Limited Generation Profiles Workshop #2 

7:56 am - 4:11 pm  Tuesday, November 29, 2022 | (UTC-08:00) Pacific Time (US & Canada)

pht2  Eamon Hoffman ET  gary holdsworth sdg&e  Prasanth Gopalakrishnan ASE/Kalkitech  De Ocampo, Jorge  Eva Wang TotalEnergies  Saxton, Patrick  Abtin Mehrshahi  Antonio Nunez  Melcher, Jerry  John Berdner Enphase  Roni Mejia - SCE  Kimberley Chong SDG&E  Sky Stanfield  Stephan Barsun - Verdant Associates  Francisco Hernandez (Consultant) @CPUC  Saeed Jazebi  2094****59  Denise Chan PG&E  Jason Bobruk  Mandee Figueroa SCE  Abe F SDG&E  Yu	 Lister  Alex Mwaura PG&E  Stephan Barsun  Tseng, Wayne  Sherise  Cory Mitsui  Regnier, Justin  David Schiada  Christian Eder, Fronius USA  Steve Sherr  Jan Strack  phuoc  Josh McDonald SCE  Adrianna Magallanes-Chacon SDG&E  Will Wood  Ralph Troute CALSTART  Frances Cleveland  Matt Belden SDGE  Iman  Matt Gonzales  Sheikh Hassan  Jacob Willman (Consultant)  Frank Goodman  Jordan  Aliaga-Caro, Jose  Yi Li SDG&E  Dan Bedell - SDGE  Dan Bedell  Brian Lydic - IREC  Roger Salas SCE  Webb, Tyler  Christian Eder  Fardin Sarraf  Wilfredo Guevara - SDG&E  Belinda Vivas SCE  2153****14  Younes, Amin  Albert Tapia  


WEBVTT

1
Aliaga-Caro, Jose 00:18:05.824 --> 00:18:20.554
Thank you everybody who has joined so far, um, workshop officially will commence at 90 a. M, so, uh, this time, uh, feel free to get yourself your water coffee, whatever unique.

2
Aliaga-Caro, Jose 00:18:22.894 --> 00:18:28.054
We're just giving enough time, uh, you know, we're giving people enough time to join the workshop.

3
Younes, Amin 00:18:42.484 --> 00:19:03.574
jose since uh since i'm here and you're here and i don't know if you're doing anything else but i'm curious how people get on the agenda for these types of workshops particularly i know that we have the e fifty two well might have the fifty two thirty workshops coming up at some point and if i wanted to talk at that provide a presentation how would i go 

4
Younes, Amin 00:19:03.610 --> 00:19:04.385
About doing that.

5
Aliaga-Caro, Jose 00:19:04.805 --> 00:19:08.225
I will be solicit 15.

6
Aliaga-Caro, Jose 00:19:09.814 --> 00:19:25.714
Agenda topics, uh, and, uh, if, uh, basically we'll follow the same procedure as we did for this workshop, we will, uh, for 5,230, we will announce the workshop.

7
Aliaga-Caro, Jose 00:19:27.784 --> 00:19:47.434
And, uh, I mean, I, I believe you're on the service list. Yeah. So we'll announce the workshop. And, uh, I believe I, uh, also, uh, in the announcement, I, uh, circulated a form for people in particular that 1, to participate in the workshop.

8
Aliaga-Caro, Jose 00:19:49.685 --> 00:19:54.035
To fill out, including any agenda topics that they wanted to cover.

9
Regnier, Justin 00:19:55.985 --> 00:20:09.875
I think we're not actually using the service lists. There's a lot of legal minutia here, but the resolution itself is kind of its own many proceeding with its own record. And because.

10
Regnier, Justin 00:20:09.904 --> 00:20:29.434
It's adjacent too, but not involved in the proceeding itself. I don't think we notice via the service list, or we have done as noticed via the smarter murder working group. I mean, there's a, it's not exactly a 1 to 1 correspondence between people. That are on there. And on the service list, but it's pretty close.

11
Aliaga-Caro, Jose 00:20:29.824 --> 00:20:31.024
Yeah, well, uh, just.

12
Aliaga-Caro, Jose 00:20:31.174 --> 00:20:52.174
Uh, we did notice the initial, uh, kickoff workshop in the service list. So we, as you said, you know, as you said, not everybody in the smart, and we're working group is on the server list or vice versa. So, we did announce that initial kickoff into the service.

13
Aliaga-Caro, Jose 00:20:52.179 --> 00:21:02.674
787 07, so we'll be following that same procedure for the resolution. e5230 workshops.

14
Aliaga-Caro, Jose 00:21:06.305 --> 00:21:25.985
And then, you know, if I will be circulating, like I said, a form for participant for people that are interested in attending the workshop and participating, or even just listen only and then following workshops, basically, you know.

15
Aliaga-Caro, Jose 00:21:26.224 --> 00:21:40.744
Uh, invites are distributed to that list of respondents that way. We don't buy the service list with, you know, invites that people may not be interested in attending.

16
Aliaga-Caro, Jose 00:21:42.964 --> 00:21:49.924
So, and in that form, I mean, there is a section to submit topics for discussion.

17
Younes, Amin 00:21:52.834 --> 00:21:55.954
Got it, thank you. I'll look look for that when that comes out.

18
Aliaga-Caro, Jose 00:21:56.404 --> 00:21:57.274
Okay, yeah.

19
Aliaga-Caro, Jose 00:38:29.675 --> 00:38:36.785
Hey, we're 5 minutes before the hour. Uh, I'd like to check whether we have the, uh, presenters from the utilities here.

20
Aliaga-Caro, Jose 00:38:38.735 --> 00:38:41.045
Uh, do we have, uh, on the call.

21
Aliaga-Caro, Jose 00:38:56.074 --> 00:39:01.384
Uh, anybody from on the call, I believe you should be able to unmute yourself.

22
Aliaga-Caro, Jose 00:39:20.704 --> 00:39:27.304
All right, so let me do a, uh, test here. Can anybody unmute themselves and speak.

23
Yi Li SDG&E 00:39:28.984 --> 00:39:30.544
We'll say this is.

24
Yi Li SDG&E 00:39:31.719 --> 00:39:32.254
You hear me.

25
Aliaga-Caro, Jose 00:39:33.364 --> 00:39:39.874
Yes, thank you. I was afraid people were not able to unmute the upstairs. Right? Okay.

26
Yi Li SDG&E 00:39:40.414 --> 00:39:46.204
Yeah, I I see, Alex, I, he just mute it and maybe just grabbing a drink or something.

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Aliaga-Caro, Jose 00:39:46.384 --> 00:39:52.864
Okay, yeah, yeah, I saw it, but like I said, I need a confirmation that someone could.

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Aliaga-Caro, Jose 00:39:52.895 --> 00:39:54.785
Unmute themselves and speak.

29
Aliaga-Caro, Jose 00:39:57.424 --> 00:39:57.874
Thank you.

30
Aliaga-Caro, Jose 00:40:00.725 --> 00:40:09.095
So, okay, so while we wait a confirmed there on the call and do we have Edison on the call?

31
Roni Mejia - SCE 00:40:10.745 --> 00:40:13.025
Good morning who said this is right here.

32
Aliaga-Caro, Jose 00:40:13.355 --> 00:40:18.485
Ah, thank you Ronnie. Good to, uh, have you on all right.

33
Aliaga-Caro, Jose 00:40:21.424 --> 00:40:28.774
And, uh, I know I Rick is presenting later today, so I just want to make sure they're on the call right now.

34
Aliaga-Caro, Jose 00:40:32.794 --> 00:40:38.584
Do not see Iraq yet, but it's still 5 minutes to the hour.

35
Alex Mwaura PG&E 00:40:40.864 --> 00:40:41.854
Alex from PG E.

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Aliaga-Caro, Jose 00:40:42.334 --> 00:40:47.524
Thank you, Alex, thank you for confirming. You're on the call. Perfect.

37
Aliaga-Caro, Jose 00:41:07.324 --> 00:41:12.844
So, uh, if you could bring up the, uh, energy division slides.

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Aliaga-Caro, Jose 00:41:16.684 --> 00:41:25.444
Ah, thank you. Perfect. And we'll just keep it there until we officially start in about 4 minutes.

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Aliaga-Caro, Jose 00:45:05.704 --> 00:45:10.144
Okay, well Thank you everybody for joining today's call.

40
Aliaga-Caro, Jose 00:45:11.734 --> 00:45:21.694
The 2nd, uh, limited generation profile workshop ordered per resolution E50 to 11 for him. Next slide. Please.

41
Aliaga-Caro, Jose 00:45:24.184 --> 00:45:37.414
So, some, uh, workshop and logistics safety reminder, of course, make note of your surroundings and roots and reach out. If you need help, either during the call or to an attendee.

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Aliaga-Caro, Jose 00:45:38.614 --> 00:45:59.464
Just a reminder also that this meeting is being recorded a workshop recording and materials are posted at the CPC rule 21 limited generation profiles web page. I will go over that later on. If you were forwarded to invite and did not receive it directly.

43
Aliaga-Caro, Jose 00:45:59.494 --> 00:46:09.334
From energy division and would like to be added to the workshop distribution list. Please email Mary at Mary dot at CPC. That's.

44
Aliaga-Caro, Jose 00:46:09.339 --> 00:46:27.874
Dot Gov, workshop participants are encouraged to ask questions during the presentations we do have dedicated Q and a time slots for each presentation. But, you know, if there's something a dire feel free to raise your hand.

45
Aliaga-Caro, Jose 00:46:30.154 --> 00:46:50.224
Comments on the on the chat window or also. Welcome. But if you do have a question, I do encourage you to speak up has sometimes it is difficult to both follow the chat window and attentively. Listen in to what this presenters are speaking.

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Aliaga-Caro, Jose 00:46:51.544 --> 00:46:52.114
Um.

47
Aliaga-Caro, Jose 00:46:53.584 --> 00:47:14.134
Please, uh, Additionally, keep yourself muted were not speaking and do not put the call on hold. You are able to unmute yourself by pressing that, uh, microphone button. If you come by phone, uh, use the mute button on your handset and unmute yourself to speak.

48
Aliaga-Caro, Jose 00:47:14.944 --> 00:47:19.114
Uh, if needed by the host press star 6 to unmute.

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Aliaga-Caro, Jose 00:47:21.274 --> 00:47:22.924
Any questions so far.

50
Aliaga-Caro, Jose 00:47:26.794 --> 00:47:29.374
Okay, hearing now next slide.

51
Aliaga-Caro, Jose 00:47:31.445 --> 00:47:49.985
So, um, here is where you'll be able to find, uh, all the, uh, workshop materials and recordings uh, the 1st, uh, the works, the 1st workshop is already posted, uh, we will be posting it probably, uh, within a couple of days.

52
Aliaga-Caro, Jose 00:47:52.444 --> 00:47:57.964
So, uh, this workshop should probably be available by probably Thursday or Friday this week.

53
Aliaga-Caro, Jose 00:48:00.244 --> 00:48:01.084
Next slide.

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Aliaga-Caro, Jose 00:48:04.655 --> 00:48:17.165
So, uh, today's agenda, uh, we're starting on with an introduction, uh, then we are moving on to, uh, the utilities, uh, presentations, um.

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Aliaga-Caro, Jose 00:48:26.314 --> 00:48:45.844
Yeah, uh, so that covers items 1 and 2 uh, we'll be taking a short break around 1145 and then we'll continue the utilities presentation and then we'll be taking in our lap break around noon and.

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Aliaga-Caro, Jose 00:48:45.849 --> 00:48:56.104
And the plan is that will also be presenting, uh, everybody should have received updated slides this morning.

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Aliaga-Caro, Jose 00:48:57.814 --> 00:49:18.274
Uh, again, uh, I'd like to stress this as a tentative agenda based on the 7th on the November 7th workshop. Uh, you know, there were a lot of, uh, there was a lot of dynamic interactions. So we did go over. So, even though we are scheduled to terminate, uh, to end the.

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Aliaga-Caro, Jose 00:49:18.304 --> 00:49:30.634
Shop at 330 today it may go up until probably 430. so we have allowed some buffer time next slide. Please.

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Aliaga-Caro, Jose 00:49:34.354 --> 00:49:53.464
Uh, so, again, just a reminder, uh, workshop calls to arrive at some sort of consensus proposal for the specifics of whether, and how reductions to the customer's limited generation profile are determined. Uh, just as a reminder these were 15 and 16.

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Aliaga-Caro, Jose 00:49:53.554 --> 00:49:56.584
From a decision in 2903 5.

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Aliaga-Caro, Jose 00:49:57.994 --> 00:50:18.784
The utilities presentations contain their proposals and should not be taking has final solutions. Uh, we, uh, reiterate that stakeholder. So welcome to propose different processes. And we are encouraging that, uh, this, uh, workshop.

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Aliaga-Caro, Jose 00:50:18.909 --> 00:50:38.944
Has, uh, means to discuss every available solution and again, just a reminder when it comes to discussions of the integration capacity analysis. Boot 21 is an end user. So changes to the are out of scope.

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Aliaga-Caro, Jose 00:50:40.324 --> 00:51:01.204
So, any discussions regarding the icaay should center on how it is right now, and not on changes to it that is under another proceeding. The Heidi proceeding next slide.

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Aliaga-Caro, Jose 00:51:03.964 --> 00:51:20.794
Uh, this is just, uh, background material on, uh, ongoing paragraph, 16 and 15 from, uh, and I know 35 I will not go through with them through them. Uh, everybody should be already familiar with them.

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Aliaga-Caro, Jose 00:51:22.384 --> 00:51:25.804
And let's see.

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Aliaga-Caro, Jose 00:51:30.844 --> 00:51:47.074
And having said that, I think we are perfect, uh, right on time to start the utilities, uh, discussion. So, uh, if we could bring up the, uh, PDF file from the utilities, please.

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Aliaga-Caro, Jose 00:51:58.324 --> 00:52:06.274
All right, so, uh, who will be, uh, speaking 1st for the utilities who will be driving the conversation.

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Roni Mejia - SCE 00:52:06.964 --> 00:52:15.304
Good morning so, um, I'll be, uh, starting 1st and then I'll be handing it over to Alex, uh, from PG E. and then, uh.

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Roni Mejia - SCE 00:52:16.115 --> 00:52:21.485
Then Alex will be handing it over to E from after that.

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Aliaga-Caro, Jose 00:52:21.725 --> 00:52:33.635
Okay, thank you. Ronnie. Um, please let our ity specialist know when to proceed to the next slide. Uh, and I will let you take it away.

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Roni Mejia - SCE 00:52:34.775 --> 00:52:36.725
Awesome. Thank you. Thank you very much.

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Roni Mejia - SCE 00:52:38.404 --> 00:52:46.414
Can you please go to the next slide so, uh, just briefly good morning everybody, uh, my name is running here from a.

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Roni Mejia - SCE 00:52:46.984 --> 00:53:08.074
And, um, just a quick overview of the agenda that we plan to cover during our presentation, uh, brief overview of, uh, 15 and 16 and re resolution 5,211, which, I think, um, Jose has done a really good job at already touching onto. We're also.

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Roni Mejia - SCE 00:53:08.109 --> 00:53:29.254
Talk about some of the, uh, the issues that are not in scope for 5,211, uh, some of the items that are included as part of 1930 or part of phase 2, and then we're going to dive into the topics, uh, that, uh, from the previous workshop.

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Roni Mejia - SCE 00:53:29.284 --> 00:53:50.374
That either, we had a, uh, extensive discussions around and to some extent we have, uh, some general consensus and then we're going to touch on topics, uh, where we don't have consensus. And we're gonna, uh, dive deeper into those topics. And then, uh, some additional areas where.

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Roni Mejia - SCE 00:53:50.435 --> 00:53:52.385
Additional discussions are.

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Roni Mejia - SCE 00:53:54.664 --> 00:53:56.884
Are warranted so.

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Aliaga-Caro, Jose 00:53:58.114 --> 00:54:07.774
Ronnie, uh, and before we continue, could we ask anybody speaking to turn your cameras on? And that was my bad. I should have started that off.

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Roni Mejia - SCE 00:54:13.054 --> 00:54:15.514
Can everybody see my camera.

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Roger Salas SCE 00:54:18.904 --> 00:54:19.204
Yes.

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Aliaga-Caro, Jose 00:54:19.264 --> 00:54:19.924
Yes.

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Roni Mejia - SCE 00:54:22.715 --> 00:54:27.575
All right cool. So so moving on to the next slide um, okay.

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Roni Mejia - SCE 00:54:29.914 --> 00:54:51.004
All right, so so this 1 is just a level set, uh, slide. And, uh, as I said, I would say, has already mainly covered a lot of these elements here. And, uh, the, the, I wanna just briefly summarize that, uh, the, the objective of.

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Roni Mejia - SCE 00:54:51.064 --> 00:55:12.184
Uh, of us, trying to comply with team is to define the circumstances, uh, that would lead to a reduction to an project. And then the process, uh, for determining that level of reduction in a nutshell. And I think, uh, as part of the.

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Roni Mejia - SCE 00:55:12.485 --> 00:55:33.335
Workshop number 1, we, we dove into those, uh, subject matters and we will be furthering, uh, you know, those discussions as we go through the slides. And, um, and of course, uh, we are going to be, you know, talking about, uh, in the previous workshop.

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Roni Mejia - SCE 00:55:33.454 --> 00:55:54.334
Talk about our business as usual practices. Um, and, uh, so highlighting that here and some of the future conditions that may arise, which we'll also define in the previous workshop and we're also going to be touching on it in this in this within our slides today. So.

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Roni Mejia - SCE 00:55:54.545 --> 00:56:03.695
Have a more opportunities for discussions around those topics so if we can move on to the next slide. Okay.

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Roni Mejia - SCE 00:56:06.484 --> 00:56:26.884
And as indicated in the agenda, why don't you highlight some of the, uh, items here that, uh, uh, the, uh, that are not in scope of resolution 5,211 uh, but other part of 50 to 30 or part of phase 2 and, uh, the bullet items, uh, that.

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Roni Mejia - SCE 00:56:27.154 --> 00:56:48.004
Identified, uh, the fall under those, uh, either of those buckets it's either, uh, it's the format of the schedule, uh, for the ltp profiles the quarterly reporting aspect of it, uh, the export versus generation nameplate and then the cost impacts, uh, to address.

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Roni Mejia - SCE 00:56:48.069 --> 00:57:00.934
Upgrades, which are part of phase 2. so what are the kind of summarize, summarize those areas? So that at least that we can, uh, stay on topic with regards to resolution 2011.

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Aliaga-Caro, Jose 00:57:02.794 --> 00:57:09.184
So, uh, lo, Ronnie, um, before we continue, I did have a question. I know I know this is, uh.

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Aliaga-Caro, Jose 00:57:09.244 --> 00:57:15.034
Jumping ahead, but could we talk about the quarterly reporting? Um.

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Aliaga-Caro, Jose 00:57:16.294 --> 00:57:34.324
I just wanted to, uh, get that clear a little, uh, resolution, uh, 5,211 did allow, you know, preliminary discussions. And, like I said, this probably requires jumping a little bit ahead to slide.

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Roni Mejia - SCE 00:57:34.744 --> 00:57:35.524
18.

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Aliaga-Caro, Jose 00:57:36.154 --> 00:57:37.414
To slide 18.

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Aliaga-Caro, Jose 00:57:37.534 --> 00:57:38.524
And so.

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Roni Mejia - SCE 00:57:39.364 --> 00:57:48.004
Yeah, we, we did recognize that um, and so that's why we made sure to include it as part of, uh, the discussion. So.

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Aliaga-Caro, Jose 00:57:48.544 --> 00:57:52.384
Yeah, could we, uh, jump to slide 18 and cover that now? Please.

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Roni Mejia - SCE 00:57:52.714 --> 00:57:53.164
Sure.

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Aliaga-Caro, Jose 00:57:54.424 --> 00:57:58.834
Just so, uh, yeah. Oh, go.

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Roni Mejia - SCE 00:58:00.154 --> 00:58:15.484
Yeah, so so, I think, uh, this was a, you know, a topic of discussion that came up during the, uh, the workshop, uh, at the last workshop. And I think, uh, there's a few. I think folks who made mention of, uh, that in.

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Roni Mejia - SCE 00:58:15.635 --> 00:58:36.635
You know, the, the asking for the quarterly report, uh, from the, uh, from the customers, um, that perhaps do not want or do, uh, do not have, um, uh, what is it, a telemetry and that perhaps we could leverage our data.

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Roni Mejia - SCE 00:58:36.664 --> 00:58:57.634
To, uh, to monitor, or extract the information so that we can do, uh, kind of like a QA if you will our QC, uh, to make sure that the, uh, the profiles that have been defined in the application process are actually being followed. And, uh, we went back.

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Roni Mejia - SCE 00:58:58.264 --> 00:59:14.704
Uh, each of the utilities to see whether or not, uh, our has the capability to do that and, um, based on our, our discussions internally, uh, we actually, uh, discussions that with our, uh.

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Roni Mejia - SCE 00:59:14.734 --> 00:59:35.854
Experts we did find that we are actually have the ability to, uh, extract the information, uh, from, uh, my, uh, data to be able to monitor the, uh, those profiles. And, uh, and so, for for this, uh, specific.

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Roni Mejia - SCE 00:59:35.884 --> 00:59:57.004
Reporting, uh, the, the are are comfortable with not requiring this, uh, this reporting anymore, because we will be leveraging, uh, the data. And, uh, and just to clarify here, this is for projects under would name play, uh, under 1 megawatt because.

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Roni Mejia - SCE 00:59:57.274 --> 01:00:05.674
Above 1 megawatt telemetry, so ready required, uh, per rule 21. so that was not the subsequent question. So.

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Roni Mejia - SCE 01:00:09.695 --> 01:00:12.815
So, any thoughts there, any questions for for us.

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Aliaga-Caro, Jose 01:00:14.285 --> 01:00:22.325
Okay, uh, thank you Ronnie for that. So it looks like we have actually resolved a.

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Aliaga-Caro, Jose 01:00:24.905 --> 01:00:30.365
1 of the issues from, uh, that was teed up for resolution 5,230, which.

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Roni Mejia - SCE 01:00:30.365 --> 01:00:30.575
Was.

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Roni Mejia - SCE 01:00:34.024 --> 01:00:37.054
Yeah, no, I, I think this is a perfect way to start.

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Aliaga-Caro, Jose 01:00:39.514 --> 01:00:59.704
Yeah, all right there may be some terra language that needs to be developed, but I think we're, you know, I think we're now at a very good place that, you know, quarter we're reporting will not be required and, you know, data will be used for projects into 1 megawatt.

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Aliaga-Caro, Jose 01:01:00.484 --> 01:01:11.344
And for, uh, project over 1 megawatt telemetry, because it's already required, anyways will be used.

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Roni Mejia - SCE 01:01:11.944 --> 01:01:12.874
That's correct.

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Aliaga-Caro, Jose 01:01:14.194 --> 01:01:16.444
So, I think Brian, did you have a, a.

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Brian Lydic - IREC 01:01:19.624 --> 01:01:21.604
Hi, just wanted to check.

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Brian Lydic - IREC 01:01:21.844 --> 01:01:38.614
With the systems that do have telemetry, I don't know that they're already monitoring export values, export power. And so would that be a change to your handbook that you need to make to require that of those systems?

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Roni Mejia - SCE 01:01:44.165 --> 01:01:45.425
I, I'm not sure.

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Roger Salas SCE 01:01:45.995 --> 01:02:01.085
I can answer that. I mean, that's that's a good point. And, and it is likely that you're not able to monitor, uh, the export with the telemetry as as correctly is, uh, then we may just have to.

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Roger Salas SCE 01:02:01.114 --> 01:02:03.274
You say, my, even for the larger systems.

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Brian Lydic - IREC 01:02:04.084 --> 01:02:04.384
Hmm.

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Roger Salas SCE 01:02:05.584 --> 01:02:09.514
Let's say there are not really sure really impact. Uh, this is the change.

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Brian Lydic - IREC 01:02:10.684 --> 01:02:11.314
Okay, thanks.

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Alex Mwaura PG&E 01:02:13.715 --> 01:02:19.505
Uh, this is Alex from PG. E. so, Brian, I just want to make sure I understand your question. Are you saying that.

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Alex Mwaura PG&E 01:02:21.094 --> 01:02:27.544
Are you asking if the utilities are willing to use in lieu of telemetry? Is that your customer.

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Brian Lydic - IREC 01:02:29.704 --> 01:02:50.404
That wasn't my question, but that might be a solution to it. So, I guess my question is, are you already requiring export data through the telemetry requirements and if not, you know, how would you go about getting? Would you, would you be changing your telemetry requirements to require.

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Brian Lydic - IREC 01:02:52.025 --> 01:02:55.775
Or, yeah, like Roger said, maybe you could use for those cases as well.

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Alex Mwaura PG&E 01:02:56.525 --> 01:03:11.585
Yeah, so I think based on this slide for projects that are over 1, Meg, the list of PG need, the telemetry requirements would not change. So, you know, at this time we have a low cost telemetry that has.

