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To: Rule 21 Working Group FourFrom: Julia Levin and Greg Stangl, BACDate: May 15, 2020Re: Anti-Islanding Proposal (Issue 18)BAC supports some of the proposals made by CALSSA in its April 10 memo to Working Group 4. In addition to the three proposals by CALSSA, BAC proposes several additional items related to anti-islanding to reduce unnecessary costs, increase transparency, and provide predictability for project developers.BAC also supports some parts of PG&E’s proposal, related to the Risk of Islanding study and the need for EPIC funding, both described below. BAC is concerned, however, that none of the utility proposals include measures focused on reducing costs and uncertainty for projects that rely on synchronous generators, such as the small-scale bioenergy projects required by SB 1122 (Rubio, 2012). BAC’s recommendations are based in part on recent experience with small-scale forest biomass projects required by SB 1122 and the Governor’s Emergency Order on Tree Mortality. California is relying heavily on bioenergy from organic waste to meet the state’s climate laws, in particular SB 32 (Pavley) and SB 1383 (Lara), to reduce the most damaging climate pollutants, known as Short-Lived Climate Pollutants (SLCPs). The state’s climate plan is relying on SLCP reduction for more than one-third of all the carbon reductions needed to meet the requirements of SB 32. More than 90% of SLCP emissions come from organic waste that is burned, either in wildfires or controlled burns, disposed of in landfills, piled and left to decay, or generated at wastewater treatment facilities. CalRecycle’s regulations to implement SB 1383 rely heavily on bioenergy production, as does the state’s Short-Lived Climate Pollutant Reduction Strategy.The Short-Lived Climate Pollutant Reduction Strategy states repeatedly that California must remove barriers to bioenergy interconnection to meet the state’s climate goals. For example, the Strategy points out that:“Practical solutions must be developed and implemented to overcome barriers to waste gas utilization for pipeline injection and grid interconnection. . . Stubborn barriers remain, including connecting distributed electricity and biogas projects, which have slowed previous efforts to reduce emissions of SLCPs and capture a wide array of benefits. These barriers are not insurmountable, and now is the time to solve them. State agencies, utilities, and other stakeholders need to work immediately to identify and resolve remaining obstacles to connecting distributed electricity with the grid . . . . Interconnecting distributed sources of renewable energy onto the electricity grid . . . remains an unnecessarily long and costly process in many cases.”California is also relying on new, small-scale forest biomass projects to help address California’s wildfire and tree mortality crises, which are ongoing. Governor Brown’s Emergency Order on Tree Mortality and the California Forest Carbon Plan call on the CPUC to accelerate interconnection for new forest BioMAT projects required by SB 1122. The Governor’s Tree Mortality Task Force highlighted the need for utilities to work with developers more proactively to find project level solutions that reduce costs. As part of the Task Force, the Governor’s Office, CPUC, PG&E, and BioMAT project developers reviewed the interconnection project costs for six projects. Working together with senior PG&E engineers, the group was able to reduce interconnection costs by an average of $1 million per project. PG&E’s senior engineer helped identify a total of $5.6 million in interconnection cost savings for the six projects. The breakdown – agreed up by PG&E, the CPUC, and project developers is in the table below:Project NameInterconnection CostsRevised Costs Net Savings Identified Blue Mountain $ 2,045,000.00 $1,315,000 $ (730,000.00)North Fork $ 1,257,000.00 $877,000 $ (380,000.00)Collins $ 3,305,000.00 $1,910,000 $ (1,395,000.00)Burney Hat Creek $ 4,657,000.00 $2,037,000 $ (2,620,000.00)Indian Valley $ 2,860,000.00 $2,860,000 0.00 Celestial Valley $ 5,560,500.00 $5,010,500 $ (550,000.00)TOTAL $ 19,684,500.00 $ 14,009,500.00 $ (5,675,000.00)The Tree Mortality Task Force review of interconnection costs highlighted the enormous uncertainty that developers face when it comes to interconnection requirements and costs and the high variability from one utility expert to another. Providing clear, reliable guidance on which technologies will be required under what circumstances is critical to help small-scale bioenergy projects determine where to site projects to minimize interconnection costs and what costs to expect.Given the urgency of connecting new bioenergy projects and other distributed generation, BAC supports CALSSA’s proposals to allow the project developer to hire an independent analyst to perform an islanding risk assessment. While BAC agrees with CALSSA’s proposals, we would like to note that DTT often greatly exceeds $800,000. This is particularly relevant in more rural areas of the State where the gird is radial and DTT is applied to numerous substations. Furthermore, none of these reported costs include the leased line communications infrastructure, which can be particularly expensive in less urban areas.In addition to the CALSSA proposal, BAC proposes the following to avoid islanding while accelerating interconnection, avoiding unnecessary costs, and reducing uncertainty:The CPUC, utilities, and developers should work together to develop a guide that provides anti-islanding options, clearly identifies the cost of each option, and sets out the circumstances when it will be required. Costs should be all-inclusive. This “Interconnection Guidebook” – while not a binding regulatory document - should provide clear guidance to project developers so that they know exactly what circumstances will trigger a requirement for DTT and what circumstances or steps can be taken to avoid DTT. There should be clear metrics and examples provided so that developers do not have to guess about potential requirements.Utilities should not be allowed to require more than what is in the Interconnection Guidebook unless they demonstrate the need for additional measures in a timely manner. For instance, if the Guidebook says that DTT is not required if an end of line fault (EOL) can be seen and the generator tripped in 120 cycles (2 seconds), then the utility should not be able to deviate from that without a clear written explanation as to why something more than the Guidebook recommendation is needed. Utilities should be required to offer least cost / best fit solutions to meet anti-islanding requirements. Most transfer trips could be achieved with a $50,000 SCADA system and a phone line or appropriate protective relays. A T1 with a $1,000,000 DTT transmitter/receiver setup is often not necessary nor preferred.Utilities should be required to explore options that are less expensive and require less upkeep than DTT. The Interconnection Guidebook described above should provide the basis (criteria) for deciding when less expensive options are sufficient.The CPUC should adopt an enforceable interconnection timeline so that projects do not have to wait for extended periods of time after completion to connect to the grid.The Working Group should support use of EPIC funding to identify and demonstrate additional, less expensive options for anti-islanding, help fund development of the interconnection guide, and help demonstrate technologies that provide anti-islanding and islanding (microgrid) solutions.BAC does not support PG&E’s current proposal as it does not seem to address projects that use synchronous generators and does not explain or provide sufficient detail for several of the items in the flowchart. BAC does, however, support giving developers the option to request of Risk of Islanding (ROI) study at any point during the interconnection study process, to determine whether DTT is necessary or less expensive options could suffice. BAC urges PG&E to add or clarify the following:PG&E should add an option that works for bioenergy (machine generation) to its proposal and graphic. As presented in PG&E’s April 16 draft, nothing in the flowchart that PG&E presented will help address anti-islanding for small-scale bioenergy projects.Can PG&E please explain, in writing, what the three percentage threshholds in the flowchart are based on, where they come from, or why PG&E chose those percentages. There is no explanation for the policy or technical bases of these percentage requirements.Can PG&E please describe, in writing, what an ROI study would include, any threshold requirements, other considerations, level of detail required, who would prepare, how long it should take to complete the ROI, etc. Can PG&E make clear that the developer is entitled to request (and pay for) an ROI at any point in the interconnection study process?Could it be considered that PGE could provide a historical example where this new methodology might be applied to a historical interconnection to see if it actually would accomplish a reduction in incidence of DTT or a reduction in the cost of the chosen anti-islanding protection scheme? ................
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