certification.
And so that's, you know, something that's.
Likely done today for.
Static limits, and then we'd be basically taking that same concept and simply applying the schedule.
Uh, this John, I just looked online and I just went to and looked at a 351 and a 751, and they both have local communication ports that support modbus for example.
So, if we've established that the, um, scheduling.
And be, uh, cloud based.
Then, uh, the, the W, whatever is doing the, the scheduling.
Could send updates to the relay.
The relay would be there at a backstop. The uncertified PCs.
And the time variant limiting behaviour.
Would could be transmitted to the relay at least based on my 1st, uh.
Cut I'm looking at it. Yeah, I think that's.
Usually done, it probably can be done multiple ways, but I think it's usually done through that. Our tech.
So again, so, if you're using if you're using a relay to supervise a customer control system, and he doesn't even have to be PCs, it could be a load management system.
You know, specific to that site it could be anything.
At that point, you know, from a utility perspective.
It doesn't matter what's happening in the facility because.
For static limit for 1, single limit. So long as the relay is capable of detecting export.
I'm controlling either a break or the generator or the generator breaker that would satisfy that requirement.
This is for a single limit. This is something that we do today.
Right, the idea of using a relay to, you know, with an, to determining a time variant export limitation is not done today. It doesn't mean it can be done. It's just not done today. We don't have.
A list, the distribution system I'm not aware of any system that's installed.
That has a different export limit, depending on the time of day or time we have something. Um, so.
You would have to go through an approval process and if we deem that, that's something that's.
Satisfactory then will, it can be approved, but as of today, we don't have.
We don't have a, we do not have any systems approved to do what's being proposed. So, this is Scott. I'm going to jump in here because I know jose's gonna jump in 3 minutes and tell us we have to have a hard stop. Alex.
It sounds to me, like, we're getting somewhere here and.
Yeah, I'm wondering you're saying that you guys would need to approve. I guess we need to talk about what that looks like.
And what it would look like to incorporate it into the tariff. But Jose.
Should we can we can be in this conversation again after lunch or where are we schedule wise?
So, we are actually, you know, like I said, we have plenty of buffer at the end of the.
Um, workshop today.
Uh, so we can convene this discussion definitely.
Afterwards, and I do want to remind everybody that, you know, uh, I dedicated, uh, this morning, we're working group this week to also continue discussions on this topic. So.
Um, let's, uh, I would propose after lunch let's convene for maybe.
Half hour, 45 minutes or so.
Cause I would like to get through topic F2 and then given timing, we can go back to.
This topic or continuate continue it on topic. E.
I mean, on, uh, continue topic key on this smart number working group.
Does that sound like a plan.
I think so.
Again, for not being the technical 1, but I did feel like, we were getting warm up something. That might be workable, but maybe I wanted to pause there to just ask because it gives an hour for people who don't have other meetings, at least to digest of how we would pursue this.
I guess.
Okay, so let's do that. Then let's reconvene after lunch then.
And see where the, uh, you know, how the timing goes.
So, like I said, we do have plenty of buffer at the end of the workshop.
I think I need 10 minutes is that I think we only need 10 minutes more on this and then we'll have it.
Love your optimism bread.
Yeah, but I do want to be, uh, you know, I did say, you know, uh.
Based on the schedule, you know, people may have scheduled the meeting the other meetings around lunchtime. I, and I do want to be, uh.
You know, recognize that that those meetings, you know, they may need other stuff to do.
So, okay, um.
But thank you, Scott you right my mind, I was thinking all right I gotta jump in here at 1 point.
But, uh, all right, so let's start back on slide 20 after lunch.
So, let's, uh, see each other back in an hour.
Sound good. Thanks. All right.
So, you'll back in an hour.