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Alex Mwaura PG&E 01:03:11.644 --> 01:03:21.334
A potential to measure output at the generation into connection and also at the T. um, but the.

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Brian Lydic - IREC 01:03:21.334 --> 01:03:21.484
Is.

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Alex Mwaura PG&E 01:03:21.484 --> 01:03:32.134
Not to replace telemetry with because 1 of the challenges is is right now the system that we use 1st of all, not a real time.

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Alex Mwaura PG&E 01:03:32.765 --> 01:03:52.385
Secondly, we have to go fix that data versus where telemetry and, uh, solutions typically come through the scanner system and, uh, you know, readily available to operations and, uh, and distribution engineers. So, I list for PG E right now we're not going to replace telemetry requirements with solutions.

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Brian Lydic - IREC 01:03:53.585 --> 01:03:53.885
Got.

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Brian Lydic - IREC 01:03:53.974 --> 01:03:58.354
Yeah, so you've already got that capability through the telemetry. That's that's good to hear.

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Alex Mwaura PG&E 01:03:58.474 --> 01:03:59.584
Yes, yes.

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Roger Salas SCE 01:04:00.154 --> 01:04:15.034
And just to make it abundantly clear for, I see where we're not proposing to change any of the telemetry requirements. All I was saying, is that if for those systems, right what, if we are not able to make sure the BCC.

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Roger Salas SCE 01:04:15.039 --> 01:04:17.854
As well as the, uh, as the.

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Roger Salas SCE 01:04:18.124 --> 01:04:24.904
And PG need us, then we will complement the use. We will complain with the use.

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Roger Salas SCE 01:04:25.925 --> 01:04:31.835
With how the adding additional requirements, but at the limit requirements requirements will remain the same.

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Roni Mejia - SCE 01:04:35.645 --> 01:04:36.635
Thank you Roger.

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Frances Cleveland 01:04:42.034 --> 01:05:00.154
Maybe just 1 additional, uh, question on that, which is, um, how, uh, what's the latency for getting the, um, data, uh, available.

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Frances Cleveland 01:05:00.515 --> 01:05:06.335
Um, our minutes day, hours days, what sort of time frame are we talking about?

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Roger Salas SCE 01:05:08.315 --> 01:05:21.305
I see it's 1 day late, uh, minimum. So that's my understanding. So so again, that's why we can probably use it for verification performance, uh, for an project, but we could not use it for real.

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Roger Salas SCE 01:05:21.334 --> 01:05:24.034
Time operations, and that's why that the limit requirements for me to say.

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Frances Cleveland 01:05:26.464 --> 01:05:26.854
Thank you.

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Roni Mejia - SCE 01:05:37.744 --> 01:05:40.174
So, let's move on, uh, to the, uh.

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Roni Mejia - SCE 01:05:44.284 --> 01:05:50.734
Slide 8 slide 6. I'm sorry.

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Aliaga-Caro, Jose 01:05:52.774 --> 01:05:53.914
I think slide 5.

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Roni Mejia - SCE 01:05:58.324 --> 01:05:58.774
Yeah.

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Aliaga-Caro, Jose 01:05:59.794 --> 01:06:00.874
Oh, no sorry.

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Roni Mejia - SCE 01:06:00.904 --> 01:06:17.524
Yes, yeah slide 5 Thank you. You heard me? Yeah, so so this is, uh, this is, uh, our, uh, our queue, uh, for starting on the, uh, on the subjects, uh, following up on the November.

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Roni Mejia - SCE 01:06:17.914 --> 01:06:38.854
Workshop, so, let's go ahead and, um, dive in into the next slide. So, we, we created this slide because, uh, we, we wanted to make sure that, uh, 1, we wanted to get some feedback from from the stakeholders here and, uh, based on our understanding of the last, uh.

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Roni Mejia - SCE 01:06:38.914 --> 01:07:00.004
Shop, uh, there was a lot of discussions about, uh, how an unforeseen reduction of load could potentially impact the, uh, conditions of the grid. Thereby causing a reduction in the hosting capacity. Thereby potentially impacting the, uh, profile of.

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Roni Mejia - SCE 01:07:00.009 --> 01:07:21.154
Of the customer we also touched on, uh, the, um, the, that as we, because we don't have these types of projects currently, uh, interconnected into our system. Uh, we don't really, really have the, uh, real time.

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Roni Mejia - SCE 01:07:21.185 --> 01:07:42.305
Operational experience or historical experience, and operating these types of projects and as we, uh, will be interconnecting, this type of project will be gaining a lot of experience and better and having better data right. To assess any impacts of, of, uh, that maybe this system conditions.

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Roni Mejia - SCE 01:07:42.334 --> 01:07:46.024
They have, uh, on the projects or not.

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Roni Mejia - SCE 01:07:48.364 --> 01:08:08.854
And, uh, another bullet item that, uh, that was discussed and brought up. And I think, uh, Brian, I think Brad may have brought this 1 up. And this had to do with, uh, clarification on, uh, when we will be reducing if, uh, if a retroactive reduction of an project will occur.

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Roni Mejia - SCE 01:08:09.184 --> 01:08:30.094
Um, this will not happen from the, uh, nameplate rating of the project. But rather from the profile that had originally been, uh, I guess, uh, agreed upon, uh, during the, our inner connection, uh, the initial interconnection, uh, process.

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Roni Mejia - SCE 01:08:30.454 --> 01:08:51.394
So wanted to kind of highlight this item here, because we thought it's, uh, it's important. Um, but with that, I'll go ahead and maybe open it up for feedback to see, uh, the, this does everyone agree that this, uh, at least in, in, uh, I guess, uh, in general that we.

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Roni Mejia - SCE 01:08:51.514 --> 01:08:59.314
We understand that this these are true or or you think that maybe we misrepresented what what we have here in the slides.

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Sky Stanfield 01:09:03.845 --> 01:09:18.154
Good morning. This is sky. I have just I wonder if you could explain the last Pro, the last bullet um, I don't necessarily disagree with that. I guess I'm trying to understand what I don't remember. What conversation led to that 1 or what what that means. Exactly.

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Roni Mejia - SCE 01:09:18.875 --> 01:09:23.825
Yes, I, if you remember, I think, uh, the I had a, what I was this.

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Roni Mejia - SCE 01:09:23.974 --> 01:09:44.133
Playing a, uh, a, a, a slide, which had the, uh, uh, the a graph of the profile and, uh, it just so happened that in this specific graph. The nameplate rating of the of the generator was.

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Roni Mejia - SCE 01:09:44.979 --> 01:10:06.034
1 was the initial profile, right? Because it just so happened that the, uh, the ACA, uh, the ACA values were right, right above that name nameplate rating and I think it was 2 megawatts a recall. And so when we were reducing where we were reducing the profile, that specific generator, it was being done from the.

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Roni Mejia - SCE 01:10:06.215 --> 01:10:27.275
Rating, but because of the, it just so happened that that's how the example was there was some discussion about that. And then we said, well, think about it, if it wasn't the 3 megawatt nameplate rating generator, then the profile would have been, like, 2.5 or something like that. And I think that's where the discussion, uh, uh, kind of.

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Roni Mejia - SCE 01:10:27.304 --> 01:10:27.754
From.

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Roni Mejia - SCE 01:10:30.125 --> 01:10:36.485
I think the, the example maybe was, uh, could have been better that, uh, discussion.

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Roni Mejia - SCE 01:10:40.024 --> 01:10:44.134
Yeah, I don't have a graph otherwise I would display it, but, uh.

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Sky Stanfield 01:10:45.814 --> 01:10:48.664
Okay, thanks.

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Roni Mejia - SCE 01:10:57.694 --> 01:10:58.774
Any other questions.

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Roni Mejia - SCE 01:11:08.405 --> 01:11:16.325
All right, so I have no questions. So, um, I'll move on to the next slide and I'll go ahead and hand it over to Alex.

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Alex Mwaura PG&E 01:11:22.774 --> 01:11:24.424
Hey, good morning. Everyone can you hear me? Okay.

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Sky Stanfield 01:11:30.094 --> 01:11:30.334
I.

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Roni Mejia - SCE 01:11:30.334 --> 01:11:31.204
You can hear you Alex.

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Alex Mwaura PG&E 01:11:31.234 --> 01:11:47.644
Oh, perfect. All right, my name is Alex. I Jenny, and I'll be going over some slides so 1st of all I'd like to apologize in advance. I am having some bandwidth and camera issues, so I'm not going to be able to turn on my camera today. I'll try to resolve those.

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Alex Mwaura PG&E 01:11:47.674 --> 01:12:08.794
For the next workshop and, uh, hopefully be uncovered then. So I'll be going over some non consensus topics. The 1st 1 has to do with this issue of reduction in level due to subs reduction. So it is the I use contention that the CPC decision does not.

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Alex Mwaura PG&E 01:12:08.915 --> 01:12:29.915
Allow us to charge other customers on the distribution system. So, lots of ability for customers to be able to export about the level. Um, we also feel like the decision did allow the. I used to.

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Alex Mwaura PG&E 01:12:29.974 --> 01:12:51.094
Be able to reduce the export value to the value to ensure safety and reliability without having to do great updates. Uh, although the decision allows for customers to provide a profile that, you know, based on the value.

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Alex Mwaura PG&E 01:12:51.125 --> 01:12:55.955
We do not feel like it requires the I used to guarantee that profile.

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Alex Mwaura PG&E 01:12:59.524 --> 01:13:03.634
We understand that the stakeholders view is that.

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Alex Mwaura PG&E 01:13:05.404 --> 01:13:25.984
They should be a guarantee, but we believe that this is a non starter for the, the 2nd, non consistent consensus item has to do with the issue of 24 versus to 88 values. Um, we still I still feel like the decision is pretty clear in in.

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Alex Mwaura PG&E 01:13:26.375 --> 01:13:47.465
It allows for all monthly values. So, you know, our intention is that customers will be able to go to the ACA maps and download the profiles and be able to generate a 1212, different value profiles. So, basically, 1 value per month, 12 values for the whole year. And provide that as part of the.

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Alex Mwaura PG&E 01:13:47.499 --> 01:14:08.434
Project application, the card item has to do with the risk of cost of upgrades to return an project that has been reduced to the original approval limits. So the, I use, uh, views that customers are getting.

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Alex Mwaura PG&E 01:14:08.854 --> 01:14:29.674
Commercial benefit of increased generation, when, you know, typically they will be limited to an value, but obviously you're able to generate at a higher values when the system is normal and therefore that, you know, they should hold the risk of the cost of upgrades. Although the limit to the value.

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Alex Mwaura PG&E 01:14:32.645 --> 01:14:50.405
And 9 hours, stakeholders, obviously view that I use subsequently already the risk to support California energy goals. So I'll pause here for these non consensus items because I believe probably will have some discussion. I see. I mean, has his hand up. So.

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Younes, Amin 01:14:51.244 --> 01:15:11.614
Yeah, hi, I'm a I mean, units from Cal advocates, I don't think that this accurately represents, um, what I've been saying, or what I said in the last meeting. Um, I guess I'll start by reiterating that catalog because has no established positions on this particular, uh, on any of these topics.

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Younes, Amin 01:15:12.605 --> 01:15:33.215
I don't think that we generally hold particularly this last view. Uh, I don't think that we typically support the position that, um, ratepayers should be the ones paying for California is, uh, energy goals beyond, beyond with absolutely.

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Younes, Amin 01:15:33.484 --> 01:15:54.394
And I don't think that anything that I said previously would align with what's written here for the position of advocates. I anything that I said was was kind of based on an interpretation of what I was hearing from energy division that it seemed like it was a fairly high bar to treat.

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Younes, Amin 01:15:54.544 --> 01:16:15.484
Separately, and that, you know, that perhaps we haven't shown that yet. So it was more of a kind of kind of analysis of what the direction that we were interpreting the commission wanted to take on this, rather than then then get the position, but just.

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Younes, Amin 01:16:15.575 --> 01:16:36.665
Iterate we do not take that deposition stated there as to the middle bullet on the 288 values. I actually don't think that's accurate either. I mean, based on my reading, I tend to agree with the interpretation of how that's written. I don't think that that actually matters very much because it's going to be.

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Younes, Amin 01:16:36.724 --> 01:16:57.844
The commission to decide what they meant when they were hopefully when they respond to the comments on resolution 50 to 30 where the, I believe specifically asked for clarification of that issue. My take, at this point would be that if we're moving forward.

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Younes, Amin 01:16:57.875 --> 01:17:13.985
At this point we should be moving forward is if we don't know how many values it's going to be. So we should leave flexibility in terms of how things are, are, you know, particularly how that file is formatted. So we can accommodate 288 values. If if we get that direction from the commission, or that.

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Younes, Amin 01:17:15.274 --> 01:17:35.914
Uh, and then on the 1st, 1, I also don't really agree that that is the position that that I kind of took that that is a position that I think I wreck my interpretation that that's what I Rick was saying, and, you know, I don't have any evidence to disagree with what Iraq is saying, but I don't have any evidence either.

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Younes, Amin 01:17:35.944 --> 01:17:57.064
To to say that I Rick was right and I don't we certainly don't speak for for interconnection customers or for the, for the developers on that topic. I would actually on that, that 1st topic, whether no guarantee of LGB profiles is a non starter. I would actually.

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Younes, Amin 01:17:57.069 --> 01:18:18.034
Interested in, seeing some, some evidence from Iraq on that. Because I mean, I guess my personal impression is that any developer is taking on some risk by interconnecting a project. I don't necessarily believe that. They're just going to walk away. If there's a small amount of risk. If they can quantify it.

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Younes, Amin 01:18:18.484 --> 01:18:21.394
Um, but I certainly understand that.

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Younes, Amin 01:18:22.449 --> 01:18:38.434
That risk is going to push some developers right away. So I would be interested in any kind of quantification or any evidence that, um, of the exact of how much of a non starter that would be for developers and that is, uh, that's it for me. Right now.

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Alex Mwaura PG&E 01:18:43.324 --> 01:18:44.314
Thanks for your thoughts.

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Alex Mwaura PG&E 01:18:46.594 --> 01:18:47.464
For Justin.

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Regnier, Justin 01:18:49.865 --> 01:18:52.745
Let me defer to Scott. This is more for.

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Sky Stanfield 01:18:55.115 --> 01:19:16.025
I was just going to say, Justin, I was just going to say that in the presentation that we are going to give later. I can talk a little bit more to that, or I'm happy to talk to it. Now. I think those are our fair points that we need to discuss a little bit more in terms of what position is and then also what we've, the outreach we've been trying to do.

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Sky Stanfield 01:19:16.054 --> 01:19:37.174
To come up with a proposal, I think, when the thing that is maybe a little bit subtle here is, I don't think that it's fair to say that the developers and again, I don't speak for developers either, but based on the conversations we've been having, and our basic gut sense on.

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Sky Stanfield 01:19:37.235 --> 01:19:57.635
What would be is not that they can't take on any risk. It's that they can't take on unlimited risk and undefined risk. And that's the part. I think that's more problematic. And then, as I'll discuss later today, I think defining what it's it's hard to get to.

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Sky Stanfield 01:19:58.474 --> 01:20:19.474
No way to cap I'm just going to use that as a broad term the risk. So that's what's driving that position but I'll talk. We can talk more about those issues, but I want to be clear that nobody is saying that developers can't take on any risk. The problem is, is that it's the problem for both the ratepayers and the customers here, is that the risk is.

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Sky Stanfield 01:20:19.534 --> 01:20:21.784
And we don't have right.

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Alex Mwaura PG&E 01:20:34.745 --> 01:20:36.515
Just ended you still have something to say.

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Regnier, Justin 01:20:37.265 --> 01:20:51.905
I did, I think a lot of what I had in mind was has already been said, but let me fill in the holes. And in terms of what I had in mind, um, just in terms of that 1st, sub decision is not grant the utilities, the authority.

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Regnier, Justin 01:20:53.045 --> 01:21:13.055
I think that's technically accurate, but in our last discussions in workshop number 1, particularly gary's conversation, uh, I think we established that, um, while the decision doesn't, you know, grant, utilities, the authority common practice.

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Regnier, Justin 01:21:13.059 --> 01:21:34.024
to for any upgrade that is required to allow facilities to operate within their interconnection agreement would already be done by our use and rate based that these things are widely seen as prudent investments eligible for inclusion in the rate base and we just haven't set up a separate customer class 

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Regnier, Justin 01:21:34.234 --> 01:21:55.324
Um, in terms of the elements that's underlined there in the next bullet without grid upgrades. I would note that without a grid upgrades refers to upgrades or updates at the time of interconnection. Um, again referencing the I use discussion. So, you know, there is no such thing as permanent.

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Regnier, Justin 01:21:55.384 --> 01:22:15.574
in the grid which is fair and the interconnection process is a point in time so it doesn't permanently constrain the status of the grid from then forward so i would note that the without grid updates um my interpretation and those is the the staff and this is the one that matters um is that 

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Regnier, Justin 01:22:16.535 --> 01:22:37.625
That's to do with grid updates at the time of interconnection because we're, we're talking about an interconnection process. I Deco skies. Sky means discussion that the non stakeholders view no guarantee of LGB profiles is a non starter is a little off. Um.

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Regnier, Justin 01:22:37.660 --> 01:22:58.625
Take away from Eva and others discussion, was that no guarantee of a reliable financial return as a non starter, but they're willing to share some of the risk. And as long as the curtailment or the risk is as well bounded and bankable they're okay with it. And finally, I would just say that our last.

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Regnier, Justin 01:22:59.164 --> 01:23:15.454
Discussions discuss both risk and benefit so the, the point that a higher utilization of existing infrastructure benefits, all rate pairs was made by several parties and I think Warren's consideration on this discussion. So that's all. I got.

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Aliaga-Caro, Jose 01:23:22.834 --> 01:23:24.814
And Gary, you had your hand.

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gary holdsworth sdg&e 01:23:28.175 --> 01:23:33.275
Uh, yes, and unfortunately, my video is not working today either. But can you hear me.

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Aliaga-Caro, Jose 01:23:36.904 --> 01:23:37.864
Yes, we can get.

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gary holdsworth sdg&e 01:23:38.554 --> 01:23:56.614
Um, trying to unpack a little bit of justin's last riff there there was a lot in there that either agreed with, or didn't agree with. But you made a statement, Justin I'm trying to for the record. You made a statement that made it sound.

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gary holdsworth sdg&e 01:23:56.645 --> 01:24:04.445
The use our funding, I'll upgrades and that's not the case. Maybe I misunderstood what you said.

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gary holdsworth sdg&e 01:24:07.805 --> 01:24:15.245
Cause the classic structure is the developer funds, the upgrades for distribution upgrades.

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Regnier, Justin 01:24:15.605 --> 01:24:15.935
Right.

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gary holdsworth sdg&e 01:24:16.055 --> 01:24:22.145
Talking about them that has the exception to that rule now under megawatt.

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Regnier, Justin 01:24:23.015 --> 01:24:27.125
Thank you for for, um, bringing that clarification that.

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Regnier, Justin 01:24:28.025 --> 01:24:48.755
My my statement was in reference to future upgrades, so, if there are upgrades subsequent interconnection on this, this goes to what this guy was talking about, the 2 different classes of risk, and the last workshop, the risk prior to interconnection and the risk after connection that if something is required to be done to the grid to allow customers.

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Regnier, Justin 01:24:48.789 --> 01:24:57.094
To continue to operate within the bounds of their interconnection agreement, or their terms of service on load but that's something that the use.

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Regnier, Justin 01:24:57.484 --> 01:25:06.064
Um, business as usual process is to do within their planning process and then include into rate base.

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gary holdsworth sdg&e 01:25:06.304 --> 01:25:10.144
Within the planning process yes. Okay. I now I'm following, you.

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gary holdsworth sdg&e 01:25:11.375 --> 01:25:12.905
Thank you for that clarification.

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Alex Mwaura PG&E 01:25:23.194 --> 01:25:42.364
all right very good discussion um looking forward to sky's presentation and uh also sounds really good that i mean or bullet number two is consistent with the interpretation as far as the twenty four of us as two hundred and eight move to the next slide 

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Alex Mwaura PG&E 01:25:42.425 --> 01:25:42.845
Please.

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Alex Mwaura PG&E 01:25:47.704 --> 01:26:06.334
So, this slide is just going over a summary of workshop topics. I'll go over this quickly topic. Number 1, is what may be needed for 1st, iteration of the process and what data experience is needed for future iterations to refine the process and meet its.

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Alex Mwaura PG&E 01:26:06.424 --> 01:26:27.184
Of taking advantage of available grid, capacity topic, number 2 will address output and when reductions occur topic, number 3, the discussion of how the process for topic number 2 topic number 4 goes over the output reductions circumstances.

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Alex Mwaura PG&E 01:26:27.845 --> 01:26:43.295
Topic number 5 will address the format of the schedule to be submitted to allow a 288 hour profile. That's allowing flexibility for more granularity topic. Number 6. we'll go over the quarterly reporting, which is.

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Alex Mwaura PG&E 01:26:44.585 --> 01:26:55.625
Number 7 increased risks with projects and topic number 8, export buses, generation, template next slide. Please.

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Alex Mwaura PG&E 01:27:00.185 --> 01:27:18.215
So, for topic number 1, uh, improvements to based on experience, I think the item in red is might be a question that we got from Jose, or from the, from the commission what may be needed for 1st, iteration of process and.

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Alex Mwaura PG&E 01:27:18.249 --> 01:27:39.364
Data slash preference is needed for future iterations to refine the process and meet its goal of taking advantage of available grid capacity. So, the 1st thing we think needs to happen is we need to modify the rule 21 tariffs in accordance with regulatory authorization.

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Alex Mwaura PG&E 01:27:39.544 --> 01:27:59.914
Jp, as far as data that we need for the 1st iteration, we believe that a minimum of 2 to 3 years will be sufficient or required to collect data. We need to allow for 12 month profile for customers. This will be.

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Alex Mwaura PG&E 01:28:00.549 --> 01:28:08.554
Find different value per month. We also need an ability to be able to monitor export.

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Alex Mwaura PG&E 01:28:11.314 --> 01:28:31.564
The monitoring will be at the point of common coupling with the grid and this was already covered before I use we're asking for either a quality report from the customers or telemetry and this issue has been laid to rest, or are able to leverage the.

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Alex Mwaura PG&E 01:28:31.569 --> 01:28:44.734
This team and will be able to monitor using the already available systems, except for projects that are over 1 megawatt, which require telemetry based on the current rule. 2100. go ahead.

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Sky Stanfield 01:28:49.234 --> 01:28:51.484
Alex, go ahead. And are you finished with that?

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Alex Mwaura PG&E 01:28:51.694 --> 01:28:53.194
No, I'm not finished, but I okay you want me to.

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Sky Stanfield 01:28:53.824 --> 01:28:54.844
Yeah, finish that person.

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Alex Mwaura PG&E 01:28:54.904 --> 01:28:56.974
Okay, sure. Okay. Let's go back to that slide.

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Alex Mwaura PG&E 01:29:02.524 --> 01:29:19.684
So, the next item is, uh, we, we'd like to CPC to allow the I used to be able to reduce the export value to the value. If, uh, 17 reliability concerns warranty.

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Alex Mwaura PG&E 01:29:20.919 --> 01:29:42.064
And then we also want the opportunity to understand impacts during this 1st iteration the projects when the system do during normal and abnormal operating conditions as far as data experience that we'll need, we profile reduction capabilities. And.

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Alex Mwaura PG&E 01:29:42.094 --> 01:29:50.494
Triggering events conditions, we also would like to know whether or not approved for. Are.

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Alex Mwaura PG&E 01:29:50.644 --> 01:30:11.494
With their profile, and then we would like to understand how many times projects to us to reduce below the approved profile. And then also the subset of that we want to know how quickly customers can implement reductions to the approved. Great.

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Sky Stanfield 01:30:15.485 --> 01:30:28.205
Okay, thanks, Alex. Um, so I guess I'm a little bit when we 1st started talking about doing sort of an iteration or a test period, or whatever we're going to call it.

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Sky Stanfield 01:30:30.965 --> 01:30:50.975
1st of all the commissions order doesn't doesn't lay out a test period. And when I'm not entirely clear, I understand, is why the utilities based on your position that the customer should bear all the liability, wants it or is proposing a test period at all like, what's the benefit of the test period? The all the additional data that you're asking for.

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Sky Stanfield 01:30:51.395 --> 01:31:12.215
You're going to have that data. You just talked about that the, and the telemetry. I'm not really clear what you guys are seeking to get out of a test period based upon the, your position that either way the customer should bear all the responsibility for the low the profile reduction.

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Alex Mwaura PG&E 01:31:15.424 --> 01:31:32.854
So, I'll go 1st, then I'll ask my colleagues from the other utilities to chime in. So, 1 of the main things that I think this test period will inform is this issue of 12 months, 12 monthly. I mean, 12 is 1 per month for 12 per year versus 208.

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Alex Mwaura PG&E 01:31:33.514 --> 01:31:54.604
Uh, if you remember during the last presentation, our contention was that if we go to 288, it introduces this additional risk. And 1 of the things I would probably would line in this 2 to 3 years of collecting data is whether, you know, that is in fact a true thing or not. And we would allow customers to have more granularity rather than.

