Gridworks



Nuvve Corporation Vehicle-Grid Integration policy recommendations and supporting information Note: Not all of Nuvve’s original recommendations are included here, as some were resolved in discussion with the working group, and some require no further explanation.Performance-based rate makingPotential addition of load from EVs combined with formation of CCAs present a major shift in IOU business model toward enhancement of the distribution grid with limited accompanying shifts in utility incentive structures to encourage efficiency. Adding a performance element focused on "operational expenditures" to traditional CAPEX-focused rate-making along the lines of those seen in UK, New York, Massachusetts, Hawaii, and Illinois will reorient the focus of IOUs toward true vehicle-grid integration rather than continuing to build based on nameplate capacity alone. We do not mean this to be a suggestion focused only on ability to reduce expenses associated with VGI, but rather to contextualize VGI as a potential major new infrastructure build-out opportunity that can be approached as efficiently as possible taking into account load management technologies and new ways of assessing loads, or not. SGIP-style battery rebate for pairing with high power DC fast chargingHigh-powered charging is an essential piece of VGI that potentially represents megawatts of nameplate capacity for each installation. While rates are one solution, decreasing the required connection to energize with local generation/storage is a more likely to emphasize "integration" than the current demand charge waiver.This proposal is distinct from requests for V2G eligibility for SGIP. It is intended to assist with en route charging for buses, and destination charging for cars to both decrease need for distribution infrastructure reinforcement and to increase resiliency of sites. Apply Station Power concept to V2GStation Power as a concept is the idea that power purchased to operate generating facilities (or storage) can be purchased at wholesale, while energy needs at the site more broadly for purposes other than actually running the generator must be paid at retail rates. The station power concept may provide a distribution-level framework for dealing with the wholesale-retail issue for V2G resources. A V2G-capable EV is a dual-use device, functioning as both a storage resource and as an end-use load. The two uses are distinct and the energy bought and sold for services can be measured and accounted for separately from energy consumed while driving. California applied the station power concept to storage in the Decision on Track 2 Energy Storage Issues. FERC order 841 on participation of energy storage in RTO and ISO markets that decided distributed storage resources should be able to buy at wholesale any energy that is then sold back at wholesale, even behind a?retail meter. FERC’s November 2019 order on CAISO’s 841 compliance filing stating that FERC believed CAISO had not sufficiently resolved this issue. While CAISO will send a response, it is possible that CAISO has taken their actions as far as is appropriate at the wholesale level, and the remainder of the solution must be sought at the CPUC’s level. Applying the station power concept to V2G is one way to approach the problem from the retail side by backing out retail usage form the broader wholesale account.The Multiple Use Applications decision addresses station power in section 5, particularly metering arrangements for in front of the meter systems and deferred to utilities for metering configuration options.?SDG&E’s advice letter establishing an electric schedule for station power, which includes an allowance for proxy measurements.It is worth investigating station power as an example of a retail solution to the remaining complexities for DERs providing wholesale services at the distribution level. If station power is not a viable path to resolving this issue, the possibility of retail-level solutions still warrants further investigation and effort in California. While others have pointed out that behind the meter values are more immediate possibilities, Nuvve feels that behind the meter values are established partly because the system of rates and incentives is built to incentivize them. Without enabling viable access to markets, we cannot claim to have fully investigated the potential significance or value of EVs at the system level.Interconnection of mobile invertersDespite several months of productive collaboration in the Working Group Three subgroup on AC interconnection of mobile inverters, there remain two primary barriers for IOUs: Safety concerns Society of Automotive Engineers and Underwriters Laboratories have pledged to update their existing standards (J3072 and UL9741 respectively) for interconnection of mobile inverters exporting AC power from vehicle. The AC Interconnection sub-working group will reconvene this summer to consider the progress the two organizations have made. IOUs should take advantage of currently proposed pilots to fully understand the implications for IOU interconnection procedures and safety considerations to allow constructive input into standards updates, and consequent changes to Rule 21 to reflect those new standards.Resolve NGR issues for behind the meter market accessNuvve agrees with Enel X’s assessment of this problem in their submissions to this group.Credit for export for V2G/StorageThis is simply a conceptual suggestion that compensation for export does not have to take the form of traditional net metering, though it should be a direct credit on a customer bill. For example, both energy flows in and out of the site can be measured individually and compensated. Some type of compensation for export can serve as part of the solution to the buy retail-sell wholesale issue also addressed in the Station Power item at #4 in this document, which is why it is important that payment be a direct credit. This is meant to address the metering complexities of resources providing wholesale services from the distribution level.Adopt interim procedures for validating current limiting functionalities in smart chargingThis request has implications for both smart charging/load management functionalities of uni-directional systems and for energization of V2G systems in charge-only mode for use as chargers while owners go through the interconnection process to obtain permission to operate as a bi-directional storage resource. While it is understandable that IOUs are waiting for testing and certification guidelines, there is no guarantee that those will be sufficient. Both energy/load management and current-limiting capabilities are an essential part of VGI as it relates to infrastructure upgrade deferral, customer bill management, and load management. Avoid over-regulation of EVSE specificationsThis request applies to V2G chargers that contain inverters, “smart” chargers, and standard EVSEs. In the V2G space, incompatible standards and operating requirements may be applied for inverters and EVSEs, leaving EVSE manufacturers that include inverters unable to meet both sets of standards. More common EVSEs and smart chargers may be subject to standards that change frequently and are sufficiently strict to make market entry difficult for new and small manufacturers, ultimately favoring incumbents and resulting in concentration of market power. The CEC is addressing this trend in the CAleVIP update, taking into account the need for healthy competition and seeking to establish high standards of quality, functionality, and interoperability without excluding new entrants to the market. ................
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