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Alex Mwaura PG&E 01:31:54.634 --> 01:31:58.864
Have 12 monthly values, or if anybody else wants to add any other items.

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Sky Stanfield 01:31:58.894 --> 01:32:15.394
Let me, let me just jump in. So Here's why I'm asking that. I, that makes some sense to me, although I may disagree about whether we should wait to do the 288 but I understand why why you're proposing that. But what the problem to me, and you may.

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Sky Stanfield 01:32:16.205 --> 01:32:36.125
People may disagree with me, but I think that it's hard to, without somebody saying, they would do it to disagree with it on this. It the problem, with this proposal is that nobody's going to build an project. You're not going to get 2 to 3 years of data.

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Sky Stanfield 01:32:37.145 --> 01:32:58.025
A customer has to bear the full responsibility. Now. I like I said, I could be wrong. We haven't heard from any developer that they'd say we'll take on this risk and we'll build a project. Um, but it seems to me, like, it would be a huge amount of time and effort for all of us to write all the terrible language and go ahead. When our expectation is that the risk is so high.

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Sky Stanfield 01:32:58.059 --> 01:33:18.814
Customer can't do it. So, this idea of saying, well, we're going to do a 2 to 3 test period, but the conditions won't allow anybody to actually test is the problem to me. And I feel like the utility proposal is not helping us, get to that point. Where we have anything to test and I agree and fully supportive of.

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Sky Stanfield 01:33:19.384 --> 01:33:25.624
A test for a variety of reasons, but we have to make the starting condition such that we have something to test.

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Roger Salas SCE 01:33:28.354 --> 01:33:29.014
Don't respond to that.

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Roger Salas SCE 01:33:30.545 --> 01:33:51.545
I mean, yeah, I think that's that in itself is a good data point sky. I mean, you're assuming that nobody is going to participate well, that in itself would be a good data to have, you know, whether or not as a reality or not. And again, I think this procedurally speaking, it appears that if you have some.

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Roger Salas SCE 01:33:51.785 --> 01:34:05.465
Or no data as indicated, then there may be a lot a little bit easier to sort of make a modification to the rules. If you want to call it that.

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Sky Stanfield 01:34:07.594 --> 01:34:20.134
Position change Roger, if you say, okay, so nobody you want to spend all of our time. We have hundreds of hours for all of us to write the tariff language with the idea that maybe nobody will do it. And then, where are we in 2 years.

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Sky Stanfield 01:34:22.804 --> 01:34:24.184
Because we won't have any.

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Roger Salas SCE 01:34:24.604 --> 01:34:28.504
We've done that before Skype I mean, you, you may recall the customer.

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Sky Stanfield 01:34:29.164 --> 01:34:30.124
That's what I'm trying to avoid.

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Roger Salas SCE 01:34:33.994 --> 01:34:53.464
Right. You know you're right. I mean, but again, I mean, I see there this or or or or sort of, you know, going full on the way we proposing as well. I mean, we, we really cannot take. We really cannot do anything what you're asking us to do, which is take that additional risk on behalf of our customers.

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Roger Salas SCE 01:34:55.385 --> 01:35:07.685
So, it's either get some data, you know, hopefully we get something, make a decision on that and determine the risks or not. And, you know, maybe we have some information. Maybe we don't but at least it's something better than nothing.

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Sky Stanfield 01:35:09.035 --> 01:35:14.825
But it's not it is nothing, right? So, I mean, we'll see. Well, I don't know until we talked about.

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Sky Stanfield 01:35:14.854 --> 01:35:33.484
With our presentation, but I think we've laid it out here that what this proposal is risks. Absolutely nothing happening and no learning happening for 2 to 3 year, period and I could be wrong. I know that. But, but all odds suggests that I'm probably not too wrong at least here.

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Frances Cleveland 01:35:35.764 --> 01:35:55.714
Well, I'd like to explore the opposite direction. So if you have this sort of test period, do you expect that after, let's say the 1st, you've got a 12 month profile, uh, that you will change that profile based on.

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Frances Cleveland 01:35:55.744 --> 01:36:16.534
Your experience, including making it less stringent, making it relaxed and then a part of it, you've got more now, the monitoring capabilities using data not not real time and that's fine.

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Frances Cleveland 01:36:17.165 --> 01:36:38.015
But would this allow you then to say well, the, for this month is X, but we recognize that we actually don't need to have it that stringent and we could relax it to something else during that.

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Frances Cleveland 01:36:38.974 --> 01:36:59.104
Given the idea that you could bring it back to the regular, not the lowest 1, but the regular, uh, value. So, what I'm trying to do is look on the good side, the benefits side so that maybe we can balance the risk against.

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Frances Cleveland 01:36:59.194 --> 01:37:20.284
Potential benefits, if you could improve the profile at the end of, say, 12 months and or even during that 12 months, improve the profile by just allowing the customer to export more based.

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Frances Cleveland 01:37:20.344 --> 01:37:23.614
On your current findings and the data.

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Roger Salas SCE 01:37:28.594 --> 01:37:46.954
I, I would say that, you know, having some information as to whether the PCs is supporting properly and following the course properly and 12 months. If you find that to that. So current, then that definitely gives us more comfort to go higher granularity. But again.

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Roger Salas SCE 01:37:47.164 --> 01:37:51.784
That's what a good day would give us. We'll give us some information on that.

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Frances Cleveland 01:37:52.864 --> 01:38:06.244
So, would you be able to modify the interconnection agreement at that point in time? Or would that be part of the interconnection agreement to review the profile and make changes as necessary?

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Roger Salas SCE 01:38:08.345 --> 01:38:11.405
Yeah, I don't know about that. I mean, what to think about that I'm not sure about.

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Alex Mwaura PG&E 01:38:12.485 --> 01:38:29.405
Yeah, I, I, I think, uh, for the projects that are already connected already have an interconnection agreement. I don't think they can just, you know, go back and change the profile. I think it would have to be what we learn would be applied to future projects. Um, and also.

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Alex Mwaura PG&E 01:38:29.824 --> 01:38:40.714
Just to make sure I understand your question and say, are you saying, are you asking whether would be able to in real time or cluster real change customer profiles.

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Frances Cleveland 01:38:44.195 --> 01:39:04.655
Change the profile in other words, that would still be a limit on the books, but you could say for the next 2 weeks, because I, you know, you've got load forecast. You've got all of this other information and you can see what the customer the customer is doing. We'll let you go.

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Frances Cleveland 01:39:04.684 --> 01:39:12.064
From 70% reduction to 80% reduction. In other words, relax the requirements.

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Alex Mwaura PG&E 01:39:13.564 --> 01:39:14.674
Yeah, I think we have.

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Alex Mwaura PG&E 01:39:17.614 --> 01:39:37.084
We have a slide that sort of touches I think, for if I'm understanding you correctly, you know, that sort of, uh, operational flexibility if you will would have to be coupled with additional tools, um, that the utility.

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Alex Mwaura PG&E 01:39:37.234 --> 01:39:51.724
Uh, planning to have in the future, and maybe if we have that, you know, those kinds of tools, then we'll be able to have enough comfort level to do what you're suggesting. Um, I don't believe that, you know, what we learn from this.

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Alex Mwaura PG&E 01:39:54.455 --> 01:40:01.565
Uh, would would be able to inform us to go to what you're suggesting, but I don't know if others feel the same way.

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Roger Salas SCE 01:40:02.345 --> 01:40:15.155
If your customer wants to change that where they're operating, there's mechanisms in there that allows changes they what changes they can and cannot make. So as long as they're those are.

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Roger Salas SCE 01:40:15.184 --> 01:40:25.744
Is that are allowable then? Then that's possible but I'm, I'm suspecting that that the changes that you're asking, for instance, with those would probably be the material and now allowed.

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Frances Cleveland 01:40:27.274 --> 01:40:35.854
Well, that may be some of the things that need to be explored, what could be put into the interconnection agreements.

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Frances Cleveland 01:40:36.724 --> 01:40:54.664
Typically, during a quote testing time, uh, that would allow, um, again, uh, changes in both directions and relaxing, uh, the, the profile as well as potentially increasing it. If there really is a problem.

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Frances Cleveland 01:40:58.384 --> 01:41:06.874
So, I'll leave it at that, but I do believe that we need to see what kinds of flexibility there are in both directions.

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Regnier, Justin 01:41:10.174 --> 01:41:19.234
So, there's been a bit of chat in the chat about developers opinions and I see that eva's hands up. And she has a developer.

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Eva Wang TotalEnergies 01:41:22.055 --> 01:41:42.575
I want to bring back just kind of a little bit about the customer's perspective on this, because I was on the sales side before so looking at the test period and looking at who could be the potential customers that who you will want to participate in the profile right like not all.

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Eva Wang TotalEnergies 01:41:42.579 --> 01:42:03.514
The customer wants you to do that, because they might have seen a lot of customers has sustainability goals that they want to export back to the grid and then offset their energy usage that that's a lot of our customer has that goes the customer. I can see.

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Eva Wang TotalEnergies 01:42:04.174 --> 01:42:24.874
Uh, the pet or or some customers, they think they might not have to pay a lot of upgrades costs. So they want that flexibility. They rather paid upfront costs and then have the flexibility of importing or exporting as much as they want. Um, the only customer that will be good for our GP.

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Eva Wang TotalEnergies 01:42:25.955 --> 01:42:39.095
Would be customers 1 doesn't have a strong sustainability goal and, um, what potentially phase? Um.

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Eva Wang TotalEnergies 01:42:40.625 --> 01:43:01.505
Much higher upgrade than anticipated and could benefit from 1st of all, not paying the upgrades and exporting to the profile that that profile has to match. Well, not match their load. Profit has to.

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Eva Wang TotalEnergies 01:43:01.564 --> 01:43:22.264
Go while with the load profiles, so they can get enough benefits from exporting back to the grade. So now it'll work. The credit they're getting by participating in. Our GP is not it's not significantly less compared to if they're just.

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Eva Wang TotalEnergies 01:43:23.314 --> 01:43:43.774
Customer, so it's very specific and I was just worried about this testing period. The 1st of all, you know, maybe like 1 of the 10 customers we have might be a good customer for and you have to tell them, like, hey, we have this 2 year period.

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Eva Wang TotalEnergies 01:43:43.864 --> 01:44:04.984
Testing period, and then after 2 to 3 years, you are still facing the risk of being limited to the lowest value. And that's a basically an acceptable risk to the customer. So, back to sky's point, like, you know, ways.

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Eva Wang TotalEnergies 01:44:05.014 --> 01:44:21.094
All these hours, creating this complicated rules and profiles, and maybe not even a lot of customers who would want to participate in the end. So I don't think that's it. What everyone wants to see.

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Eva Wang TotalEnergies 01:44:30.214 --> 01:44:34.144
Okay, it says a developers perspective, but more like customer perspective.

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Regnier, Justin 01:44:45.424 --> 01:44:57.184
In our last workshop, it sounded like there was agreement if not consensus that the most likely customers for this would be Nam above megawatt because their upgrades wouldn't be rate based anyway.

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Eva Wang TotalEnergies 01:44:57.904 --> 01:45:02.524
Yeah, yeah, it has to be about what megawatt, right? And I want to see, like.

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Eva Wang TotalEnergies 01:45:02.824 --> 01:45:23.584
You know, it depends on what's the lowest value, right? If the lowest has value is like a 5 megawatt customer, right? If the lowest values 1 megawatt, then they're facing, potentially have to regulate, like, a 4 megawatt gap and then might not want to do that. Because that's too much of a risk, but.

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Eva Wang TotalEnergies 01:45:24.364 --> 01:45:29.104
They're allowing to export 288 um.

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Eva Wang TotalEnergies 01:45:29.589 --> 01:45:48.934
How profile and most of them are close to, like, 4 or 5, like, closer to their size system size. Maybe this was, hey, this is not a bad deal right? I don't have to pay upgrades, but then I can export basically to where I was anyway, compared to.

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Regnier, Justin 01:45:49.714 --> 01:45:50.284
Profile.

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Eva Wang TotalEnergies 01:45:50.824 --> 01:46:11.794
Um, but then, you know, just 1 month or 1, you know, a few hours I have to go down to 1. that's that's. Okay. So it's it really depends. And I'm just worried to find those customers. It's 1st of all a lot of work and it's gold and then 2nd, like, if we're putting the rest of being shut down.

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Eva Wang TotalEnergies 01:46:11.915 --> 01:46:26.165
Like, in my example, 1 megawatt permanently, or you have to pay, like, 5Million dollars upgrade or, like, unlimited dollar amount of upgrade, then that's going to share the customer off from the beginning.

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Regnier, Justin 01:46:27.604 --> 01:46:48.544
So, I heard you say, a couple of different things, and I'd like to drill down if we can a little bit. Um, 1, is that the, the risk of being pulled down to the minimum value is not acceptable on. But also in a subsequent conversation that if it's a few hours.

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Regnier, Justin 01:46:48.549 --> 01:47:09.604
It's okay, and then, I think maybe I would ask your perspective as to whether whether the determinant that we should be looking at is not whether the customer gets pulled down to the minimum value ever or X number of hours. But what the impact on revenue.

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Eva Wang TotalEnergies 01:47:10.504 --> 01:47:10.714
Yeah.

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Regnier, Justin 01:47:10.744 --> 01:47:30.214
Because we know assuming, you know, this is until, and unless the commission moves on it but if you assume that the net billing tariff is going forward and the ACC is there. Then we know exactly what the value of export for each hour is going to be. And you could say that we already know that anyway through the.

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Regnier, Justin 01:47:30.875 --> 01:47:51.995
The time of use tariffs, I mean, I think we've got the tools to be able to map from not so much a, a number of reduction and minimum hours, but an actual impact on revenue but before we go through all that difficulty, I'd like to double check with the developers and industry organization.

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Regnier, Justin 01:47:52.000 --> 01:47:59.735
That really the variable that the customers care about is impact on revenue not hours of reduction.

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Eva Wang TotalEnergies 01:48:00.455 --> 01:48:12.875
That's right. Uh, especially for customers, right? They sign a contract with developers. They pay a fee or, um, dollar per kilowatt. Uh, agreed upon Pre. Agreed upon.

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Eva Wang TotalEnergies 01:48:13.714 --> 01:48:32.344
Dollar particular 1 hour, but for developers, what we really care like, for this deal to work with the customer, we need to rely on the kilowatt hours of credit working get. So it's all about revenues at the end of the day. Right? Even for negotiating that PPA.

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Eva Wang TotalEnergies 01:48:32.915 --> 01:48:54.035
To determine what's a good to have between customers really? And developers we need to know, you know, whether we're facing a limited liability down the road. Um, or like, if you talk about a few hours, then sure we can eat that right? Like, that risk we can take, but if we were talking about 10 years, 15 years.

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Eva Wang TotalEnergies 01:48:54.064 --> 01:48:57.304
Down the road, like, that's too much of risk.

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Regnier, Justin 01:48:58.954 --> 01:48:59.194
So.

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Eva Wang TotalEnergies 01:48:59.224 --> 01:49:08.284
Change is going to affect the so it's eventually going to put out to the customer and the will be too high. Then we will have a contract.

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Regnier, Justin 01:49:09.544 --> 01:49:15.184
So, I want to make sure I don't derail Alex too much here, but let me maybe we can put a pin in this. So it's.

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Regnier, Justin 01:49:15.214 --> 01:49:27.664
Sounds like the non starters are the long term uncertainty on the revenue impact. So, as long as there's a certainty over long term of the revenue impact, there's space within that to work.

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Eva Wang TotalEnergies 01:49:29.674 --> 01:49:31.534
I think that's a fair statement. Yeah.

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Regnier, Justin 01:49:32.704 --> 01:49:50.404
And I know, I mean, listing a little bit last workshop around what sort of analysis to run around different scenarios. It sounds like really if we're gonna run scenario analysis, we should look at what the, the positive.

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Regnier, Justin 01:49:50.464 --> 01:50:11.584
Back to revenue would be for the extra production, unlimited generation profile and what sort of negative impact to revenue that might offset in the case that curtailment is necessary. Does that seem about okay, I'm seeing a head nod and I'm going to back off the topic because I see. Sky is.

331
Regnier, Justin 01:50:11.614 --> 01:50:14.704
Got her hand up and I know Alex has got lots of stuff to go through.

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Sky Stanfield 01:50:17.974 --> 01:50:30.904
Well, thanks, Justin, I was just going to add that. It seems to me, like, the 11 other element that we're missing and that would be needed is again, the odds that that revenue would be impacted.

333
Sky Stanfield 01:50:33.064 --> 01:50:53.824
I, it seems to me, and again, I'm not a financing expert, but that's a critical thing to understand for the customer is, how likely is it that the revenue will be impacted and then, by how much we're getting at the like, how would you, you know, potentially modeling the amount of the of the impact, but not.

334
Sky Stanfield 01:50:53.915 --> 01:51:15.035
How likely it is that that would occur and maybe that's not relevant to the calculation but it seems to me, like, it's a critical piece of actually being able to assess it. Right? Unless you think every, all the is just extra revenue, and maybe the modeling would come out that way and it didn't matter whether you got to build it or not. But I don't think.

335
Sky Stanfield 01:51:15.244 --> 01:51:17.854
Quite at that, that level of pricing.

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Regnier, Justin 01:51:20.254 --> 01:51:39.784
And I think really, the, the point that I've heard from the developers is that your costs get locked in by the infrastructure that you build. So you can run optimization through system advisor module or whatever software you're using to say, you know, we've, we've got this load. We want to battery that size. We want production at this size.

337
Regnier, Justin 01:51:41.104 --> 01:52:01.564
But at that point, you've made your choice and you have to live with the consequences. I think to the point is that we don't. We don't have you made the point last workshop that they have not run the analysis to know what the risks will be. And what I think I heard from the, and the last workshop is.

338
Regnier, Justin 01:52:01.594 --> 01:52:08.884
That the, they have no way of knowing it without actually doing it. Um.

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Sky Stanfield 01:52:12.875 --> 01:52:16.955
Right, well there's the problem is, how do we do it to get the data.

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Roger Salas SCE 01:52:17.705 --> 01:52:18.095
Do you mean you.

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Sky Stanfield 01:52:18.485 --> 01:52:31.175
I'm trying to unpack is how do we actually get some test cases that could move ahead to get any data and I also, I have 1 part of our presentation is just to talk about. I still think we need a lot more sense from how we would even.

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Sky Stanfield 01:52:31.204 --> 01:52:52.294
Figure it out with the data either today, or after a test period like, what would the data actually, tell us about the frequency of the events in the future? That I think it seems to be beyond my pay grade in terms of thinking about what we would actually learn, but we should definitely talk about it because it seems like there might be ways to figure that out but it's not clear to me what how.

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Sky Stanfield 01:52:52.354 --> 01:52:53.614
Exactly, you can figure it out.

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Alex Mwaura PG&E 01:52:55.924 --> 01:52:56.554
The 1 thing that.

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Alex Mwaura PG&E 01:52:58.205 --> 01:53:19.115
1 thing I want to point out that I think we've kind of missed in this whole discussion is, I think the assumption is that the lowest value is much much lower than the highest value. And that's not always the case. There might be a Delta, but it may not be as significant as, you know, it's probably being.

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Alex Mwaura PG&E 01:53:19.144 --> 01:53:34.894
Assumed in this discussion, so you can still have a customer that may be willing to do project. I guess it's not like every location is going to be 5 Mega, which is a maximum of 500. kilowatts is the minimum.

347
Sky Stanfield 01:53:34.954 --> 01:53:40.144
Right when the project can choose how much of that additional capacity they take to your point, Alex, you could decide.

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Sky Stanfield 01:53:40.414 --> 01:53:50.554
Only 500 kilowatts of extra capacity or whatever, but you still have to make that extra 500 kilowatts make sense and.

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Alex Mwaura PG&E 01:53:50.554 --> 01:53:51.064
Understood.

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Sky Stanfield 01:53:51.964 --> 01:53:58.084
And and we'll we can get into it a little bit more of this later again. I think we should. Well, I'm not dictating what happens next.

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Frances Cleveland 01:53:58.864 --> 01:53:59.134
Yeah.

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Alex Mwaura PG&E 01:53:59.194 --> 01:53:59.554
Okay.

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Frances Cleveland 01:54:00.574 --> 01:54:01.414
I just liked.

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Frances Cleveland 01:54:01.444 --> 01:54:22.564
Again, say that if revenue the revenue stream is the critical value of a critical issue, then we have to look at the potential ability to increase that revenue by allow.

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Frances Cleveland 01:54:23.194 --> 01:54:33.514
Um, customers to increase their export when it's, you know, above the, the normal profile of the.

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Frances Cleveland 01:54:34.205 --> 01:54:54.995
Uh, just based on reality, um, you know, a, a few days I had a few weeks ahead, whatever it might be because I see values are, of course, you know, planned years ahead. So, there's very likely and worst case for the most.

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Frances Cleveland 01:54:55.025 --> 01:55:16.145
Heart, so it's very likely to be additional room. This would be particularly beneficial if we had the 288 hourly values, rather than the monthly values. But I think this is where we really need to look at the benefits or the potential benefits side and the.

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Frances Cleveland 01:55:16.149 --> 01:55:25.054
Ability to actually increase revenues as well as the potential for lowering the revenue stream.

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Regnier, Justin 01:55:33.334 --> 01:55:54.214
I think I heard Roger respond to that, but that was, that was something that could be informed when we have better tools, such as terms in terms of the more near real time, or not near real time. Sorry, the mid mid kind of time frame, you know, days and weeks. I don't know.

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Regnier, Justin 01:55:54.220 --> 01:56:00.815
If I see it can support that, but I'd defer to Roger for my understanding of what Roger said.

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Roger Salas SCE 01:56:02.135 --> 01:56:15.305
I mean, that's part 1 of the future slides. So where, how can you increase granularity to take more advantage of the capacity in the LGB and yeah, you got it, right?

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Roger Salas SCE 01:56:16.474 --> 01:56:35.884
They are adjusting, you know, more tools, including in terms of our ability to have more situation, awareness, um, determining, you know, that is safe to operate the grid and the real time operating conditions, ability to take actions, things like that. But we can defer the discussion to to the slide where we're essentially discussing.

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Frances Cleveland 01:56:37.684 --> 01:56:57.664
But could there be a way of, um, making a, a difference and it may just be in the interconnection agreements but between the say, larger than 1 megawatt, where you have telemetry versus the, the smaller ones where you'd be using the data um.

364
Frances Cleveland 01:56:57.844 --> 01:57:07.054
Because I think that, you know, again there is a real benefit, uh, if, if you have more flexibility.

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Roger Salas SCE 01:57:09.334 --> 01:57:18.754
Yeah, there, there's more to to the risk of having more problems in the grid. Okay, so that's it's always it's always nice to hear from the other side.

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Roger Salas SCE 01:57:18.844 --> 01:57:30.784
Yeah, you have all these increased benefits, but at the end of the day with the utilities, how to figure out how to operate the grid with all these variations and that's what makes us nervous.

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Alex Mwaura PG&E 01:57:33.004 --> 01:57:53.944
So, you know, when it comes to telemetry that gives us VSI visibility, but we'd have to be able to do something with that information. So, you know, that's where the dump system would come into play. We need to have be able to have control. So, if we see that, you know, all, we're doing all getting from the telemetry information from, you know, customer site.

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Alex Mwaura PG&E 01:57:54.094 --> 01:58:01.354
The exploited amount, right? So we still need to be able to tie that to what's happening on the system and then be able to take an action.

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Frances Cleveland 01:58:03.095 --> 01:58:23.615
Yeah, I certainly agree with that. What I'm trying to do is to use this quote, testing time if, if we all agree to it, um, to come up with scenarios that could be implemented in the future because we can't say that this, you know, this.

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Frances Cleveland 01:58:23.679 --> 01:58:44.824
Process this process is, is going to be stagnant it's got to be dynamically, changing over time as more telemetry, more command capability, more terms capabilities come into place. So we have to think of it as a process not just as a static. Okay. Here.

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Frances Cleveland 01:58:44.854 --> 01:58:49.984
What we're going to do for the next 10 years that's really not how it should work.

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Roger Salas SCE 01:58:51.034 --> 01:59:05.944
Yeah, 1st, I agree with that. I mean, I think I agree with that. I mean, that's the reason why we'll work really hard to cobble that functionality in this morning borders. Right and all that communication capability. So, I mean, all those ability to change the settings, but it's really more.

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Roger Salas SCE 01:59:06.004 --> 01:59:19.624
About timing when, when are we going to be able to build our systems and how the regulation you place and enable all of those things to come together so, I think what we're talking about here is timing is just.

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Frances Cleveland 01:59:20.554 --> 01:59:27.124
I agree 100% and I think that's what's been essentially left off the table. We need to say this is.

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Frances Cleveland 01:59:27.155 --> 01:59:48.275
An interim process for what we might do in the next year or 2, but we will plan ahead for more flexibility, more telemetry, more commands, more germs, analysis capabilities, et cetera. I think we have to see this as a process, not as a static.

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Frances Cleveland 01:59:48.665 --> 01:59:50.255
You know, this is the way it is.

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Alex Mwaura PG&E 01:59:55.655 --> 01:59:58.805
Sort of what we're going to say in the slides that I mentioned.

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Alex Mwaura PG&E 02:00:05.795 --> 02:00:06.785
Any other questions.

379
Sky Stanfield 02:00:10.354 --> 02:00:27.964
I just have a comment on this conversation. Um, I don't think dermis even at the control level or and is going to change the fundamental thing that we're disagreeing about, which is, who has the liability and how do you or how do you.

380
Sky Stanfield 02:00:29.284 --> 02:00:50.284
Mitigate the risk. The problem here is the utilities aren't even if you have germs, you're still not intended to allow project to do what we're talking about, unless they bear the full responsibility. They don't see how dermis actually mitigates any of the, the customer's risk. So, I'm fully in agreement Francis thought like.

381
Sky Stanfield 02:00:50.344 --> 02:01:11.464
We want to build in the full sophistication of being able to enable these systems to operate in the manner. That's best. We forget. That is our principal goal here but James is not going to fix the, the basic issue. We're most disagreeing about at this initial stage, which is, how does a developer build a project.

382
Sky Stanfield 02:01:11.495 --> 02:01:19.625
If they have, no, if they have no guarantee that they'll be able to take advantage of any additional capacity.

383
Sky Stanfield 02:01:23.255 --> 02:01:24.365
Results any of them.

384
Roger Salas SCE 02:01:24.725 --> 02:01:43.595
I agree. That's great. I mean, basically won't allow to maximize the granularity and the profile, but, you know, it could be that those just reduces the profile because such as what the system can handle. Right and, and that may not be acceptable to.

385
Roger Salas SCE 02:01:44.254 --> 02:01:50.914
To be our operators and so, you know, there's, there's the issue again who pays for the updates that are needed.

386
Sky Stanfield 02:01:52.534 --> 02:02:13.504
For that is, is that the utilities of business model isn't driven to actually incentivize optimal use of the grid like, that's the fundamental issue. You're saying, what would be convenient, but we get a rate revenue return. If we upgrade the grid ourselves for rate pair needs, but not otherwise. So we're at this point where there's there is benefit, but the utility.

387
Sky Stanfield 02:02:13.715 --> 02:02:34.655
Instead of, and I'm not talking you Roger on that. That's just the facts. And so I think that's what the commission is gonna have to grapple with here. But I don't think getting any getting germs is really what we should be worrying about at this 1st, stage. We need to get a basic test case with a static profile that would actually allow projects to be built before we can get more. And then, I think to.

388
Sky Stanfield 02:02:34.685 --> 02:02:55.805
This is point, maybe if we do get to something that seems viable, the project will actually both be built that we could test for 2 to 3 years we should make sure we're collecting data that would enable that future conversation. But right now we're not at the point where I feel like we're going to get any data at all. So it seems a little bit beyond where we are.

389
Sky Stanfield 02:02:55.809 --> 02:02:56.524
Are at the moment.

390
Regnier, Justin 02:03:02.855 --> 02:03:03.305
From.

391
Regnier, Justin 02:03:07.414 --> 02:03:10.174
That all makes sense. Um.

392
Regnier, Justin 02:03:11.584 --> 02:03:32.434
So, there's, there's a bit of a split in the conversation I maybe want to call it out explicitly. So the, the question of how, and when curtailment happens is 1, that is separate from the question of who bears cost the question of who bears the cost.

393
Regnier, Justin 02:03:32.470 --> 02:03:53.615
Disguise point is integral to ensuring that there's actually enough uptake that this is a, an exercise that that yields useful information. I think our, our, our core necessity for this workshop, and for the advice letter subsequent is to get a well articulated set.

394
Regnier, Justin 02:03:53.644 --> 02:04:14.764
Of tariff language that addresses the weather and the how I do respect francis's perspective on the long term. But I, I know that we've got a finite amount of time and attention and effort and I want to make sure that we nail the things that we're that are our main objective before we get.

395
Regnier, Justin 02:04:14.769 --> 02:04:35.914
Too far into to optimization for future systems with that. I'm happy to turn it back over to Alex to continue on presenting the material that he has here, or have further conversation with the stakeholders based on.

396
Regnier, Justin 02:04:36.124 --> 02:04:40.714
On folks, preference, I'm going to go ahead and tag you Alex to run that.

397
Alex Mwaura PG&E 02:04:44.855 --> 02:04:51.665
All right, thank you, Justin. I don't see any more hands up, so I will go ahead and continue with the presentation next slide. Please.

398
Alex Mwaura PG&E 02:04:54.814 --> 02:05:02.914
So, topic, number 2 is output reduction element 1 for this question.

399
Alex Mwaura PG&E 02:05:04.444 --> 02:05:23.494
With the extent to which the LGB option allows for performance that avoids triggering upgrades within existing hosting capacity constraints. So they are you position is that as long as the exports at or below minimum level upgrades will be avoided.

400
Alex Mwaura PG&E 02:05:33.755 --> 02:05:34.775
Oh, Justin has it sound.

401
Regnier, Justin 02:05:36.305 --> 02:05:51.845
If we can go back 1, I think that there's, there's a bunch of asterisks which you probably had in mind when you wrote this but want to make sure that we're clear on it that the only rationale for reducing the export to minimum.

402
Regnier, Justin 02:05:52.624 --> 02:05:58.024
Level has to do with, uh, safety and reliability.

403
Alex Mwaura PG&E 02:06:03.094 --> 02:06:03.664
Yeah.

404
Regnier, Justin 02:06:06.065 --> 02:06:25.835
Okay, and I think in our prior discussion in workshop, 1, there was pretty clear agreement consensus from both and non parties that if a, that that mitigations would be undertaken even if upgrades are not too.

405
Regnier, Justin 02:06:26.104 --> 02:06:47.044
To restore as much of the hosting capacity as was available during the original interconnection agreement that was something that the sounded willing to embark upon. And these non stakeholders were in agreement that was reasonable.

406
Regnier, Justin 02:06:47.104 --> 02:06:54.514
That mitigation should be done to bring folks back to to their original condition, irrespective of upgrades.

407
Alex Mwaura PG&E 02:07:01.174 --> 02:07:04.714
I didn't you say it that 1 more time, Justin.

408
Regnier, Justin 02:07:05.674 --> 02:07:18.004
Yeah, so drawing the distinction between mitigations and upgrades mitigations being those things that are in the, as Gary was saying, the tons of thousands of range. And as Roger said, things that do not results in new hardware, being required.

409
Regnier, Justin 02:07:18.214 --> 02:07:37.564
So, adjustments and parameters, um, smart and murder, um, characteristics being modified to, for example, provide more bars. Um, you know, that mitigations should always be.

410
Regnier, Justin 02:07:39.665 --> 02:08:00.275
On the table, in terms of restoring the ability of the interconnection customer to operate within the parameters of their, um, interconnection agreement. But this this is this is discussing upgrades. But the mitigations are are a separate topic and that there's not really any contention that the, and.

411
Regnier, Justin 02:08:00.369 --> 02:08:05.914
Interconnection customer will work to get mitigations going to restore the original connection agreement.

412
Alex Mwaura PG&E 02:08:07.054 --> 02:08:07.294
Yeah.

413
Alex Mwaura PG&E 02:08:07.444 --> 02:08:19.054
I think so. I think mitigations and upgrades are interchangeable but what I think you're referencing is the low cost to us as high cost upgrades, slash mitigations. So.

414
Regnier, Justin 02:08:19.054 --> 02:08:19.234
Well.

415
Alex Mwaura PG&E 02:08:19.234 --> 02:08:21.964
The collection is right. Sorry?

416
Regnier, Justin 02:08:22.084 --> 02:08:28.564
No, my recollection is that we drew a distinction between the distinction was was well, now.

417
Regnier, Justin 02:08:28.594 --> 02:08:37.324
Roger up there, so I'll let him speak to his own his own words. But my understanding was that the, the difference was whether we installed new hardware or not.

418
Roger Salas SCE 02:08:37.444 --> 02:08:41.254
Yeah, yeah, I mean, I, you know, just for, you know.

419
Roger Salas SCE 02:08:41.375 --> 02:09:02.405
Uh, I guess speaking on behalf of, I think, upgrades upgrades to bring the project towards original something of last resort, meaning that we, we know we would do all we can to be able to.

420
Roger Salas SCE 02:09:02.465 --> 02:09:23.465
Being the approved IC values to the extent that we can, uh, Lucas mitigations no, cus mitigations you know, we, we have a few things under under our Toolbox that we can implement, um, so that we can restore the customer cell GP profile in cases. So say, you know, large.

421
Roger Salas SCE 02:09:23.559 --> 02:09:44.494
Disappearing and so always saying is that we cannot always guarantee that 1 of those, you know, 1 of those options is going to solve the issue. And only and when that happens, then upgrade will be required. And if if customers wanted to to bring back to the original GP, so, yes, mitigation. So.

422
Roger Salas SCE 02:09:44.734 --> 02:09:56.494
No cast or Lucas will always be done 1st, uh, and, you know, likely, you know, that that will resolve that condition, but it can narrow. It cannot be guaranteed. That's the only issue that makes it.

423
Alex Mwaura PG&E 02:09:57.484 --> 02:10:05.584
So, I just again mitigations in the system could be anything that needs to mitigate whatever issue is.

424
Alex Mwaura PG&E 02:10:05.884 --> 02:10:27.004
Being caused on the distribution system that can be an upgrade. That is a physical, physical piece of equipment that's installed for an upgrade to existing piece of equipment or we keep being upgrade to settings to an existing piece of equipment. Um, but all those mitigations that are a result of an.

425
Alex Mwaura PG&E 02:10:27.035 --> 02:10:47.195
You on the distribution system, so this time, sometimes I interchangeable. They use it interchangeably, but you have generation system that's wanting to connect to a distribution system. It causes an issue that has to be mitigated. And then that issue, whatever mitigation could be, you know, again, a re, conductor installation of a new piece of equipment.

426
Alex Mwaura PG&E 02:10:48.395 --> 02:10:55.925
To an existing piece of equipment, which could be a setting change, which is usually very minimal cost, but all those, uh, you know, medications.

427
Alex Mwaura PG&E 02:11:00.755 --> 02:11:01.805
Just needs to have to handle.

428
Alex Mwaura PG&E 02:11:09.064 --> 02:11:11.644
All right, then more questions can move to the next slide.

429
Alex Mwaura PG&E 02:11:16.624 --> 02:11:34.144
So, this is related to topic number 2 element 2. and the question here is if future grid conditions, reduce the hosting capacity, the extent to which large may need to reduce generation to ensure safety and reliability without grid upgrades.

430
Alex Mwaura PG&E 02:11:35.434 --> 02:11:55.744
So the 1st item here has to do with the extent of reduction, uh, depending on the severity of the system condition. So what the operators will do is, they'll perform initial actions. This could be something that they, you know, I guess operational engineers, depending on what the titles are. The different utilities.

431
Alex Mwaura PG&E 02:11:55.864 --> 02:12:16.234
Do maybe a voltage LTC voltage regular or LTC controller settings change to me to get safety or reliability conditions and if they determine that, you know, those changes are not effective, then they will assess a reduction to experts.

432
Alex Mwaura PG&E 02:12:18.214 --> 02:12:37.534
And then a determination will be made that the export for projects need to be lower to the level. Um, original LGB export level can be restored. When reliability condition is mitigated. The 2nd item is.

433
Alex Mwaura PG&E 02:12:38.225 --> 02:12:59.135
All the scenarios below unlikely to account for projects, this will be scenarios that should be monitored for future discussions as experiencing the application is gained. So this is something that we can learn from the test cases that we talked about in the previous slide. And when system's condition.

434
Alex Mwaura PG&E 02:12:59.314 --> 02:13:20.434
System conditions have changed the export is causing an overvoltage on overload, condition, grid, operation operators, or operational engineers can observe potential grid safety issue and determine that export is causing the condition. We may be getting some premature equipment failure.

435
Alex Mwaura PG&E 02:13:21.664 --> 02:13:41.584
Determined through investigation, and we can determine through investigations that the export was the, cause of the equipment failure might be in advance equipment malfunctions such as customer about us tripping off line due to voltage issues or frequency issues on the grid. If the.

436
Alex Mwaura PG&E 02:13:41.589 --> 02:14:02.704
That's telemetry then distribution operations engineer can scrutinize more and based on non test or actual export clearance limits under loading distribution operator. Operational engineer can approve generation to stay online or directed to come offline. If generation has no telemetry.

437
Alex Mwaura PG&E 02:14:02.764 --> 02:14:10.354
And most likely the deal, you will direct generation to come offline and they may be other scenarios that are not covered on the slide.

438
Alex Mwaura PG&E 02:14:21.275 --> 02:14:22.085
Next slide please.

439
Sky Stanfield 02:14:23.915 --> 02:14:28.205
Alex, sorry, this is just a quick question on that last slide. Um.

440
Sky Stanfield 02:14:33.305 --> 02:14:44.375
None of the items in this under the 2nd, primary bullet are specific to customer risk right? Am I.

441
Alex Mwaura PG&E 02:14:46.325 --> 02:14:47.225
That is correct. Yeah.

442
Sky Stanfield 02:14:49.804 --> 02:14:54.844
Does it say, I mean, overall, does this just apply to any project that's already connected today? All of this.

443
Alex Mwaura PG&E 02:14:56.824 --> 02:15:17.464
This all of this is applicable to any generation project, any, any system can cause these issues. Um, but again we go back to the idea of that for existing systems. We don't have the mechanism to reduce their export values to a different amount. And we believe that the decision that allows to.

444
Alex Mwaura PG&E 02:15:17.470 --> 02:15:21.005
Jp does give us the ability to go to the.

445
Sky Stanfield 02:15:21.365 --> 02:15:38.615
So, you don't think that the commission was tying that ability to the risk created by the itself and just saying, now, we'll just create, like, a 2nd, class of projects that can be reduced. Like, I think that you guys are gonna stretching a little bit to say we can make reductions to an.

446
Sky Stanfield 02:15:38.644 --> 02:15:59.734
Projects that aren't driven by its profile, for example, inadvertent equipment malfunction and treat those projects are because that's not safety and reliability issue that's driven by the fact that it's operating as an any project can have an equipment, inadvertent equipment now function. And I'm not sure that the commission.

447
Sky Stanfield 02:15:59.769 --> 02:16:01.414
Envision that you were going to.

448
Sky Stanfield 02:16:02.704 --> 02:16:18.274
Create an additional set of restrictions that have nothing to do with the profile itself. It seems to me, like, the safety reliability issues were we were convinced conceiving. We're around the profile not equipment manufacturer. Malfunction that could happen to any project.

449
Alex Mwaura PG&E 02:16:18.874 --> 02:16:23.434
Yeah, but I I think, I think for so I, I think that the commission.

450
Alex Mwaura PG&E 02:16:24.724 --> 02:16:42.874
Um, understood that projects are going to be a larger export more than they would normally be allowed to export and because of this additional, you know, advantage or additional, you know, export capability. They realize that this could cause issues to the system. And then.

451
Sky Stanfield 02:16:45.695 --> 02:16:54.635
It is not the project's ability to produce to export more. That is causing that that that the risks you've identified here, there's nothing to do with that.

452
Alex Mwaura PG&E 02:16:54.665 --> 02:16:54.875
Yeah.

453
Sky Stanfield 02:16:55.445 --> 02:17:03.425
So, why would the commission want to penalize those even beyond the cheese, which is what you're suggesting here.

454
Alex Mwaura PG&E 02:17:03.965 --> 02:17:06.035
So, I think let me go back to that.

455
Alex Mwaura PG&E 02:17:06.039 --> 02:17:18.214
Bullet point, so it's the 2nd item and bullet number 2, which says grid operator observes the potential grid safety issue or? No, it's not that. 1. let me see.

456
Roger Salas SCE 02:17:18.814 --> 02:17:19.414
Alex.

457
Alex Mwaura PG&E 02:17:21.484 --> 02:17:27.183
Perfect so premature equipment fairly investigation. The time is that export was the cause of the.

458
Alex Mwaura PG&E 02:17:27.303 --> 02:17:35.524
Failure, so, if it's not determined that the is the 1 that's causing an issue. I don't believe that we will be asking the just the project.

459
Sky Stanfield 02:17:35.524 --> 02:17:35.853
I think.

460
Alex Mwaura PG&E 02:17:36.754 --> 02:17:37.414
We may have the.

461
Sky Stanfield 02:17:37.414 --> 02:17:48.334
Get more specific with what you've laid out here is not tied to the specific. That's my point. It's not tied to the and the.

462
Sky Stanfield 02:17:48.339 --> 02:18:09.334
Performance of the function and so these scenarios we need to make sure that we're not saying you propose an, and also a bunch of other things could happen to you. It wouldn't have nothing to do with the profile. We're already having a major risk issue, just with getting a customer to build that additional capacity. And now you're adding.

463
Sky Stanfield 02:18:09.544 --> 02:18:12.904
It wouldn't even exist if they just designed a regular project essentially.

464
Aliaga-Caro, Jose 02:18:13.473 --> 02:18:13.834
Yeah.

465
Sky Stanfield 02:18:14.254 --> 02:18:20.553
Maybe, that's what it sounds like. What you're thinking is that you need that maybe that is constrained, but that's not how these are reading right now.

466
Roger Salas SCE 02:18:21.814 --> 02:18:26.614
I think I think maybe maybe that's not maybe we, we didn't do a good job.

467
Roger Salas SCE 02:18:27.994 --> 02:18:48.933
Bringing this, but I think the 2nd bullet is just like, how do you, how do you even notice that there's a problem and yeah, you're right. This could be an, and project. Um, I think the big the big difference what we talked about before, is that is that for for a non project.

468
Roger Salas SCE 02:18:49.745 --> 02:19:10.115
Uh, you can still reduce it for things like our temporary emergency conditions, failures things that are going to be mitigated relatively quickly and we are responsible to do whatever is needed to, to basically bring it back right for, for non projects that same thing.

469
Roger Salas SCE 02:19:11.134 --> 02:19:18.574
I think that same philosophy still applies if we are required to basically reduce the output of and.

470
Roger Salas SCE 02:19:18.579 --> 02:19:39.723
Project below the ice minimum value, so that's so below the minimum value. It is the same for an project and analogy project in that. We, we are minimum kind of need to guarantee that minimum. I see value. Right? But really is.

471
Roger Salas SCE 02:19:39.728 --> 02:20:00.874
That is really our ability to reduce the profile to the minimum value that I think we're trying to say here that we can do that. And if that resolves the issue, so you have an overvoltage problems 1 example, and you're able to to mitigate that by reducing the profile not not to be not to go lower than the minimum.

472
Roger Salas SCE 02:20:00.880 --> 02:20:12.065
Oh, I see. Is your value then that's a condition that may potentially stay much more longer than then if they need to have to go below the value that makes any sense.

473
Roger Salas SCE 02:20:17.284 --> 02:20:18.274
Sorry, Scott, you're on mute.

474
Roger Salas SCE 02:20:21.934 --> 02:20:24.694
Still on mute I can I hear you. At least I can.

475
Sky Stanfield 02:20:24.994 --> 02:20:40.414
Sorry, I didn't it doesn't show up on my little thing so that I, I think I agree with the idea that if the overvoltage issue occurred doing during the, the additional profile hours.

476
Sky Stanfield 02:20:41.854 --> 02:20:49.744
The, so the cause was that you were producing power during those extra hours, I'll just call them.

477
Roger Salas SCE 02:20:49.894 --> 02:20:50.074
Right.

478
Sky Stanfield 02:20:50.104 --> 02:21:02.914
That that would be fine or that that's potentially what's allowed then. But I think that that this list of conditions doesn't.

479
Sky Stanfield 02:21:02.920 --> 02:21:03.635
Line with that.

480
Roger Salas SCE 02:21:03.695 --> 02:21:03.965
Yeah.

481
Sky Stanfield 02:21:03.995 --> 02:21:08.585
So some of them do, and some of them don't. And so my suggestion would be.

482
Sky Stanfield 02:21:10.025 --> 02:21:31.115
Maybe you guys could go back and think about these criteria a little bit more deeply. And especially, because I don't think a customer again with the idea of mitigating, getting a customer comfortable with the amount of risk. I don't think saying especially, I don't think you're going to feel nervous. Like, well, now I'm giving the data them all this and telemetry data and they're more likely to.

483
Sky Stanfield 02:21:31.324 --> 02:21:51.304
Even for conditions that would have occurred anyways, I want to avoid that, because I think we need to make it again. We made to make this feel like a normal interconnection level of risk extent. We can, and some of these make sense like I said, the overvoltage overload condition during those hours, but other ones don't seem as tied to me here.

484
Roger Salas SCE 02:21:52.834 --> 02:22:00.724
Well, I mean, I, I think this could again, this could occur to any, any generator out there, right? Whether it's on non.

485
Roger Salas SCE 02:22:00.729 --> 02:22:21.484
And 2nd bullet is just the 2nd bullet is just, you know, how do you even determine that whole problem out there right now the next thing that that is important is, okay, what actions can or cannot you cannot take obviously our number 1 action is going to be ensure that the system safe and so.

486
Roger Salas SCE 02:22:21.905 --> 02:22:42.695
Standard actions, immediate actions need to be taken, whether it's an, and to bring the system to normal conditions. Then that's only be taken immediately regardless as to whether it's an, and an now then what happens next is important is the evaluation if the evaluation. So, it shows that.

487
Roger Salas SCE 02:22:43.029 --> 02:23:04.174
We can remove those additional problems, but she's bringing the extra hours below the lower, but not below the minimum value. Then There'll be that that thing that's the area that we would say. Well, you know, we are allowed to do that, but if we needed to bring that value, even lower than the minimum value.

488
Roger Salas SCE 02:23:04.835 --> 02:23:12.215
Then we, we start to mitigate that condition real time, but then we have to do, uh, something to try to fix that as quickly as possible.

489
Sky Stanfield 02:23:12.875 --> 02:23:14.765
Yeah, that makes sense to me.

490
Alex Mwaura PG&E 02:23:23.255 --> 02:23:23.825
Adjusting.

491
Regnier, Justin 02:23:25.835 --> 02:23:43.655
So, I agree with both sky and Roger on this, I think sky raises a valid point and we can take an action item to pull the actual language out of the resolution. Because I do believe that there's language and addictive, not on the findings, the fact ordering paragraphs.

492
Regnier, Justin 02:23:45.365 --> 02:24:03.905
That clearly articulate that in it's gotta be based on specific issues. Um, so I think roger's heard that and the ideas have heard that, and they can go back and make sure that what goes into the advice letter corresponds with direction on the resolution. We're happy to provide that exact language if necessary.

493
Regnier, Justin 02:24:04.863 --> 02:24:25.683
I think, really where we're getting hung up here as to do with the long term policy on upgrade. I would throw out a couple things. There. 1, is that we've established that the business as usual process for interconnection customers.

494
Regnier, Justin 02:24:26.044 --> 02:24:46.864
To provide upgrades that bring them back into compliance with their interconnection agreement, full stop unless we have, you know, we've not established a separate customer class. We've not established that this would be, you know, an important expenditure of rate pair funds. So that's the.

495
Regnier, Justin 02:24:47.254 --> 02:25:00.814
The framework that we are in absolutely. Development that the upgrades would be provided, um, as they would to any other customer.

496
Regnier, Justin 02:25:04.084 --> 02:25:23.404
I don't think that the resolution of that question necessarily has to come before we talk about weather and how curtailment would occur where we're getting hung up is, you know, timeframe and costs for restoration of original hosting capacity.

497
Regnier, Justin 02:25:24.364 --> 02:25:44.884
Um, I think those are critical questions in terms of policy design and making sure that this has uptake that Scott and I just had mentioned. But I'm not sure. We absolutely need to solve those questions prior to having advice letter language for the tariff. That articulates. Exactly. Whether, and how it curtailment occurs. So those.

498
Roger Salas SCE 02:25:48.994 --> 02:26:08.884
Yeah, Justin, I guess, just to clarify at least for se and based on our view, is that the resolution, or the order clear says, I think, uh, you know, someone had it in 1 of the slides here that we know that we're allowed to reduce.

499
Roger Salas SCE 02:26:08.890 --> 02:26:13.115
The profile down to the lowest ACS.

500
Roger Salas SCE 02:26:13.119 --> 02:26:34.264
Value or safety reliability issues and and there was clear saying without doing system upgrades. So, for me, it would make no sense that we need to do the, the system upgrades after the fact. And so that we.

501
Roger Salas SCE 02:26:34.294 --> 02:26:45.184
Restore that profile and essentially put that as part of the in repairs when, when when originally should would have been part of the interconnection customer.

502
Regnier, Justin 02:26:46.924 --> 02:26:54.364
I hear what you're saying, but you're conflating 2 different sections of the document. Um, the without upgrade.

503
Regnier, Justin 02:26:55.420 --> 02:27:05.105
Cost is that time of interconnection and unfortunately we weren't as clear as we might have been in terms of the.

504
Regnier, Justin 02:27:08.944 --> 02:27:19.084
The long term use of the strategy of reducing limited generation profiles to the I'm sorry the.

505
Regnier, Justin 02:27:19.895 --> 02:27:31.745
Minimum level as an acceptable means to provide mitigation to safety and reliable reliability issues. Yeah. At present we don't.

506
Regnier, Justin 02:27:33.904 --> 02:27:51.874
We don't allow unsafe for unreliable conditions to persist on the grid. We fix them as a part of the planning process. So I don't I, I understand where you're coming from. But I think we're conflating a couple separate parts of the document. I don't think we've got the clarity that you have in mind.

507
Roger Salas SCE 02:27:53.584 --> 02:27:54.124
Sounds good.

508
Regnier, Justin 02:28:00.004 --> 02:28:00.964
Like, challenge goes hand.

509
Alex Mwaura PG&E 02:28:04.175 --> 02:28:04.475
Join.

510
John Berdner Enphase 02:28:04.505 --> 02:28:21.965
Thanks, Dustin and I, I just wanted to something that occurred to me is that, um, there are certain things where mitigations can occur and we're talking about costs for those. The 1. I think that is an outlier. Is.

511
John Berdner Enphase 02:28:22.984 --> 02:28:40.654
Loss of a major load there's not really an upgrade that can solve that. So how how would that be covered? It's a condition on the grid, but there's not really a way to do an upgrade. So maybe that should be looked at separate.

512
Regnier, Justin 02:28:45.424 --> 02:28:55.864
Well, I, I think we discussed that last time under brad's, 2 factories scenario, and came to the conclusion that it would be the responsibility to mitigate. Um.

513
Regnier, Justin 02:28:57.005 --> 02:28:57.335
Yeah.

514
John Berdner Enphase 02:29:00.155 --> 02:29:19.805
Yeah, I, uh, again, just sort of thinking about it, um, you know, the loss of load issue, um, can create a couple couple of conditions. And so, um, how, how do we know.

515
John Berdner Enphase 02:29:21.244 --> 02:29:30.244
What would the utilities mitigation be? Would they install more instrumentation? Or is it is.

516
John Berdner Enphase 02:29:31.114 --> 02:29:45.994
Issue on a specific line segment, or is it reverse flow concerns? And how would that be mitigated? The question of of what would be the mitigation is the 1 I struggled with.

517
Roger Salas SCE 02:29:47.374 --> 02:29:51.394
Yeah, gentlemen, it all depends. I mean, you know, the depends on the.

518
Roger Salas SCE 02:29:51.695 --> 02:30:12.815
Free the prince and the condition every time we do mitigations, whether it's for load anyway for generation, we always look at the most cost effective solution that can that can meet the need. Right? So, yeah, in some cases could be the pain. If it's a voltage problem potentially.

519
Roger Salas SCE 02:30:12.844 --> 02:30:33.964
We need for voltage regulation or additional voltage regulators or simply changing regular settings. Um, if it's a term overload, then, you know, potentially having to re, conductor certain sections. So, the circuit, but really depends. I mean, it's really hard to say yeah. For this condition, we're going to.

520
John Berdner Enphase 02:30:44.284 --> 02:30:45.244
Okay, thanks.

521
Alex Mwaura PG&E 02:30:51.964 --> 02:31:08.404
I don't see any other hands up so I just want to point out that on this slide for the 2nd item bullet number 2 and 3, both talking about an investigation that will determine whether the project is the cause of the issue. So.

522
Alex Mwaura PG&E 02:31:09.275 --> 02:31:30.365
Not just saying that just because there's an issue it's going to be automatically assigned to the project, but there's going to be some sort of, you know, investigation that will determine either way what's causing the issue. And also, it's not uncommon on the distribution system to have, you know, a single project in the line section and you may be having.

523
Alex Mwaura PG&E 02:31:31.204 --> 02:31:36.934
Issues in that specific line section, which, you know, if there's only 1 project is pretty clear what's causing that issue. So.

524
Alex Mwaura PG&E 02:31:39.274 --> 02:31:40.294
Next slide please.

525
Aliaga-Caro, Jose 02:31:44.164 --> 02:31:52.954
Um, so I'm wondering if maybe this Jose CPC, I'm wondering, uh, before we move on to the next slide, whether this would be a good time to take a break.

526
Alex Mwaura PG&E 02:31:54.664 --> 02:31:54.994
Sure.

527
Aliaga-Caro, Jose 02:31:56.524 --> 02:32:15.394
Okay, uh, let's do that. Uh, let's take a, that way. We're at least keeping a little bit in track, uh, in track with the agenda. So, uh, everybody, let's take a 15 minute break and that's, uh, reconvene at 11 o'clock and we'll continue then with.

528
Aliaga-Caro, Jose 02:32:15.634 --> 02:32:17.104
Utilities presentations.

529
Aliaga-Caro, Jose 02:32:27.064 --> 02:32:30.094
And overhead this would yeah, thank you.

530
Aliaga-Caro, Jose 02:42:17.134 --> 02:42:21.904
All right, we're almost at 11 o'clock. Just want to make sure the utilities are back.

531
Aliaga-Caro, Jose 02:42:25.144 --> 02:42:25.654
Ronnie.

532
Aliaga-Caro, Jose 02:42:39.544 --> 02:42:40.804
Roger Alex.

533
Roger Salas SCE 02:42:44.194 --> 02:42:44.494
Running.

534
Alex Mwaura PG&E 02:42:48.215 --> 02:42:49.835
Backwards as well, this is Alex.

535
Aliaga-Caro, Jose 02:42:50.645 --> 02:42:52.835
All right Thank you Alex.

536
Aliaga-Caro, Jose 02:42:56.975 --> 02:43:00.035
And who's going to be speaking on element? 3 is it so Rony?

537
Alex Mwaura PG&E 02:43:09.454 --> 02:43:12.094
It's tell me Jose have have a few more slides to.

538
Aliaga-Caro, Jose 02:43:13.084 --> 02:43:23.794
Okay okay Alex. All right. So we'll wait until 11 sharp, which is just a few seconds away and get started.

539
Aliaga-Caro, Jose 02:44:07.205 --> 02:44:12.605
All right I show 11 o'clock so, uh, we can resume uh, go ahead, Alex.

540
Alex Mwaura PG&E 02:44:18.274 --> 02:44:36.424
Okay, thank you Jose. So this is, uh, eliminate number 3 for topic 2. and this is going to go over the permanence of reduction of capacity and generation that is even other entity, text, future action that reduces hosting capacity for those, using the option.

541
Alex Mwaura PG&E 02:44:37.324 --> 02:44:58.294
Other entities the 1 causing the issue, and should ultimately be responsible for the cost of carrying the lack of hosting capacity, the ability of customers to dial back production to the grid hosting capacities and is a convenient and expedient short term fix this expediency alone is not justification for permanent reduction.

542
Alex Mwaura PG&E 02:44:58.324 --> 02:45:19.294
Of export power, as part of the discussions that I usually present on scenarios, the trigger analysis using cost acquisition principle. So the 1st bullet here is talking about reduction not to be below the lowest value could be temporary and the emergency conditions.

543
Alex Mwaura PG&E 02:45:19.744 --> 02:45:40.564
And potentially permanent for future grid conditions, and some of these conditions could be unforeseen significant load reductions a customer, closing a plant, creating a new feature grid condition. It could be customers installing large amounts of non expert projects, which causes significant reduction of needed load, creating a new.

544
Alex Mwaura PG&E 02:45:40.625 --> 02:45:53.975
Feature great condition, a permanent grid modification or future expansion of the grid requiring system outages, needed to complete large system. Upgrades could have long lead times.

545
Alex Mwaura PG&E 02:45:55.324 --> 02:46:15.514
for configuration and can create a long term condition different from the original grid condition that was used for the project i use also contend that there's no mechanism to hold customers that reduce the load response responsible for the cost of carrying the result in reduction in hosting capacity 

546
Alex Mwaura PG&E 02:46:15.850 --> 02:46:31.535
Typically, if you have a large plant that closes down, they move to a different location. There's no way to go them and, you know, have them pay for the issue that they are causing. And 1 other item that's not really included on here is.

547
Alex Mwaura PG&E 02:46:33.004 --> 02:46:53.314
If we had a distribution system with no generation, and we had a customer nearby kit or move the plant somewhere else, you know, the issues that are caused by generation projects are not the same issues that will because I've seen 2 of them. Right? So, yeah, the customer is moving, but, you know, the reason why we're having these issues is because these.

548
Alex Mwaura PG&E 02:46:54.425 --> 02:46:58.055
Generation facility that's connected on that distribution system.

549
Alex Mwaura PG&E 02:47:04.535 --> 02:47:06.365
I see skydance hangs up. Go ahead, go.

550
Sky Stanfield 02:47:07.325 --> 02:47:22.115
Yeah, help me with the, the permanent grid modification and the future expansion of the grid. Help me understand how those are specific to the and not just the general.

551
Sky Stanfield 02:47:23.134 --> 02:47:29.824
Um, what, what are you saying that, that how would the cause those 2 scenarios.

552
Alex Mwaura PG&E 02:47:31.654 --> 02:47:39.274
I think those those about applicable projects, um, any, any generation project.

553
Alex Mwaura PG&E 02:47:40.624 --> 02:47:42.814
Cause these issues, um, again.

554
Sky Stanfield 02:47:43.444 --> 02:47:58.594
What are you saying, then, Alex, that you would treat the customer differently in that you would seek trigger, tell them to the value for those 2 conditions and if not, why are they on the list here?

555
Sky Stanfield 02:48:00.574 --> 02:48:07.744
For any project, but what you're saying is that you would reduce, because right.

556
Alex Mwaura PG&E 02:48:08.734 --> 02:48:21.334
So, I wouldn't say it that way, but the, the issue here we go back to the decision it allows the I use to reduce the projects to the.

557
Alex Mwaura PG&E 02:48:21.394 --> 02:48:22.624
I see.

558
Sky Stanfield 02:48:22.834 --> 02:48:42.484
If the ltp is causing the safety reliability issue, we just talked about this on the last slide is the position that even if it's not the profile that the commission is going to allow you to make productions, again, you're just making it even more risky. You guys, you need to draw a distinction between a safety and reliability issue that is caused by.

559
Sky Stanfield 02:48:42.514 --> 02:48:55.924
The profile versus a safety reliability issue that, as we all agree exist for every project today, there's a really critical distinction here. Otherwise you're just making these projects even have a higher risk, but no better.

560
Alex Mwaura PG&E 02:48:58.024 --> 02:49:15.904
See, what you're saying, but so if we use an example of 2 projects that are connected in the same line section, 1 is an project. The other 1 is not and there are issues obviously, we don't know which electrons are getting to causing that issue. Right, because all both these projects are able to export. So.

561
Sky Stanfield 02:49:15.904 --> 02:49:19.144
It would have to be tied to a temporal distinction.

562
Sky Stanfield 02:49:19.294 --> 02:49:19.894
Right with.

563
Yi Li SDG&E 02:49:21.544 --> 02:49:23.374
Uh, this is a.

564
Yi Li SDG&E 02:49:24.275 --> 02:49:44.525
As we're creating a slide, we're trying to tie back to the question advantage division is asking. So I think the bullet that you're pointing to sky you're correct. I think it's over is that we didn't mean to include the permanent grid modification as the condition. That will required on that to be customer to change out, but we have discussed.

565
Yi Li SDG&E 02:49:44.614 --> 02:50:00.544
These scenarios in workshop number 1 that those, if we are doing a great modification, right? We are we know this. Well, ahead of time, we wouldn't really ask them to be customer to reduce. We'll handle that via, like, system upgrades and part of the design.

566
Sky Stanfield 02:50:01.894 --> 02:50:05.464
Is that same for the further? I'm not entirely sure. I understand the.

567
Sky Stanfield 02:50:05.705 --> 02:50:09.395
What the future expansion part is, but it's not the same.

568
Roger Salas SCE 02:50:09.425 --> 02:50:26.465
Yeah, I think the, the last 1 was more to talk about that there's, you know, the, the future lies and large expansion. At least the intent of it was, um, just because we have so many system outages out there or, you know, abnormalities.

569
Roger Salas SCE 02:50:27.154 --> 02:50:47.944
When you're doing a large system upgrade, there may be a need to sort of keep a system in a normal configuration for an extended period of time, you know, you know, months, at a time if you want to collect that. Right? Like, you know, for the winter time, while we do a large upgrade, we may have to reconfigure the system for months in order for us to the system updated. That's what.

570
Roger Salas SCE 02:50:48.004 --> 02:50:50.614
The last 1 was talking about that during that time we may have.

571
Roger Salas SCE 02:50:51.124 --> 02:50:55.414
Reduce the profile during that large expansion of time, right?

572
Sky Stanfield 02:50:55.744 --> 02:51:04.444
No, what would you do if I was a project today, if I was interconnected and you need to do that future expansion the grid how what would, what would you do now?

573
Roger Salas SCE 02:51:06.633 --> 02:51:24.543
Yeah, I mean, that's a good question again haven't gotten to that situation, but I can tell you something that we will not do, you know, if we were to be in that situation, we will not do upgrades to mitigate the fact that we want to be in a temporary condition.

574
Roger Salas SCE 02:51:24.640 --> 02:51:43.025
In order to perform this upgrade. Right. Uh, so so I don't know exactly what we do because we really haven't been in that situation, but I, I don't think that we would do upgrades to to fix the problem for a condition that is temporary in nature like, in months, for instance.

575
Sky Stanfield 02:51:45.305 --> 02:51:45.755
Okay, but.

576
Sky Stanfield 02:51:45.789 --> 02:51:51.904
Again, what I'm trying to get to here, Roger, is why are you saying that you would do that to an customer.

577
Roger Salas SCE 02:51:52.234 --> 02:51:56.464
We'd probably do it to both in this situation could be applicable to both. Right?

578
Sky Stanfield 02:51:56.854 --> 02:52:06.934
So, my request here, is that both with the last slide, though, I think we worked out where you met with the last slide a little bit more, but here we need to. I, I would like.

579
Sky Stanfield 02:52:06.939 --> 02:52:11.224
To see a proposal from the utilities that is a lot more specific.

580
Roger Salas SCE 02:52:11.284 --> 02:52:11.824
On.

581
Sky Stanfield 02:52:11.914 --> 02:52:28.084
What conditions and how you would treat a project an project, where are those conditions are driven by the, the, the profile we need to weed out and make sure the customers understand that they're not actually going to be even greater risk than they would be. If.

582
Sky Stanfield 02:52:28.114 --> 02:52:49.234
Just installed the because what this future expansion and permanent grid modification are is total curtailment, right? Or some version there in. So you're basically saying that even the value isn't captured and that that's untenable. That's not built by the commission, but by the commission order, but also in general, I think we.

583
Sky Stanfield 02:52:49.384 --> 02:53:01.714
You guys understand that, but I don't think we're seeing the language that reflects that understanding and we need to be really clear about what we're saying is going to happen to an customer because of their profile.

584
Roger Salas SCE 02:53:05.284 --> 02:53:07.684
Yeah, I think we can make that clear to me. So.

585
Roger Salas SCE 02:53:09.454 --> 02:53:16.984
Yeah, I think we, I think hopefully, I think with the discussion that we have, we're sort of understanding what we're talking about, which is sometimes this, this.

586
Sky Stanfield 02:53:17.314 --> 02:53:19.804
They're not been in the workshop, right? Yeah.

587
Regnier, Justin 02:53:26.675 --> 02:53:42.545
I guess the question I haven't dove tailing. Sky's point is the only option with currently interconnected static export value generators is to turn them entirely off or lead them entirely on.

588
Regnier, Justin 02:53:43.744 --> 02:53:59.104
On those last 2 bullets, do we have any history where you've had to entirely turn them off to deal with permanent grid modification or future expansion of the grid for, for large system upgrades? Or is this.

589
Regnier, Justin 02:54:01.864 --> 02:54:04.804
Is this just, um, hypothetical.

590
Roger Salas SCE 02:54:05.464 --> 02:54:22.294
No, I don't think monthly permanent. Um, but, uh, I'm sure I don't know. I don't I don't I don't have the data, but I'm sure that there's been situations where we have to cartel generators because we had to switch certain sections. So, circuits to do system upgrades.

591
Roger Salas SCE 02:54:22.744 --> 02:54:26.134
I just don't don't have the data to to show what that is. Um.

592
Regnier, Justin 02:54:26.524 --> 02:54:33.604
I think that's a critical piece of information. So maybe, let's make sure we get that data by the next workshop if we can because.

593
Yi Li SDG&E 02:54:33.634 --> 02:54:43.264
I think that was shared in workshop number 1. I remember that presentation, uh, coming from the reliability metrics, laying out the data.

594
Yi Li SDG&E 02:54:43.624 --> 02:54:52.114
How many times the 21 generator workers held part of a system reconfiguration or fence.

595
Yi Li SDG&E 02:54:54.874 --> 02:54:58.624
Remember that for this week I'm getting mixed up between the 2.

596
Roger Salas SCE 02:54:59.494 --> 02:55:15.874
Yeah, I think it's part of this week, there was a slide about about outages for generators and all those words temporary in nature. They're not permanent, but they have to do with things like a normal condition.

597
Regnier, Justin 02:55:16.025 --> 02:55:16.295
So.

598
Roger Salas SCE 02:55:17.195 --> 02:55:29.495
I don't remember if there was a line item for system upgrade, uh, even mean, you know, you know, determine how we get the data. I'm not sure how we would be able to retrieve the data, but, uh, something we can take a look into.

599
Regnier, Justin 02:55:31.025 --> 02:55:37.025
I mean, if you have an established history of shutting systems down for a day or 2.

600
Regnier, Justin 02:55:37.054 --> 02:55:58.174
When you absolutely have to to complete a large system upgrade, that's that's relevant information. If you've already presented it. If you've already got it and you want to reiterate it in the next workshop fine. But I think I think we should understand what the duration and frequency of that kind of a shut down.

601
Regnier, Justin 02:55:58.205 --> 02:56:02.135
Be, if you want to bring it on the table for this particular discussion.

602
Yi Li SDG&E 02:56:03.695 --> 02:56:19.265
Yeah, just so 1 thing we do want to point out is that, um, we, we are okay with sharing the historical data, but the same time, you know, historical doesn't always represent what's gonna happen in the future. So, we just want to make sure folks are aware of.

603
Yi Li SDG&E 02:56:19.354 --> 02:56:30.274
So you're not going to have the expectation that it hasn't happened previously too often it's never going to happen in the future. Just kind of won't caveat. I want to throw out.

604
Regnier, Justin 02:56:34.264 --> 02:56:40.894
I don't think anybody is under the impression that we can perfectly predict the future understanding best practices and.

605
Sky Stanfield 02:56:41.464 --> 02:56:53.104
But that's also why we need to find a way to cap risks because customers have no visibility into what how likely it is to happen in the future. Especially when utilities are added caveats like that.

606
Alex Mwaura PG&E 02:57:18.364 --> 02:57:20.734
All right 1 more question is this is this where you take over.

607
Yi Li SDG&E 02:57:23.074 --> 02:57:25.324
I think I have few more slides Alex.

608
Alex Mwaura PG&E 02:57:25.444 --> 02:57:25.894
Okay.

609
Alex Mwaura PG&E 02:57:27.065 --> 02:57:27.575
Next slide.

610
Alex Mwaura PG&E 02:57:34.804 --> 02:57:41.884
So this is a continuation of topic number 3, the process, the, how to reduce the customer's excuse me?

611
Alex Mwaura PG&E 02:57:46.385 --> 02:58:04.985
All right, so when are deemed necessary, I used envision utilizing contact information to inform them to inform the customers, or we need to change the operating profile. So, if a customer is enabled to make those changes, and customers will be required to disconnect from the system.

612
Alex Mwaura PG&E 02:58:05.134 --> 02:58:06.784
Such time that they can make the change.

613
Alex Mwaura PG&E 02:58:07.899 --> 02:58:29.044
And then will require confirmation that the changes have been performed. Some examples to consider I use we'll notify customers in writing as soon as safety and reliability issues result in the need to temporarily adjust does not include the emergency conditions. Because obviously, if it's an emergency condition, we have to take whatever action is needed to maintain.

614
Alex Mwaura PG&E 02:58:29.374 --> 02:58:50.194
Reliability, and they may not be enough time to notify customers temporary changes will now require a new interconnection agreement. We may have to update the update to the attachment may be needed update to the interconnection agreement may be needed by an attachment it will be. The customer's response.

615
Alex Mwaura PG&E 02:58:50.199 --> 02:59:11.164
Ability to engage authorized personnel to implement the changes within customer's power control system. And then I reserve the rights to request proof of the updated profile. Implementation process would be normalizing the appropriate Internet connection agreement as I mentioned before it may be an update to the.

616
Alex Mwaura PG&E 02:59:11.375 --> 02:59:17.675
Connection agreement by an attachment and then notifications for plant maintenance and system upgrades.

617
Alex Mwaura PG&E 02:59:20.373 --> 02:59:40.953
The requirements, notifications with planned maintenance system upgrades will be set in the interconnection agreements E, notification in advance. We would have to notify customers in advance that we're planning to make those changes all other drivers. Implementation would be required with subsequent.

618
Alex Mwaura PG&E 02:59:40.984 --> 02:59:42.724
The information provided to the customer.

619
Alex Mwaura PG&E 02:59:51.245 --> 02:59:51.965
Go for.

620
Sky Stanfield 02:59:52.685 --> 03:00:07.835
Hi, Alex. Um, okay, so a couple things here so on, um, when the notify the customers as soon as the safety reliability issue results, um.

621
Sky Stanfield 03:00:09.755 --> 03:00:30.305
Either to do a temporary or a longer term change I think we might want to get a little bit specific about what information the utility will provide to the customer that demonstrates along with the theme for the last 3 slides that the safety reliability issue is driven by the profile.

622
Sky Stanfield 03:00:30.723 --> 03:00:51.453
Um, otherwise again, the customer needs to be have some, some certainty in the commission important, most importantly, potentially also needs the certainty that the reductions that are being asked for are driven by the profile itself. So, I think figuring out how you're going to demonstrate that and document that that's.

623
Sky Stanfield 03:00:51.484 --> 03:01:12.304
What the driver is, and that would be helpful. Um, I don't know what that looks like. Exactly. So, it's something you guys might need to think about, but I think Eric would feel like it needs to be documented. That that is the reason why they your a** being asked to curtail. Um, and then.

624
Sky Stanfield 03:01:12.754 --> 03:01:33.754
Let's see, I guess the, the idea of this modification of the interconnection agreement is giving me some making me wonder, like, so say that the, the customer's profile is reduced has to be reduced because there was like a modest reduction in.

625
Sky Stanfield 03:01:34.235 --> 03:01:50.045
In the load on the circuit, but that we don't know if that modest reduction is going to be permanent or not say it happened for 1 season because of business was go undergoing renovations or something like that. I don't want to get too hypothetical here, but.

626
Sky Stanfield 03:01:51.845 --> 03:02:11.825
I'm wondering if W, at what point, we know that those reductions are do need to be permanent as opposed to something that will change over time. It seems to me, like, the only way we're going to know that they're permanent is when it's a major change and I don't know that I have a huge problem at least an initial.

627
Sky Stanfield 03:02:11.854 --> 03:02:22.864
Age of locking this in, but it does suggest that we're basically saying we're not giving any opportunity for the customer to get back to their original profile. Right?

628
Alex Mwaura PG&E 03:02:26.344 --> 03:02:45.244
I would say so, if we have a location or project that has a permanent reduction, and the reduction is, we realized in the, I don't see a mechanism through which they would be able to go back. Unless obviously, you know, if there's upgrades that happen on the grid, and somehow the customer, you know, knows about it.

629
Alex Mwaura PG&E 03:02:45.670 --> 03:02:57.755
I would sort of be the process, but I personally don't see, I don't see any way that they would be able to go back. So, if it's permanent, that would mean that that would be moving forward. That would be the new limit.

630
Sky Stanfield 03:02:58.205 --> 03:03:03.695
How do you so help me understand how do you draw the line between when you guys would decide something is permanent?

631
Alex Mwaura PG&E 03:03:05.195 --> 03:03:06.725
I think he has to go back to.

632
Alex Mwaura PG&E 03:03:06.904 --> 03:03:27.784
The chairman has to go back to the to the cost and if it's, you know, obviously a significant cost to the repairs, then to bring the customer back to their profile versus it's your limit, then that's something that I use obviously reserve the right to make that decision and opposition at this point, is that.

633
Alex Mwaura PG&E 03:03:27.970 --> 03:03:37.085
Will probably not do those upgrades and would rely on the, you know, what's allowed under the decision to go to be able to go back to the value.

634
Sky Stanfield 03:03:43.774 --> 03:04:00.304
Okay, I think this is something that's going to I just need to think more about because it does, I think again, as this additional layer risks WH, what we were talking about, if a customer knew that, okay, I might just be reduced for a few hours a year or whatever, but if you were saying.

635
Sky Stanfield 03:04:01.024 --> 03:04:21.484
As soon as we hit that potential for an upgrade costs that it's going to be a permanent reduction that adds quite a bit more financial risk to the customer. And I don't know the exact way to work around it but it does add some makes it even. I think even less likely someone's going to do this, if they're sure that the those reductions would be.

636
Sky Stanfield 03:04:21.574 --> 03:04:22.384
Permanent.

637
Alex Mwaura PG&E 03:04:33.845 --> 03:04:34.535
Great Justin.

638
Regnier, Justin 03:04:36.335 --> 03:04:52.565
So, I got a few thoughts here. My, my original was just a very simple on the last sub bullet of the 2nd bullet. I use reserve the rights to request proof of the updated profile, given the evolution.

639
Regnier, Justin 03:04:52.654 --> 03:05:13.714
Of using data and telemetry data to verify the profile. I would just throw out there that maybe attestation is a more appropriate word than proof here. So, reserve the right to request an attestation that the updated profile has been implemented, I think might be as far as we want to go there. If you've already got.

640
Regnier, Justin 03:05:13.745 --> 03:05:34.865
The ability to independently verify and maybe it's not even needed at this point. Um, we were talking about and Alex was was mentioning the determination may be made by balancing or by looking at the cost of the upgrade required. And then we just note that maybe we want to be.

641
Regnier, Justin 03:05:34.869 --> 03:05:56.014
Balancing the cost of the upgrade, and as we were talking with Eva, the revenue impacts to the customer this is a point that was made by Rogers and others in the last workshop that, you know, a very expensive upgrade for a very minimal increase in output is something that.

642
Regnier, Justin 03:05:56.074 --> 03:06:17.164
They're not seem to do so, maybe some process for balancing costs and benefit is warranted, um, in terms of what sky just mentioned and elements in the, the notifications. I don't know if it's feasible to put a maximum duration of reduction in there. Um.

643
Regnier, Justin 03:06:17.195 --> 03:06:38.285
It's worth considering if it's feasible, because that goes back to the certainty and finally, and if we've got kind of discretion on how we look at this, my gut response is, if we can not muck about with the interconnection agreement, if we can expand the interconnection.

644
Regnier, Justin 03:06:38.319 --> 03:06:59.434
Agreement language to encompass the foreseeable conditions. That would be preferable just because we've had common law, common contract law for a long time, and it seems to be working on. Right? And I just get a little leery at telling the interconnection customer that we can go back. And.

645
Regnier, Justin 03:06:59.494 --> 03:07:11.134
Unilaterally change legally binding contracts if we can get all the conditions into the contract and leave the contract in place. It seems like a safer approach. That's all I've got and I see sky comes back up.

646
Sky Stanfield 03:07:14.225 --> 03:07:16.025
I just haven't left it up. Sorry, Justin.

647
Alex Mwaura PG&E 03:07:20.554 --> 03:07:39.874
Thanks Justin. That's a good point. So yeah, so we may require and the proof could be an, a discussion from the customer saying, here's my new profile. Right? So, because the verification process is is based on historical steps. So we're verifying after the fact. So, what we would want to know.

648
Alex Mwaura PG&E 03:07:40.654 --> 03:07:53.794
You know, through some means, or nowadays that the profile is gonna be below whatever, whatever profile would, you know, the timing. Right? And then obviously we could go back and verify after the fact by.

649
Regnier, Justin 03:07:55.924 --> 03:08:05.584
So it's like a day after the fact, if we need more, if we need faster response, then we can, we can have that discussion. But I don't know if we've established that need.

650
Alex Mwaura PG&E 03:08:10.534 --> 03:08:11.464
Any other questions.

651
John Berdner Enphase 03:08:14.884 --> 03:08:33.904
Yeah, Alex, this is John. It's more of a comment, um, sky had said if it and I think it follows up on what Justin just said. Um, Scott had used the term if it's going to be a permanent condition and, you know, I think permanent.

652
John Berdner Enphase 03:08:34.234 --> 03:08:55.024
Obviously, there's no way to know whether a condition is permanent or not, particularly with departing load. So, could we perhaps get a little bit more clarity there? If you can estimate a schedule for mitigations.

653
John Berdner Enphase 03:08:55.114 --> 03:09:09.544
Or it's not possible to mitigate a schedule, not possible to create a schedule to mitigate the condition something along those lines because saying something permanent. I think nobody's crystal ball.

654
Alex Mwaura PG&E 03:09:16.565 --> 03:09:33.155
Yeah, that's a good point. Yes. Yes I guess what I was trying to say is that we wouldn't so let's say the scenario where, you know, a large customer decides to close the plant. Um, you know, could another customer come back in the future and take that location and, you know, bring back the load to the previous.

655
Alex Mwaura PG&E 03:09:33.215 --> 03:09:53.795
Probably, but again, just like, we would not know, we would not know when that's gonna happen. So may happen in months or years, or, you know, several years. So there's no knowing. Uh, and I don't know how we can. I'm not sure what we can discuss this further obviously, but I'm not sure how we would.

656
Alex Mwaura PG&E 03:09:54.333 --> 03:10:09.753
Who would even keep track of this issue and kind of mention we'll bring it up to the at some point and say, oh, now we have a new customer, the loads app. So, we can go back and readjust these customers, which I think is kind of what you're suggesting.

657
John Berdner Enphase 03:10:11.073 --> 03:10:15.453
Yeah, and I, I think there should be a determination.

658
John Berdner Enphase 03:10:15.514 --> 03:10:36.604
Been made if the date is doable or not doable and, you know, clearly there could be things that are not doable but in my mind, it's not permanent or not permanent. It's about whether a date that a mitigation could be.

659
John Berdner Enphase 03:10:37.204 --> 03:10:46.714
Is notable, or is not doable so somehow make that distinction because, like you said, it may not be.

660
Alex Mwaura PG&E 03:10:49.384 --> 03:10:51.844
That's fair we'll go back and discuss this. Thank you.

661
Regnier, Justin 03:10:58.444 --> 03:11:03.844
Maybe maybe a threshold for reassessment, rather than trying to get to perfect prediction.

662
Alex Mwaura PG&E 03:11:07.684 --> 03:11:07.924
Okay.

663
Alex Mwaura PG&E 03:11:10.294 --> 03:11:12.454
I don't see any more hands up. So next slide please.

664
Alex Mwaura PG&E 03:11:15.545 --> 03:11:35.255
This is a continuation of topic. Number 3 I use identify condition an acceptable voltage Tom overloads. So this could be violations that are detected on a planned basis or violations that are detected near, or in real near, or in real time near real time. In real time.

665
Alex Mwaura PG&E 03:11:36.334 --> 03:11:56.974
So is for unplanned outages or planned basis I should say I use perform planning analysis ahead of time including path flow analysis to identify, anticipate collisions and possible remedies. I use a evaluate potential. No cost options, such as switching.

666
Alex Mwaura PG&E 03:11:56.979 --> 03:11:57.964
Additional loading today.

667
Alex Mwaura PG&E 03:12:00.034 --> 03:12:06.844
When no, no cost options are valuable. I use provide customer in writing a reduced export level for each month.

668
Alex Mwaura PG&E 03:12:08.260 --> 03:12:29.375
New schedule, and then I also provided written description of the cause of the problem, and the reason for the export reduction and then for things that will happen near or in real time I use will investigate the issue to take immediate action, depending on the situation could be immediate action may include bubble direction.

669
Alex Mwaura PG&E 03:12:29.410 --> 03:12:43.775
To reduce export or remote customer disconnection in extreme cases, or if initial robot direction not followed, or further communication in the situation and mitigation plans will be coordinated between you and the customer as appropriate.

670
Alex Mwaura PG&E 03:12:49.684 --> 03:12:50.524
Any questions.

671
Alex Mwaura PG&E 03:13:00.004 --> 03:13:03.844
Okay, I'll go ahead and send it over to you to go over the next slides. Thank you.

672
Yi Li SDG&E 03:13:05.494 --> 03:13:18.754
Thanks Alex. Everyone here. Sorry. I'm kind of still struggling with a some sort of a preschool virus. Um, my voice is typically a little more cheerful.

673
Yi Li SDG&E 03:13:18.995 --> 03:13:22.565
Apologize for that next slide please.

674
Yi Li SDG&E 03:13:26.074 --> 03:13:45.544
Uh, so, this topic, we were hoping to, uh, provide some of the ltp reduction circumstances per request, uh, from the stakeholders and energy commission. So, I believe we have already talked about these in previous slides and some of the workshop 1 discussion but here, we're listing.

675
Yi Li SDG&E 03:13:45.934 --> 03:14:06.634
2 scenarios, the 1st scenarios is around the low reduction. So the underlying concern here for a little reduction is that when we have a large reduction in low emit limits available capacity and raises concern, but possible violations associate with system voltage.

676
Yi Li SDG&E 03:14:06.874 --> 03:14:27.814
Thermal limits, and the triggering condition could be a solution. No expert generation or just a big low reduction. For example, someone brought up during the workshop number. Why? When we have a plant closing kind of a large load given away on a circuit and the parameters.

677
Yi Li SDG&E 03:14:27.850 --> 03:14:48.965
Here that we laid out would be that for the, we will need to reevaluate the level of ltp, which, uh, reduced underlying concern to acceptable level and provide the customer and schedule based on the maximum allow expert from the to maintain the voltage or symbol limits where they will.

678
Yi Li SDG&E 03:14:49.594 --> 03:15:04.504
Well, they come in reading limits, uh, in the scenario reduction will last until the issues resolved, as we discussed in workshop, 1, the mitigation may be a non cost.

679
Yi Li SDG&E 03:15:04.535 --> 03:15:15.785
Which may occur very quickly, for example, some operational switching or a quick fix in the field typically less than a month or low cost solution.

680
Yi Li SDG&E 03:15:15.904 --> 03:15:36.694
Description of vitality, which we all have to evaluate and based on each individual case, moving onto the 2nd scenario, which is around emergency conditions and plan outages. The underlying concern here is emergency grid conditions as a result of.

681
Yi Li SDG&E 03:15:36.964 --> 03:15:42.484
Can just send just so you want, do you have a question on scenario? 1 you want to raise.

682
Regnier, Justin 03:15:44.884 --> 03:15:47.164
Yeah, but go ahead and finish too. Well, we can go back.

683
Yi Li SDG&E 03:15:47.584 --> 03:15:57.994
Oh, okay. So, um, the underlying concern is a motion secret condition, uh, as a result of fault condition or plan outages that.

684
Yi Li SDG&E 03:15:58.294 --> 03:16:19.234
Risk a possible issue with the voltages where it comes thermal limits. The triggering condition is kind of similar to the underlying concern here. And the primary is a customer will need to cartel to 0, export until further notified by reduction will only last for a tuition of the emergency or plant outage.

685
Yi Li SDG&E 03:16:19.264 --> 03:16:39.814
Is, uh, until you provides customer notification that it may resume normal operation just similar to what Alex is present on the last slide for these curtailment emergency curtailment will have to actually work with a customer to store the can be done as quickly as possible and.

686
Yi Li SDG&E 03:16:40.390 --> 03:16:42.545
1, only lasts for the tuition of the.

687
Roger Salas SCE 03:17:09.215 --> 03:17:10.865
Did we lose lead or.

688
Aliaga-Caro, Jose 03:17:12.665 --> 03:17:20.225
Okay, I think we did. All right I thought it was just I was just about to us, whether we're just me or everybody else.

689
Roger Salas SCE 03:17:23.824 --> 03:17:25.924
You know, a minute, I think we might have lost the.

690
Roger Salas SCE 03:17:54.755 --> 03:18:06.035
It looks like, uh, looks like she's having, uh, technical problems so let's just continue. I think she was in scenario 2, right? Uh, sure, exactly where she left off. Um.

691
Roger Salas SCE 03:18:07.833 --> 03:18:12.813
I mean, I think we already generally spoken about this term. Oh, it looks like you're back in.

692
Roger Salas SCE 03:18:16.564 --> 03:18:16.984
Go ahead.

693
Roger Salas SCE 03:18:21.304 --> 03:18:22.714
You're a mute I think.

694
Regnier, Justin 03:18:36.305 --> 03:18:37.715
Sorry, I believe you're on mute.

695
Regnier, Justin 03:18:49.414 --> 03:18:50.464
Maybe a double mute.

696
Aliaga-Caro, Jose 03:19:17.404 --> 03:19:19.084
Still mute it, but.

697
Aliaga-Caro, Jose 03:19:24.035 --> 03:19:24.485
Sky.

698
Regnier, Justin 03:19:25.325 --> 03:19:26.615
Delegate sorry.

699
Roger Salas SCE 03:19:27.335 --> 03:19:42.215
Yeah, okay. Um, so so, yeah, well, let's just continue. So, Scott, I think to your question yeah, this would be for scenario to again will be the same for L. G. P. and so it's an emergency.

700
Roger Salas SCE 03:19:42.279 --> 03:20:00.754
Conditions planned outages. Whatever may be. I think we discussed in several times already that that it's it's really for, um, it's applicable to both. And, uh, is that does that clarify your question?

701
Sky Stanfield 03:20:00.934 --> 03:20:03.424
Yeah, I just wanted to make sure that we were clear the.

702
Sky Stanfield 03:20:03.455 --> 03:20:20.795
Customers weren't going to be called out, you know, when you guys are going to have depends on what the condition is. How many generators you may need to ask disconnect and so on I assume, but the LGB customers aren't going to be treated differently in those conditions on scenario. 1. they might be scenario 2.

703
Roger Salas SCE 03:20:21.095 --> 03:20:21.935
And never have you right?

704
Roger Salas SCE 03:20:23.255 --> 03:20:28.955
Sounds good or any. I think this was covered already any other questions on this slide.

705
Regnier, Justin 03:20:32.345 --> 03:20:52.745
I just had a little concern on scenario, 1, last sentence of the mitigation maybe and I are, you know, cost solution, which may occur quickly or are you low cost solution at discretion of the utility? My, and we can go back to the tape. But my recollection was that the yeah, I used.

706
Regnier, Justin 03:20:52.804 --> 03:21:09.004
We're just going to do low cost mitigations so I'm not I'm a little, not understanding why we're talking about it being at a, at the discretion of the utility sort of thing.

707
Regnier, Justin 03:21:13.204 --> 03:21:15.154
Has to go in the planning process, but yeah.

708
Roger Salas SCE 03:21:16.384 --> 03:21:32.254
Yeah, I mean, I think it goes all goes back to the discussion of what are we require when when and how are we when, how are we required to perform system upgrades to.

709
Roger Salas SCE 03:21:32.260 --> 03:21:51.845
Store the original, um, you know, assuming that we're not requiring. Let's just for a 2nd assume. That's that's the that's the, where we end up then that should not prohibit any utility to their own discretion and say, you know, why wouldn't we do this upgrade? Because it does have other benefits. That's what what you're saying.

710
Regnier, Justin 03:21:55.415 --> 03:22:03.515
For sure, um, yeah, 1, how, and if those are, that's that's useful framing. Yeah. Um.

711
Sky Stanfield 03:22:03.545 --> 03:22:14.405
Doesn't this also kind of go back to what we were just talking about on the last slide about? I guess I'm a little confused about when it's so it says that the.

712
Sky Stanfield 03:22:14.583 --> 03:22:18.783
Reduction with last until mitigation is resolved so.

713
Sky Stanfield 03:22:21.694 --> 03:22:41.194
If we're gonna require the update to the interconnection agreement, what you were suggesting is, is that it would be permanent right? Am I not my, I don't know if on the last slide you would distinguish between mitigations versus are you saying here that you wouldn't require an interconnection agreement change?

714
Sky Stanfield 03:22:41.405 --> 03:22:48.095
Where you were, it just took you time to implement the low cost mitigation is that the distinction.

715
Roger Salas SCE 03:22:49.805 --> 03:23:02.105
That may be the case, right? I mean, if, if we know that this, you know, an example, would be new change the regulator settings or.

716
Roger Salas SCE 03:23:02.614 --> 03:23:20.704
Or whatever is that we need to do that is low cost then there's no need to update the interconnection, uh, in the condition agreement for that. Right? It's something that's gonna be, hopefully short term, and we just need to get that done, um, as opposed to something that may take much longer, uh, years potentially.

717
Sky Stanfield 03:23:21.154 --> 03:23:23.614
Right. So really what what a scenario.

718
Sky Stanfield 03:23:23.649 --> 03:23:44.794
1 needs to be broken into 2 separate a different scenario, or a sub scenario. 1 is where there is a low cost mitigation, and 1 is where there is. No right. And what would happen in each 1 would trigger the need for. But we definitely need to build into the, even the 1st scenario where there is a mitigation to make sure the customer knows.

719
Sky Stanfield 03:23:44.824 --> 03:23:55.114
That there would be some temporary reduction of their profile while that mitigation was implemented. And then if there was no mitigation that it would be a permanent reduction.

720
Roger Salas SCE 03:23:57.514 --> 03:24:05.344
Yeah, I mean, I think we need we need to be a little more specific as to what permanent means in this in this scenario. So yeah.

721
Yi Li SDG&E 03:24:06.664 --> 03:24:10.834
Yeah, I, uh, can you guys hear me now? Just curious.

722
Sky Stanfield 03:24:11.854 --> 03:24:12.334
Yep.

723
Yi Li SDG&E 03:24:12.424 --> 03:24:17.284
Oh, perfect. Sorry about that. Just happened. Not sure what happened.

724
Yi Li SDG&E 03:24:18.665 --> 03:24:39.665
I don't think we're married to the idea of changing the at the stage right? Cause, you know, limited solution profile can also be see attachment or it can be a separate file. Just like the whole maintain charging schedule. We need to think more about, you know, how it's going to happen.

725
Yi Li SDG&E 03:24:40.174 --> 03:24:52.414
For emergency conditions, like Raja was saying, it's not going to be permanent. We may not need to change that schedule just for something that changed for, like, a few hours.

726
Sky Stanfield 03:24:53.224 --> 03:25:00.874
And under the emergency conditions, the should already covered that because that's a condition applies to any project. Now, is what we've been saying.

727
Sky Stanfield 03:25:00.939 --> 03:25:01.329
Right.

728
Sky Stanfield 03:25:02.885 --> 03:25:08.705
I should already have provisions and I haven't looked back to see what they do have, but that allow that emergency.

729
Yi Li SDG&E 03:25:11.075 --> 03:25:11.795
Oh, yeah.

730
Sky Stanfield 03:25:11.795 --> 03:25:12.215
Talking.

731
Yi Li SDG&E 03:25:12.215 --> 03:25:23.465
Different things, right we're talking about the provision to allow for the versus the actual, like, the different number right? Different sets of number. So when we say upgrading.

732
Yi Li SDG&E 03:25:23.499 --> 03:25:34.534
Hey, we're also referring to if we're going to have a different schedule, we need to have a record between now using the customer where the schedule is as currently stand. Right?

733
Yi Li SDG&E 03:25:43.953 --> 03:25:46.443
Uh, any further question on the slide.

734
Yi Li SDG&E 03:25:56.224 --> 03:25:58.174
All right, can we go to the next slide please.

735
Yi Li SDG&E 03:26:03.275 --> 03:26:21.305
So, the next slide is, we're starting start to get into some of the topics that were brought up in the last workshop, but I relatively kind of continue to consider to be out of scope for 5,211. so we wouldn't really, necessarily include these items in the.

736
Yi Li SDG&E 03:26:21.333 --> 03:26:41.883
Will be drafting a submitting in January, but, uh, we still want to have a discussion given stakeholders that have question and there has been comments and discussion around these topics. So, starting with the topic number 5 around the schedule. So we receive a question. Go ahead.

737
Regnier, Justin 03:26:46.055 --> 03:26:48.845
Sorry, I can just go at the end of it. Please.

738
Yi Li SDG&E 03:26:49.775 --> 03:26:54.695
I was just going to read the question from India division anyway, so go ahead.

739
Regnier, Justin 03:26:59.073 --> 03:27:03.873
Sorry, I just I wanted to follow up on the question that Alex had last time. Um.

740
Regnier, Justin 03:27:10.204 --> 03:27:26.164
So, we've got 2 professionals working here so the question Alex had had to do with getting back to us on costs, as opposed to time frame for implementation on different schedule options. I want to clarify that the cost questions in terms of.

741
Regnier, Justin 03:27:26.195 --> 03:27:47.315
Upgrades are looking to be addressed in phase 2 what we have in front of us here, the design of different policy options and understanding of the timelines required for their implementation, appreciate Alex's question and have some empathy. Because in the last workshop, I was sick and just couldn't quite.

742
Regnier, Justin 03:27:47.343 --> 03:27:50.403
Get the answer together in time, so I hope you're feeling better soon.

743
Yi Li SDG&E 03:27:56.345 --> 03:28:14.105
Thanks, Justin, um, getting back to, uh, the slide here uh, we, we see the question around addressing the format of the schedule to be submitted to allow a 288 hours profile. So it's a long flexible.

744
Yi Li SDG&E 03:28:14.109 --> 03:28:35.254
For more granularity, and we're also asked to address how this will simplify and streamline a customer's experience, as opposed to filling out manually the value in the portal. So, I believe we have had this discussion heavily in the last workshop, but just to reiterate that I will use views still that.

745
Yi Li SDG&E 03:28:35.259 --> 03:28:56.404
This is only requires 12 hours. We are pasting the decision language here, which is resolving the issue number 9 from the working group. 2 slash 3 accordingly. We adopt utilities counterproposal to resolve issue 9 with the modification to allow the frequency of changes to be mostly versus.

746
Yi Li SDG&E 03:28:56.435 --> 03:29:11.585
Seasonal, so, you know, as punched out here, this already takes advantage of the into cash and capacity analysis, allowing customer to establishing schedule. I'll put some lines issue. 9 proposal with the.

747
Yi Li SDG&E 03:29:12.845 --> 03:29:33.065
Further as described below allowing a customer to establishing mostly schedule output, limited strikes of balance between the proposed schedule, and the more conservative season schedule recommend in a counter proposal. So, friar's perspective there was enough discussion part of the working group tail and also subsequently.

748
Yi Li SDG&E 03:29:33.363 --> 03:29:54.213
Matching the decision that, uh, you know, it was adopted a, uh, sort of the middle ground between what was proposed by the, which is the seasonal schedule, versus what was initially proposed by the stakeholder, which is the hourly schedule. So, the decision clearly outlined that what's being adopted is the mostly schedule, which is the.

749
Yi Li SDG&E 03:29:54.245 --> 03:30:15.365
Of hours, instead of 288 hours as to the question on how customer is going to handle and submit the values we discussed this briefly in the last workshop as well on. Our initial thought is that customer will be.

750
Yi Li SDG&E 03:30:15.544 --> 03:30:36.514
I see profiles from the portal that each I'll use separately, maintain and determine and calculate the algae P values for each month. We provide a similar kind of example, to the rights. We don't believe it's going to be a really too much difference between style you and lastly, we believe the customer.

751
Yi Li SDG&E 03:30:36.519 --> 03:30:57.364
We'll be providing the in the portal based on utility portals capability. So, uh, each style use, depending on where we will be implementing this. Um, and kind of a, how long will be given to implement these capability uh, the ability for a customer to submit the portal will really be, depending on each.

752
Yi Li SDG&E 03:30:57.695 --> 03:31:08.075
Use capability I see a few hands up on. Was it Justin who raise your hands? 1st do you want to go? 1st?

753
Regnier, Justin 03:31:09.215 --> 03:31:10.085
Parties can go 1st.

754
Younes, Amin 03:31:13.834 --> 03:31:32.914
All right, I guess that's me. Um, so I, I guess my my point here is relatively minor, but I know that there's some disagreement over this interpretation and I think that it will be, I believe it's kind of in scope for the next set of workshops to debate this issue not this 1, um, whether whether it's.

755
Younes, Amin 03:31:32.920 --> 03:31:38.855
Complete versus hourly um, but I think that in the absence of having a.

756
Younes, Amin 03:31:40.265 --> 03:32:01.115
Kind of mentioned this earlier, but in the absence of having an agreement on that issue, we should move forward with a, with a data format that would enable either option to work. Should we decide which of the commission clarify? What exactly they meant by that? Um, by their statements, so, even though even though I actually.

757
Younes, Amin 03:32:01.119 --> 03:32:20.134
They tend to agree with the interpretation of the based on my reading of the of the language. I think it that is not the data format that I think we should go. I think we should go with the other data format that would allow hourly values. So that we don't preclude that option or make that too difficult down the road. If if that is the direction of the commission.

758
Yi Li SDG&E 03:32:22.534 --> 03:32:43.414
Uh, before moving on, just I just want to understanding your point a lot more. Are you saying that we would adopt the 12 limits? But the submission should be 280 values but basically, for that entire months, all these Valley needs to be below the limit as adopted by the decision is.

759
Yi Li SDG&E 03:32:43.445 --> 03:32:44.555
What you're recommending.

760
Younes, Amin 03:32:45.185 --> 03:32:59.795
I guess I'm saying that we should look the data format 88 points now, and then we can decide later whether or not the 1224 values in each month, has to be the same or not based on based on what the commission can, uh, put forth later. Does that make sense?

761
Aliaga-Caro, Jose 03:33:01.295 --> 03:33:04.565
Yeah, I think, I mean, uh, you were driving the point that I've been.

762
Aliaga-Caro, Jose 03:33:04.593 --> 03:33:25.563
Trying to drive along in this discussion, which is what John partner and Bryan have been, uh, you know, also trying to discuss is the 288 profile per, which the decision does a state that's required. And not just 12 values has shown here but.

763
Aliaga-Caro, Jose 03:33:25.745 --> 03:33:37.145
So, a standard format to submit those values, that is a, you know, the startup standard.

764
Aliaga-Caro, Jose 03:33:39.875 --> 03:33:51.005
And by format, I don't mean typing it into the, to the portals. I made an actual file that you generate, and, you know.

765
Aliaga-Caro, Jose 03:33:52.564 --> 03:34:10.294
Submit to the utilities, but it's the same file format across the 3 utilities and I do not know if John burner or Brian seal are on the call at the moment. But this is 1 of their, uh, their proposed topics.

766
John Berdner Enphase 03:34:15.665 --> 03:34:18.185
Yeah, Jose, John's on a call.

767
Aliaga-Caro, Jose 03:34:18.215 --> 03:34:19.325
Okay all right.

768
John Berdner Enphase 03:34:21.905 --> 03:34:26.345
Yeah, I mean, I think you, you've covered it. Um, well.

769
John Berdner Enphase 03:34:27.759 --> 03:34:38.434
We are looking at implementing a schedule based on 288 values and which we've talked was consistent with.

770
John Berdner Enphase 03:34:40.744 --> 03:35:01.414
Silence, but it seems that that unusual that you would have 288 values, which consisted of 12 sets of values, repeated 24 time. So the schedule that we're developing, the PCs work.

771
John Berdner Enphase 03:35:01.625 --> 03:35:22.745
Would support 288, unique values beyond that. I don't know what else you would you would like to say, like me to say the schedule certainly goes 1 implementation would be 24 hour a day for each.

772
John Berdner Enphase 03:35:22.774 --> 03:35:43.894
Define month schedule could be implemented that way, but the schedule that we're developing, and the PCs work is more flexible than can consider day a week as well as time of day. So, it's, it's quite a bit more flexible than what's being proposed in the.

773
Aliaga-Caro, Jose 03:35:47.855 --> 03:35:50.885
Yeah, uh, thank you, John. Uh, um.

774
Aliaga-Caro, Jose 03:35:51.394 --> 03:36:12.094
And this is, uh, per the, uh, I believe in the original guidance document, that energy division provided the utilities uh, you know, this is 1 of the issues we wanted to raise and I think this is the 1st time that it's been made clear, both by John. And by Maine.

775
Aliaga-Caro, Jose 03:36:12.455 --> 03:36:28.415
You know, the 288, uh, profile would allow more flexibility, uh, you know, shoot the commission, decide that, you know, we need more granularity either now, or in the future.

776
Roger Salas SCE 03:36:34.985 --> 03:36:51.575
And I think that's a different topic of yeah, me to what John is working on with the team is enough essentially a very flexible schedule that can be implemented. That doesn't necessarily mean that this decision.

777
Roger Salas SCE 03:36:51.603 --> 03:37:12.723
And directed as to implement a very flexible schedule. I mean, at least from our view is that the commission adapted the utilities counter proposal, which is a monthly value 1 value per month, whether it's 1 value per month, showing the table here or whether it's 1.

778
Roger Salas SCE 03:37:12.754 --> 03:37:33.214
Core values that are the same for that month. Um, that that, that I think that that can be discussed but, for our view is that the utility commission adopted our counterproposal that is 1 value, uh, with modification to be 1 value per month. If that if the commissioning cut intended to.

779
Roger Salas SCE 03:37:33.904 --> 03:37:55.024
Use to unique values, then they would have adopted the proposal because the 99999 now, your proposal is exactly that and adapt the non proposal. And so, for our view is the fact that they adopted the utility proposal indicates that is 1 value per month.

780
Roger Salas SCE 03:37:55.054 --> 03:37:56.284
These repeated values.

781
Alex Mwaura PG&E 03:37:58.504 --> 03:38:16.174
Yeah, I, I agree with Roger 100. I think that's a, that is the accurate, uh, interpretation and I also like to point out that, you know, just I've sent the issue with, you know, the system potential system issues with having, you know, more more than 24 values.

782
Alex Mwaura PG&E 03:38:16.205 --> 03:38:37.325
Like, as far as like, safety reliability issue, there's also this implementation, you know, it's much more complex to accept 208 values versus, you know, have a table with 2012 hours. Right. Because now, as we've talked about in the last discussion, it doesn't make sense to have, you know, potential.

783
Alex Mwaura PG&E 03:38:37.353 --> 03:38:58.443
Input to 88 values in a form, it would make sense for them to submit a file and then the utility systems, which you're trying to automate these processes and application process and steady process obviously because we want to make sure that we stay within the timelines by the carrier.

784
Alex Mwaura PG&E 03:38:58.504 --> 03:39:10.924
Doing these studies, and the more we can automate the process, the more likely we're able to stay within the timelines, the more accurate the studies are going to be it's going to be much more complex if we have to accept the file with 288 values versus, you know, 24 values.

785
Aliaga-Caro, Jose 03:39:14.194 --> 03:39:18.754
Thank you and sky and then just didn't have the risk.

786
Sky Stanfield 03:39:22.954 --> 03:39:28.384
Yeah, I just had like, maybe a simpler question. I'll say that I do agree that.

787
Sky Stanfield 03:39:29.524 --> 03:39:50.644
Working on a 288 hour profile simplifies future pause and it seems a little bit strategic for the utilities to say they won't talk about it now, but let's put that aside because I think you guys covered that amply. I just wanted to ask Yogi who's actually sitting here with me in person today, which is a setting.

788
Sky Stanfield 03:39:50.675 --> 03:40:11.795
About that yeah 1 of the main things that needs to happen is that there needs to be some consistency in the last 2 bullets identify that that there will be some variation, depending on the portal capabilities. I'm wondering if you guys have identified portal capability, differences that would drive a difference.

789
Sky Stanfield 03:40:11.824 --> 03:40:32.944
Or, if you're just trying to reserve some, some unknown differences, because I think the consistency is important, and we would want to learn a little bit more about why what the capability problems are. If we were going to have some inconsistent format for ease of tracking the data for the.

790
Sky Stanfield 03:40:32.974 --> 03:40:34.714
The customer submitting the portal, et cetera.

791
Roger Salas SCE 03:40:39.274 --> 03:40:55.474
Well, let's let's start with the fact that we have 3 different roles right? I mean, his utility has his own portal or, you know, connection and we likely have different requirements as to how to build those portals just from the I. T perspective.

792
Sky Stanfield 03:40:57.755 --> 03:41:18.065
I understand that that problem, I guess what I'm asking you is, as we've gone through a couple of these have you actually thought about whether there is a problem you guys don't tell me you aren't talking about these so I know you have 3 different portals. We're talking about submitting a CSV file, for example, that shows your schedule. Are you suggesting that there are 3 different that 1 of.

793
Sky Stanfield 03:41:18.093 --> 03:41:20.523
Systems isn't capable of that, or.

794
Roger Salas SCE 03:41:20.763 --> 03:41:21.393
No, I don't.

795
Sky Stanfield 03:41:21.393 --> 03:41:39.183
Reserving some future. It seems to me like you guys are about to propose to have to put in the advice or how you're going to implement this. Each of you should say how would I implement this. And then if there's a difference, we need to figure out if that's a capability difference or that we can get over or not.

796
Sky Stanfield 03:41:39.605 --> 03:42:00.365
But the, the W, what we would like, and we'd like to not have to fight about this in 4 more iterations of an advice letter. Is it be consistent? So, if you guys could think about it ahead of time at the site, is there some reason why the CSV file couldn't be accepted by all 3 of systems, as opposed to just leaving a door open to later a controversy that would.

797
Sky Stanfield 03:42:00.394 --> 03:42:00.904
Helpful.

798
Roger Salas SCE 03:42:01.504 --> 03:42:05.224
Okay, well we'll we'll, we'll pick that up make sure that we pick pick that up.

799
Alex Mwaura PG&E 03:42:06.424 --> 03:42:17.224
Yeah, I, I think what I can say right now is sky, is that, you know, it all depends on whether we we go with 288+it's 12. so if we, if we.

800
Sky Stanfield 03:42:18.964 --> 03:42:21.604
Say, why we're talking about a CSV file either way.

801
Alex Mwaura PG&E 03:42:21.604 --> 03:42:37.264
No, no, I'll tell you why, so the difference is, if we do, if we're able to accept 12 values, we do not need to accept the customers can punch this in, in this form that's shown on the right side of this. Right? It's 12 values. That would go in.

802
Alex Mwaura PG&E 03:42:39.154 --> 03:42:50.374
Pigeon is actually proposing a way to bring in the values in the form. So customers can in real time. See what they're proposing. As far as their profile is below that number.

803
Sky Stanfield 03:42:50.404 --> 03:42:59.374
Where are you just being obstinate and saying you, why don't you have to answer the question? Have you actually looked at whether a profile.

804
Sky Stanfield 03:42:59.615 --> 03:43:20.735
It was either 12 months or 288 hours is possible in your system or you just say, conveniently that it would be. You're not even saying, you know, that each of the systems can submit support a 12 a profile that you've put in here, which suggests to me that you guys don't actually know or you're trying to put it in an obstacle for strategic.

805
Alex Mwaura PG&E 03:43:20.974 --> 03:43:21.424
No.

806
Sky Stanfield 03:43:21.994 --> 03:43:22.534
I'm not saying, you.

807
Alex Mwaura PG&E 03:43:23.584 --> 03:43:41.884
Yeah, that's not what I'm saying. I'm so PG E, and I'm assuming for the other utilities, we were going down the path that we would be accepting 12 values, not a CSB file an actual profile, put into the application form. That's the part that we were.

808
Alex Mwaura PG&E 03:43:41.914 --> 03:43:55.864
If the decision is that we have to go to 288 versus 12, it obviously would not make sense to have a customer. Somebody sit there and punching to 80 values. So, in that case, we would have to accept the file. Now.

809
Sky Stanfield 03:43:56.164 --> 03:43:56.644
Accept.

810
Alex Mwaura PG&E 03:43:56.644 --> 03:43:57.244
A fire.

811
Sky Stanfield 03:43:57.244 --> 03:44:03.034
You're saying is you're going to make the commission go back and do a whole, another round of advice letters for you to figure out.

812
Sky Stanfield 03:44:03.039 --> 03:44:18.574
Whether you could accommodate the 208 because you're unwilling to provide that optionality now because you're trying to pinch the commission into your pathway. I mean, if there's not, it's not that complicated. Decide if a CSB file can be accommodated in your.

813
Alex Mwaura PG&E 03:44:18.724 --> 03:44:24.184
Csv file can be accommodated in more systems you can you can but the thing is, you can accept the file.

814
Alex Mwaura PG&E 03:44:24.274 --> 03:44:35.464
But what do you do with the file? Right? What do you do with those values? Because this has they have to go through a steady process right? So if you try to automate the process, then that file has to go PG users.

815
Alex Mwaura PG&E 03:44:35.855 --> 03:44:56.615
Somehow we have to integrate that from the application portal into our SAP system that accepts the project, and then go back to the same system that actually does analysis. It's a much more complex integration when you're talking about 200 values versus 12. now, the reason why we propose this, this form.

816
Alex Mwaura PG&E 03:44:56.914 --> 03:45:02.164
That's shown on the right which was included in the last advice letter that we filed. If you look at the.

817
Sky Stanfield 03:45:02.164 --> 03:45:03.754
It's a rejected by the way.

818
Sky Stanfield 03:45:05.163 --> 03:45:13.623
Come back here, because you guys were told that what you did the 1st round, which is what you're proposing again, wasn't adequate. So here.

819
Yi Li SDG&E 03:45:16.624 --> 03:45:17.974
True sky.

820
Alex Mwaura PG&E 03:45:18.034 --> 03:45:18.454
Yeah.

821
Yi Li SDG&E 03:45:19.084 --> 03:45:37.384
This in a vice letter, which is adopted with modification in the resolution 230, it's not rejected. So, I really feel like, um, I appreciate that. You don't make the assumption that that has not take this into consideration and really consider how we can implement this.

822
Yi Li SDG&E 03:45:38.044 --> 03:45:58.624
It's not just about uploading a file to a portal. Obviously any system can accept a file. It's about how we can interpret that and handle that student process is submitting 12 values. 3285isreally different. Also, each area has a different capacity. So, for perspective.

823
Yi Li SDG&E 03:45:58.685 --> 03:46:19.805
We, we may not have as many capacity of these applications compared to say, or PG. E. so we may be handling these application a little bit differently. Right? And if we're looking to implement this ltp in a timeline that's directed by the resolution, uh, which I think that's seeing everyone's best interest based on the.

824
Yi Li SDG&E 03:46:19.863 --> 03:46:40.893
And that's being made so far, we may be handling, we may be utilizing some Excel manual process in the beginning and looking to automate if we get more applications down the road. Um, because we'll need to be into implement ID changes. And again, it's, it's a different level of ity changes if we're implementing the 12 values in 208.

825
Yi Li SDG&E 03:46:41.015 --> 03:46:55.085
Wanted to just kind of making up ity costs and timeline just based on, you know, initial discussion we have to know for sure. And then engage ity vendors and get the exact cost estimate timeline to implement the changes.

826
Regnier, Justin 03:46:56.495 --> 03:46:58.895
So, I, I think I might have some constructive input.

827
Yi Li SDG&E 03:47:01.414 --> 03:47:02.314
Go ahead Justin.

828
Regnier, Justin 03:47:04.504 --> 03:47:21.844
To Gary, I think I think that that's a good recommendation for all parties, utilities, and otherwise that we keep the conversation positive and not pylon. Um, our differences in opinion in this particular topic have been well.

829
Regnier, Justin 03:47:21.850 --> 03:47:42.935
In the 1st workshops, I'm not going to go into them here. What I wanted to follow up on was the discussion that we had at the end of the last workshop in which both and PG E, um, discussed the possibility of within their portal bringing in the values.

830
Regnier, Justin 03:47:43.024 --> 03:48:04.144
By line segment, and that was kind of the genesis of the question that Alex had in terms of we're looking at costs and timeline or just timeline and would like to follow up on the inquiry on Timeline the 12 versus 288 punching in manually versus bring it in.

831
Regnier, Justin 03:48:04.150 --> 03:48:25.295
File or automated through the portal is maybe a, a bit of a red herring. I think that we can make the argument that automated input or automated file upload is 1 that meets the goals of this proceeding explicitly stated streamlined.

832
Regnier, Justin 03:48:25.324 --> 03:48:36.664
The interconnection process, whether it's 12 dollars or 208 values or some, some non 0 manager, whatever um, partly because.

833
Regnier, Justin 03:48:38.644 --> 03:48:59.134
People will do batch uploads of systems. This is something we've talked about on the residential sphere, although I understand that doesn't map 1 to 1. and there are efficiencies to be gained. A CSB is a very common file format as Alex has mentioned. Most systems can incorporate it. I just wanted to touch a little bit on our discussion.

834
Regnier, Justin 03:48:59.314 --> 03:49:20.254
I'm afraid we also have them in a workshop 1 where we're talking about the relative levels of complexity of comparing a, a static value against an curve versus a output curve against an curve and the point that we raised in that discussion right?

835
Regnier, Justin 03:49:20.314 --> 03:49:41.434
Embarrassed consideration here is that the user are ready, considering an output curve against the curve when they look at their typical PB profile. So I think if we're going to make the argument that that is a higher level of complexity. We'd want to hear more detail as to why bringing in a.

836
Regnier, Justin 03:49:42.454 --> 03:50:02.374
I see or bringing in limited generation profile probe that is, is, uh, a number of points and just for 1 to 1 comparison. Uh, you know, the 288 is what we would look at with the, the generalized.

837
Regnier, Justin 03:50:02.615 --> 03:50:23.615
Profile, why profile is more difficult to compare than a 288 PB profile? I think that's that is an open question, but if we're going to oppose having a file format input that we'd want to deal with and.

838
Regnier, Justin 03:50:23.739 --> 03:50:44.884
So the 2 elements 1 is, if we're going to oppose having a file format input, then we should talk about what additional complexity is is introduced above and beyond the PB profile versus profile case too, because we wanted to follow up and make explicit that we do want to understand what.

839
Regnier, Justin 03:50:44.914 --> 03:51:06.034
It would take in terms of timeline for the portal upgrades that were discussed last time. So, specifically the ability to bring values within the application portal when the customer inputs, the line segments CSP value. Those are, those are the 2 things I wanted.

840
Regnier, Justin 03:51:06.064 --> 03:51:16.054
Make sure we got in before the conversation moved on without, you know, getting back into all of our well documented points of disagreement on interpretation.

841
Yi Li SDG&E 03:51:28.295 --> 03:51:34.595
I think what you have actually have the next slide on doing some discussion of.

842
Yi Li SDG&E 03:51:35.915 --> 03:51:42.275
288 valleys, compare it suits all values. Do we want to go there?

843
Roger Salas SCE 03:51:48.814 --> 03:51:57.814
Mostly justin's asking for updates and what we might have indicated that we would do. Uh, is that is that correct?

844
Regnier, Justin 03:52:02.074 --> 03:52:02.554
Yes.

845
Roger Salas SCE 03:52:02.584 --> 03:52:02.794
Yeah.

846
Regnier, Justin 03:52:02.824 --> 03:52:05.224
That is correct and I don't know if that's something that I.

847
Regnier, Justin 03:52:05.434 --> 03:52:09.214
Jamie has also contemplated, I guess the 3rd thing that I would throw in there.

848
Regnier, Justin 03:52:10.925 --> 03:52:29.615
Is that commission has been very clear in their direction that the real 21, um, language and requirements should be uniform across I use in the absence and overriding condition that would force them to be desperate. So, to the extent that we are able to make it uniform, we obligated to make it uniform.

849
Roger Salas SCE 03:52:32.914 --> 03:52:53.194
Yeah, so for I don't think that I have the update. Um, Justin, um, I think I need to follow up. I know you know, my colleague who's not here today. He might have had that information. I don't. Um, but maybe maybe what I want to make. Sure. Is that that I understand.

850
Roger Salas SCE 03:52:53.224 --> 03:53:14.344
The questions clearly, because I'm not sure that I do. So so if others do understand the questions or the request clearly, maybe I can follow up with others, but I don't think I do 100%. So, maybe if you can repeat this for my, my, my.

851
Roger Salas SCE 03:53:14.350 --> 03:53:16.205
Understanding of what the request is.

852
Regnier, Justin 03:53:17.375 --> 03:53:32.855
Sure, um, 3 different elements and the lovely thing about recording it is we can all go back and make sure that we're being honest with ourselves. Um, so you, you can go back and run the tape on it before. And that should be consistent with what I just said.

853
Regnier, Justin 03:53:34.115 --> 03:53:54.905
Which is 1, if we're going to go the route where the are stating that it is an additional level of complexity to have an input file versus punching in the values individually, that we should have some substantiation of how the.

854
Regnier, Justin 03:53:55.239 --> 03:54:04.264
Complexity has increased by an input file that gives output compared to.

855
Regnier, Justin 03:54:05.284 --> 03:54:14.944
Versus the already existing case of using a input file that gives typical PV values compared against the values.

856
Roger Salas SCE 03:54:15.634 --> 03:54:24.334
Hey, Justin, can you verify when you say input the value input the value for what? Or to what? What do you mean by that? Can you clarify that?

857
Regnier, Justin 03:54:24.394 --> 03:54:26.254
Um, yeah, but you've got.

858
Regnier, Justin 03:54:26.284 --> 03:54:28.834
Illustration on the next slide so I'm going to go to slide 17.

859
Roger Salas SCE 03:54:28.954 --> 03:54:29.284
Can.

860
Alex Mwaura PG&E 03:54:30.574 --> 03:54:33.124
Justin, can I clarify what I said before.

861
Regnier, Justin 03:54:37.145 --> 03:54:39.005
Sure do you want to do it midstream? Or or should we.

862
Alex Mwaura PG&E 03:54:39.575 --> 03:54:41.135
Go for it yet. Okay. I'll wait.

863
Regnier, Justin 03:54:45.065 --> 03:55:03.065
So, right now, when you are looking to evaluate a system permissible size, you compare the yellow curve with the green curve, the 2 solid yellow, or the 2 solid curve, the solid green curve.

864
Regnier, Justin 03:55:04.353 --> 03:55:12.513
Solid yellow, and that is a 288 value versus 288 value comparisons.

865
Roger Salas SCE 03:55:13.383 --> 03:55:15.963
For the typical BB profile, right?

866
Regnier, Justin 03:55:16.353 --> 03:55:16.773
Backwards.

867
Roger Salas SCE 03:55:17.163 --> 03:55:25.353
Right so typical profile you look at that hour by hour and you compare the hour by hour and you say well, I said, and I said, that's.

868
Roger Salas SCE 03:55:25.534 --> 03:55:28.534
Cds margin what are the margin is? Yes. So.

869
Regnier, Justin 03:55:28.564 --> 03:55:45.154
Exactly. Right, exactly. Right. Uh, so we're, we're consistent on our understanding of that. What we're saying from the commissions perspective is what we're hearing from the is that using an input file to compare against the values.

870
Regnier, Justin 03:55:46.629 --> 03:55:49.924
Introduces an extra element of complexity.

871
Regnier, Justin 03:55:52.294 --> 03:56:13.414
And what we'd like to understand is how it's more complex. Yeah, yeah. We're going to compare a 288 value or whatever, value, limited generation, profile array. If you will against the array of value.

872
Regnier, Justin 03:56:13.505 --> 03:56:32.075
That are permissible so how is that more complicated than doing the exact same thing for the photo will take to entity value? So, that's what we'd like to understand if you're continuing to hold that using an input file, introduces a level of complexity that is unwarranted or unacceptable.

873
Roger Salas SCE 03:56:33.335 --> 03:56:34.415
In case the clock.

874
Roger Salas SCE 03:56:35.013 --> 03:56:55.473
That is for the analysis portion, as opposed to the application portion, you know, customer some, you know, submitting an application, you know, going online, submitting an application, uh, as opposed to picking that information. And then performing analysis using that information.

875
Regnier, Justin 03:56:57.035 --> 03:57:00.785
What I think I hear you're saying is it's a screens versus in a connection.

876
Roger Salas SCE 03:57:00.995 --> 03:57:16.835
Question no, no, no, no screens or more of a I mean, a customer can submit, obviously can submit a file in the interconnection application as a, as an attachment, you know hey, Here's my profiles and attachment. Right. Uh, CSB or otherwise.

877
Roger Salas SCE 03:57:17.704 --> 03:57:37.414
Um, as opposed to going into the application form, the, the, the actual application form, and in punching in 12 numbers right? Um, the analysis after the fact, we can take that CSB file and perform analysis. Just like what you're showing here.

878
Roger Salas SCE 03:57:38.044 --> 03:57:52.414
Or take the 12 values that the customer performance performing the same analysis there. So, I just want to make sure that we're talking about the analysis portion. Are we talking about the interconnection application portion? Because it's 2 different things? I think.

879
Regnier, Justin 03:57:53.404 --> 03:57:55.084
We're talking about analysis portion.

880
Roger Salas SCE 03:57:55.354 --> 03:57:59.164
The analysis perspective, Dallas is stuck in the Alex is talking about the.

881
Roger Salas SCE 03:57:59.225 --> 03:58:01.385
Application portion is that correct? Alex?

882
Alex Mwaura PG&E 03:58:04.385 --> 03:58:05.405
That is correct yes.

883
Regnier, Justin 03:58:06.185 --> 03:58:24.485
It is clearly more complicated to import a file than it is to import fields that are already in your portal. I think we can establish that. But W, I think we've also established that. That's not right. It's not a great hindrance. Because, as Alex mentioned really all systems.

884
Regnier, Justin 03:58:24.664 --> 03:58:25.684
Csv import.

885
Roger Salas SCE 03:58:26.554 --> 03:58:30.514
Okay, so so just to clarify the question, the question is for this 1st question is.

886
Roger Salas SCE 03:58:31.625 --> 03:58:52.745
If we get a profile 28 profiles, whether it's truly unique values, or whether it's, you know, 12 sets of 24 values, nevertheless, a profile. Are there any differences in the technical evaluation as compared to a typical PV?

887
Roger Salas SCE 03:58:52.749 --> 03:58:55.654
File, you know, essentially.

888
Regnier, Justin 03:58:55.714 --> 03:59:13.894
So, what what I'm hearing is objection to using a standardized file, are 2 things 1 is the complexity that is introduced by pulling a file, as opposed to just interrogating the fields that are already in your portal. And I think we've put that to bed with Alex. And statement, I.

889
Regnier, Justin 03:59:13.900 --> 03:59:22.115
The common understanding, the CSB file is easy to import on just about any system. So we've taken that application complexity as a hurdle away.

890
Alex Mwaura PG&E 03:59:22.955 --> 03:59:23.165
Yeah.

891
Regnier, Justin 03:59:23.375 --> 03:59:23.675
What we're.

892
Alex Mwaura PG&E 03:59:23.675 --> 03:59:35.015
Is 1 other aspect there's another aspect, Justin so I was pointing out before 1 of the things that we're trying to look into potentially doing is on that application form. That was.

893
Alex Mwaura PG&E 03:59:35.049 --> 03:59:40.684
Being displayed on the previous slide is actually pulling in the is.

894
Alex Mwaura PG&E 03:59:40.714 --> 04:00:01.684
Values for the month, so that we can actually just compare the values right there with what the customer's putting in. If you go with the 28 values, a file has to be uploaded. And then somehow there has to be an integration with the system to pull in the 208 values to be compared with. Right? So, that's the.

895
Alex Mwaura PG&E 04:00:01.895 --> 04:00:03.875
Another aspect of the complexity, so.

896
Regnier, Justin 04:00:04.865 --> 04:00:22.355
I think both are required, though, if we're going to go that route so I, I appreciate the the discussion of pulling in the values to the portal and that's that is the thing that I'm explicitly asking for feedback in terms of timeline. Um, so that is 1 element.

897
Regnier, Justin 04:00:23.194 --> 04:00:36.964
But it may be that the applicant doesn't want to follow the entirely it maybe that they want to have a lower output limit in certain time periods, or some other permutation. So there's gotta be.

898
Alex Mwaura PG&E 04:00:37.594 --> 04:00:38.224
For them to do.

899
Regnier, Justin 04:00:39.184 --> 04:00:40.174
Yeah, so they gotta be.

900
Alex Mwaura PG&E 04:00:41.374 --> 04:00:42.094
The maximum.

901
Regnier, Justin 04:00:43.354 --> 04:00:43.744
Right.

902
Alex Mwaura PG&E 04:00:43.774 --> 04:00:44.014
Yeah.

903
Regnier, Justin 04:00:44.164 --> 04:01:01.984
So that if the customer, I mean, I think could be lovely if we had just a quick click through where you say, okay, here's the profile. Those are the maximum values. We accept that. Great. But that doesn't allow them to edit it. And I think that's where an actual consistent file format becomes useful.

904
Alex Mwaura PG&E 04:01:02.494 --> 04:01:05.284
No, it would allow them to edit it because they actually.

905
Alex Mwaura PG&E 04:01:05.344 --> 04:01:10.774
Their profile values, right? So they're making a determination of what the values would be. And.

906
Alex Mwaura PG&E 04:01:11.134 --> 04:01:26.164
I think they're doing the only advantage is they're able to compare with the value to make sure, you know, let's say this new values, a megawatt and they decided they wanted to go to 800 or 900. that would be. Okay, but they can go into any lower than that. It can go to 500 or 700, for example.

907
Regnier, Justin 04:01:27.064 --> 04:01:40.834
Okay, but then we get into the streamlining and a connection consideration of manual entry versus automated file input, whether that's 12 or 288 or 2056 values. I don't know.

908
Regnier, Justin 04:01:43.354 --> 04:01:47.254
The concept is, is the same whether the, even if the magnitude is different.

909
Roger Salas SCE 04:01:50.014 --> 04:02:10.144
Okay, so so, so maybe I heard 2 different things there. So again, I want to make sure I'm clear. So we, we, we talked about the evaluation and whether the valuation is different from a profile versus the typical PB profile. Okay. So we have that 1 that.

910
Roger Salas SCE 04:02:10.745 --> 04:02:31.295
That we want to evaluate the other item that I heard in this discussion was that Justin, the commissions that is expecting or not measures are required, but at least expecting, or or desires that that in our interpretation application portals we bring in the LGB.

911
Roger Salas SCE 04:02:31.954 --> 04:02:52.384
The, the, the, the, I guess the maximum profile allocation, so, for instance, customer wants to interconnect at a given location, they find where the, our electrical identifier.

912
Roger Salas SCE 04:02:52.449 --> 04:03:13.474
And the map they punch in that electrical node and then when the punch that value, then that the application form comes up with a whatever it's a, what a box that says, say here here here are the 12 values.

913
Roger Salas SCE 04:03:14.105 --> 04:03:23.375
Maximum that you can interconnect that this location with the LGB profile. Is that why you're asking? I want to make sure I understand.

914
Regnier, Justin 04:03:25.114 --> 04:03:42.874
My understanding is that already has this functionality coded, but not implemented to be able to pull in the values within the portal. My request is an estimation of the time that it would require to have that functionality with all 3.

915
Roger Salas SCE 04:03:43.024 --> 04:03:43.834
Okay.

916
Regnier, Justin 04:03:43.834 --> 04:03:45.964
Not directing.

917
Regnier, Justin 04:03:46.029 --> 04:04:07.174
i'm ministerial and i'm a commission employee not the commission so i'm not directing that you implement this functionality but it seems that it would be useful to understand the level of effort and level of time that would be involved and if we hear from stakeholders that justin's just wandering off in a field somewhere and that would 

918
Regnier, Justin 04:04:07.205 --> 04:04:15.605
Useful at all then maybe we don't need to do it, but it seemed to have come up in the course of discussion and understanding the trade offs seems to be a useful thing.

919
Roger Salas SCE 04:04:15.995 --> 04:04:19.385
Okay, but but my description was, what, what are you looking for it?

920
Regnier, Justin 04:04:22.384 --> 04:04:30.274
I'm not going to say that your description is what we're looking for, because we are still debating the number of values that come up and you.

921
Roger Salas SCE 04:04:31.414 --> 04:04:42.424
Regardless of what, regardless of whether it's 12 to 88, uh, whatever you're asking is for our customer to be able to go to the.

922
Roger Salas SCE 04:04:42.430 --> 04:04:44.885
Patient form for.

923
Roger Salas SCE 04:04:45.574 --> 04:05:06.394
For the customer to punch in the, uh, the electrical node where the generation's going to be connected and for the, uh, the, the interconnection tool to go and basically pull the value values cumbersome over to a, whether store values or values, whatever.

924
Roger Salas SCE 04:05:06.400 --> 04:05:08.405
That may be, but that's kind of the concept you're asking.

925
Regnier, Justin 04:05:09.215 --> 04:05:27.545
I'm asking for an estimation of the time that it would take to implement that functionality equivalent to what PG E has done and also for need to understand what that level of effort would look like. Um, and, you know, if parties want to wave me off and say that, they don't think.

926
Regnier, Justin 04:05:27.574 --> 04:05:36.484
Be useful, we can have that waved off and not worry about it, but it was a follow up item from workshop 1. so I wanted to make sure to close the loop.

927
Roger Salas SCE 04:05:37.114 --> 04:05:38.824
And we'll make sure it goes the loop.

928
Regnier, Justin 04:05:40.804 --> 04:05:43.384
Jenny, have you contemplated the sort of a functionality.

929
Yi Li SDG&E 04:05:44.644 --> 04:05:48.694
So, we're wearing a slightly different situation, so to be transparent.

930
Yi Li SDG&E 04:05:48.814 --> 04:05:54.334
We don't really get that many applications, like our and PG and.

931
Yi Li SDG&E 04:05:54.695 --> 04:06:15.485
So, for us, when we typically the way we handle these attachments, like CSV files and get attached and submitted to our, uh, into cash and portal and then our intake group, uh, in our customer generation group will send those files over to our engineers for further analysis. So.

932
Yi Li SDG&E 04:06:15.514 --> 04:06:36.574
We don't really have a plan to automate the process and unless we, you know, there's an increasing application, we feel like we really have to do that to increase the efficiency. So, we're kind of in a tough spot, you know, to come up with the estimate. Because, you know, we're really far away from that.

933
Yi Li SDG&E 04:06:36.844 --> 04:06:38.464
May not be necessary for us.

934
Yi Li SDG&E 04:06:45.814 --> 04:06:48.754
Alex, do you did you have a hand up.

935
Alex Mwaura PG&E 04:06:48.754 --> 04:07:02.014
Did I did I just wanted to clarify that for PG E. we, we have an integration with the IC database. This is how we analyze projects that use to.

936
Alex Mwaura PG&E 04:07:02.043 --> 04:07:23.103
So projects that are using for script using, or but we have not completed the changes necessary to implement what I was describing before. So, this idea of, you know, changing the portal to be able to accept the profile.

937
Alex Mwaura PG&E 04:07:23.170 --> 04:07:40.115
Also, to be able to query the ACA database and display these 12 values that the customer can compare to this is something that is a want, but we're still having discussions with it on how this can be implemented, but it's not been it has not been done yet, so.

938
Alex Mwaura PG&E 04:07:41.614 --> 04:07:51.274
And obviously, this issue of 288 is sort of, you know, putting a pause on it because we don't know which way, you know, we're gonna go. Um.

939
Aliaga-Caro, Jose 04:07:55.294 --> 04:07:55.894
Okay, so.

940
John Berdner Enphase 04:07:56.164 --> 04:07:56.494
This.

941
Aliaga-Caro, Jose 04:07:56.494 --> 04:07:57.124
Uh, you know.

942
John Berdner Enphase 04:07:57.124 --> 04:08:00.454
This is John from the I've had my hand up for a while.

943
Aliaga-Caro, Jose 04:08:00.604 --> 04:08:01.894
Okay, go ahead.

944
John Berdner Enphase 04:08:02.824 --> 04:08:13.354
Yeah, we just I wanted to point out I think there are 2 different issues, and we may be conflating that. 21 is what is the risk of using.

945
John Berdner Enphase 04:08:13.930 --> 04:08:35.075
For example, an hourly profile, something more temporal granularity and I understand that the user saying we don't want to do that. Yeah. The 2nd issue is around the portal and how to enter information into it and that ties back into.

946
John Berdner Enphase 04:08:35.103 --> 04:08:50.013
Prior commission orders, I believe orders is the right time with Chad a schedule will consist of 288 dollars. So, you know, you could get a schedule.

947
John Berdner Enphase 04:08:52.804 --> 04:09:13.024
Rows of 24 values are all identical. Um, I could put forth 12 values for that line segment and providing that 24 identical values were 90% or less of that initial IC value. That would be.

948
John Berdner Enphase 04:09:13.235 --> 04:09:34.235
client so the issue is i believe the order sets of schedule will consist of two hundred and eighty eight dollars we could agree that at least initially there'll be two twelve set to twenty four identical browsers and that would not require modification 

949
John Berdner Enphase 04:09:34.324 --> 04:09:42.154
the exact same order but would address the utilities concerns over more granular schedules today 

950
John Berdner Enphase 04:09:43.054 --> 04:10:02.104
so one is about data entry how to do it what is the format of an electronically transmitted file versus a manually created file and the second issue is around the complexity of the high of using a more granular schedule so i think there are two different issues 

951
Yi Li SDG&E 04:10:12.334 --> 04:10:18.754
Thanks for that clarification, John. Yeah, I agree. These are 2 separate issues. I see your chat messages.

952
Yi Li SDG&E 04:10:21.003 --> 04:10:24.693
Is there anyone who want to comment on that before we move on.

953
Aliaga-Caro, Jose 04:10:29.585 --> 04:10:39.185
So, um, I suggest, let's finish this, like, 617, I think, and Dan, let's break for lunch.

954
Aliaga-Caro, Jose 04:10:41.343 --> 04:10:55.353
And then we'll finish up the utilities presentation and then move on to the direct presentation. So, let's finish up this, uh, topic 5 and we'll break for lunch.

955
Yi Li SDG&E 04:11:00.334 --> 04:11:18.634
Sure, on to, uh, John's points, uh, there's 2 separation here and this particular slide is mostly addressing utilities concern or integrating utility concerns around using 280 distinct value versus 12 values.

956
Yi Li SDG&E 04:11:18.844 --> 04:11:39.784
I think we have made those statements in a previous working group discussions hence why we filed the proposal in, uh, and, you know, also what was being adopted by the decision as a country proposal. Uh, we believe that, um, you know, going from 12 value to 280 a valley really increased.

957
Yi Li SDG&E 04:11:39.789 --> 04:11:46.834
The capacity of implementing, uh, going for the annual minimal.

958
Yi Li SDG&E 04:11:46.840 --> 04:12:03.485
To mostly already kind of decrease the safety margin seems to generator will be allowed to operate at the higher level during most Moses and increasing that for the 280 a further decrease the safety margin. And also Israel.

959
Yi Li SDG&E 04:12:03.814 --> 04:12:24.904
You know, I think we collectively agreed that during the workshop 1 that would currently have really limited experience and infrastructure to work with this type of generator control from a utility perspective where I'm starting as to, whether the will meet the expectation and truly avoid a need for a utility system to.

960
Yi Li SDG&E 04:12:24.935 --> 04:12:46.055
By side controllers, as you all know that we're furthering, agreeing to relying on meters to perform that validation after the fact. And as we discussed early today at the beginning of this conversation, although we are going to try to rely on my data to capture the expert.

961
Yi Li SDG&E 04:12:46.058 --> 04:13:07.113
But those are typically delayed and does not really represent the real time operation behavior and further beyond that, as we listed here on the slides currently. None of that I've used really having infrastructure needed to manage the generation and reducers. I'll put in real time.

962
Yi Li SDG&E 04:13:07.235 --> 04:13:28.355
We don't really have the necessary visibility to recognizing graduation happen in real time. And whether, and how we will find out when the generation output needs to be reduced, and whether they could effectively communicate the chance to the DVR and whether the would responding a timing accurate manner, I think we.

963
Yi Li SDG&E 04:13:28.359 --> 04:13:49.444
Received clarification requests from the division around what infrastructure we're referring to here we're kind of referring to sort of a, all associate infrastructure such as, you know, uh, basically the infrastructure that allows for us to have a high visibility, more real time, visibility and controlling.

964
Yi Li SDG&E 04:13:49.894 --> 04:14:09.934
Which is not really only a physical infrastructure requirement also requires, you know, recognition allowance for us to do that. Cause right now we don't really have any ability to, um, have to have visibility to Dr system under 1 megawatts and let alone have any control over these systems.

965
Yi Li SDG&E 04:14:11.105 --> 04:14:31.625
And last, but not least, uh, we do want to point out the modeling challenges associates, uh, with going from 288 limits. Uh, we're still each I always still having discussion with our respective groups on how to implement these changes. Uh, we have listed a few, um, thoughts in.

966
Yi Li SDG&E 04:14:31.808 --> 04:14:52.953
By file, which is currently we are ordered to have more discussion on the restaurant 503 going from handling in how query generation application get model. It is more complicated than how we used to handle the application based on the template. We have to figure out how to adjust our models.

967
Yi Li SDG&E 04:14:53.045 --> 04:15:13.925
To accurately reflect the application, not yet. See profile approved given. Now, they have a dynamic profile versus a nameplate. Because initially we will just remove that, you know, namely value from the remaining to update that. So, the next customer in line will get the accurate representation of how much remaining capacity.

968
Yi Li SDG&E 04:15:14.194 --> 04:15:35.194
In on the system, but with, we do have to implement a little bit different process and how we model these systems and going from Intel value limits to 200 limits. Just makes it overly complicated. And that's something that we want to highlights as 1 consideration for a while. We do not want to go for more granularity.

969
Yi Li SDG&E 04:15:35.404 --> 04:15:40.444
P schedule any comments questions.

970
Sky Stanfield 04:15:43.473 --> 04:16:03.453
This guy, I'm not going to comment now on all these different points. I think that's helpful to lay out these position. And it'll be not surprising that we don't necessarily agree both of the complexity or that. The complexity is insurmountable. But I want to ask just a hypothetical question to help me understand.

971
Sky Stanfield 04:16:03.460 --> 04:16:20.855
How you guys envision the risks of profiles of different sorts? So what if instead of what if the commission instead of allowing a 12 month profile had allowed a schedule that was.

972
Sky Stanfield 04:16:23.199 --> 04:16:44.344
12 hours in a day or 12 increments in a day or 6 increments or 4 increments in a day versus a 12 month profile would that does a profile based on a daily? Does it limited generation profile based on the daily profile? Create more risk than a.

973
Sky Stanfield 04:16:44.375 --> 04:16:49.805
Profiled based upon a monthly profile, does that make sense?

974
Yi Li SDG&E 04:16:51.425 --> 04:17:07.505
I think so, let me try to answer that I can let me know if I'm missing understand your question. So, on what you think of, like, kind of the profile yeah, I think we have a picture here on the right which is sort of the more granular proposal. Initially part of the working group, too.

975
Sky Stanfield 04:17:07.505 --> 04:17:07.955
Mm, hmm.

976
Yi Li SDG&E 04:17:08.403 --> 04:17:29.433
Although currently part of the analysis, we do provide the 576 profiles, but kind of get you understand now, there's a lot of assumption that goes into coming up with IC limits right? We are rely on forecasting and also rely on, you know, a lot of historical data in order to provide.

977
Yi Li SDG&E 04:17:29.495 --> 04:17:33.875
Value at a granular level, so when it comes to.

978
Sky Stanfield 04:17:33.875 --> 04:17:34.295
Going on.

979
Yi Li SDG&E 04:17:34.295 --> 04:17:43.565
Uh, like, say a minimal I see. And then to a daily and.

980
Yi Li SDG&E 04:17:44.553 --> 04:18:03.453
The further granular you go do more kind of risk and become, because you're getting more relied on that forecasting down to each granular level. Right? So, just kind of I'm just kind of coming out, like, speaking out loud here uh, cause I'm really hungry right now. So, I'm not really.

981
Sky Stanfield 04:18:07.115 --> 04:18:25.865
Clarify something, so what I mean, by the so there's 24 hours of the daily profile I don't mean an actual day. I mean, the day, the way that you guys are modeling it, which we got clarified, which isn't based on any assumption of any actual dates, the worst case scenario in every 1 of the 24 hour.

982
Sky Stanfield 04:18:25.984 --> 04:18:47.014
Right so what I'm asking is is a profile that's based on that more risky to you even if it was, for example, chunk. So we say somebody could design the profile in for our chunks over a 24 hour period. Is that more risky than a profile? That's based upon the 12 month scenario.

983
Sky Stanfield 04:18:47.073 --> 04:18:54.573
And I understand what I'm trying to understand is, I don't think that there I'm trying to understand where the variability in the forecasting hits. The hardest essentially.

984
Yi Li SDG&E 04:18:56.313 --> 04:18:58.953
Yeah, I think that question for too, for me.

985
Sky Stanfield 04:19:01.144 --> 04:19:02.014
We need to have.

986
Yi Li SDG&E 04:19:02.674 --> 04:19:14.884
To get our, and maybe come back and to see if, you know, my colleagues here can help out with this question uh, if not, you know, worst case, we can take it back and come back to you in the next workshop.

987
Roger Salas SCE 04:19:16.744 --> 04:19:22.054
Well, we have, we might come in and that would be that, you know, it is natural that as the, the more.

988
Roger Salas SCE 04:19:22.323 --> 04:19:43.353
You get the, the risk is going to increase that what you forecasted that's going to happen will not happen. Now at what point does it become problematic? You know, that's a difficult answer to have. Right it's like, you know, at this point.

989
Roger Salas SCE 04:19:43.445 --> 04:19:48.275
I think will feel more comfortable with with the 1 value per month.

990
Sky Stanfield 04:19:48.335 --> 04:20:04.565
Is it just that you feel what I'm trying to get at Roger? Is it isn't just that you feel that you'd rather have 12 our 12 points versus 288 points or is it? Because I guess cause I can envision what I'm trying to make sure. I understand.

991
Sky Stanfield 04:20:04.568 --> 04:20:25.653
And this is partly so what we all need to understand in terms of what how much value there is for the customer in this thing is, is it actually more valuable for a customer to be able to promote provide a daily profile that would be consistent across the entire year, or a monthly profile obviously, what we'd like is a monthly profile that varies by day, or maybe set the.

992
Sky Stanfield 04:20:26.285 --> 04:20:46.865
But what I'm trying to make sure I understand in terms of what the utilities real concern here is, is is it just the number of touch points essentially, either 12 versus 288 or does it matter what those touch points are tied to the monthly versus the daily profile, I think they're all based on the same set of assumption. So it shouldn't really matter, but.

993
Sky Stanfield 04:20:46.869 --> 04:20:50.284
I may not be thinking about that correctly.

994
Roger Salas SCE 04:20:51.694 --> 04:21:05.794
I mean, I think the touch points and the fact that each touchpoint, it's making the assumption of that given given value on that day, based on a forecast.

995
Roger Salas SCE 04:21:08.073 --> 04:21:29.163
Naturally, the, the closer that you get to why you think it was going to happen that particular hour the higher chances is that something may happen in the forecast that may actually be wrong. Right? So, I think it's more about the, the number of touches that we have in each month.

996
Roger Salas SCE 04:21:29.795 --> 04:21:50.315
In the fact that each hour is being is based on a different, uh, different forecast for that particular hour is what, what, what makes us nervous without having any experience um, so it's, I'm not sure if that answer your question, but really, you know, it's all of these all of these calculated.

997
Roger Salas SCE 04:21:51.753 --> 04:22:11.403
Are based on simulation, based on forecasting of load profiles, based on what happened before. Well, you know, as we all know, you know, past performance is not a feature or a guarantee of the future. So so the more that you try to simulate, what happened in the past, the more.

998
Roger Salas SCE 04:22:11.470 --> 04:22:13.055
Probability says that you want to be wrong.

999
Sky Stanfield 04:22:13.865 --> 04:22:21.605
I'm just trying to understand whether that probability increases more at the, the daily basis versus the monthly basis. Um.

1000
Regnier, Justin 04:22:28.085 --> 04:22:28.655
Lunch.

1001
Aliaga-Caro, Jose 04:22:30.035 --> 04:22:31.145
Yes.

1002
Sky Stanfield 04:22:31.145 --> 04:22:31.445
A.

1003
Aliaga-Caro, Jose 04:22:31.445 --> 04:22:37.355
A good time to break for lunch. Uh, let's break until 130.

1004
Aliaga-Caro, Jose 04:22:40.175 --> 04:23:00.815
And then we'll finish up, I believe the utilities have 2 slides to go and we'll finish that up and then pick it up with, uh, presentation. So, uh, yeah, if you could bring up or, hey, could you change those? Oh, nice. I like.

1005
Aliaga-Caro, Jose 04:23:00.818 --> 04:23:01.208
That.

1006
Aliaga-Caro, Jose 04:23:02.884 --> 04:23:07.084
Could you bring up the, uh, break slide for lunch?

1007
Aliaga-Caro, Jose 04:23:20.853 --> 04:23:24.363
And that's perfect. Yeah, we'll leave it there. So we'll resume at 130.

1008
Aliaga-Caro, Jose 04:23:30.244 --> 04:23:33.094
All right, so you all in a bit.

1009
Yi Li SDG&E 04:23:35.644 --> 04:23:36.064
You guys.

1010
Yi Li SDG&E 04:23:36.873 --> 04:23:37.593
Right.

1011
Aliaga-Caro, Jose 05:13:59.134 --> 05:14:01.294
All right. Hello everyone, um.

1012
Aliaga-Caro, Jose 05:14:03.574 --> 05:14:19.596
Nearing 1, it is 130. so, um, I think we're ready to, uh, resume the utilities presentations. Uh, can I get a roll call to make sure utilities are, uh, present.

1013
Aliaga-Caro, Jose 05:14:24.876 --> 05:14:26.044
Perfect, thank you.

1014
Roni Mejia - SCE 05:14:27.392 --> 05:14:28.142
From I see.

1015
Aliaga-Caro, Jose 05:14:29.132 --> 05:14:33.184
Thank you Ronnie, anybody else Alex.

1016
Aliaga-Caro, Jose 05:14:47.464 --> 05:14:48.454
Roger.

1017
Roger Salas SCE 05:14:49.774 --> 05:14:50.314
Here.

1018
Aliaga-Caro, Jose 05:14:50.614 --> 05:15:08.134
Okay all right. Perfect. So, we, before we, uh, continue to topic 6, uh, or, hey, can we go back 1 slide and, uh, and I just wanted to make sure we closed off any discussion items on this slide and this.

1019
Aliaga-Caro, Jose 05:15:08.434 --> 05:15:09.004
Topic.

1020
Aliaga-Caro, Jose 05:15:11.702 --> 05:15:15.902
So, uh, I is, uh, sky. Are you back.

1021
Sky Stanfield 05:15:17.222 --> 05:15:18.302
Yeah, I'm here.

1022
Aliaga-Caro, Jose 05:15:18.662 --> 05:15:31.442
Okay, since you were the last, uh, person to speak about this slide, I just wanted to make sure that we had a, you know, a finished up discussion of topic 5 before moving on to topics.

1023
Sky Stanfield 05:15:35.044 --> 05:15:53.314
Yeah, I don't think I have more questions on this again. It's more of a statement of the utilities concerns than, um, something where I think we're going to reach agreement on at this point. But I understand what their concerns are based on. Hypothetically.

1024
Aliaga-Caro, Jose 05:15:59.044 --> 05:16:02.464
all right then it sounds like we can continue on to topic six 

1025
Aliaga-Caro, Jose 05:16:05.344 --> 05:16:07.174
So, uh, who's covering this.

1026
Yi Li SDG&E 05:16:08.074 --> 05:16:09.304
Still me thanks. Thanks.

1027
Aliaga-Caro, Jose 05:16:09.304 --> 05:16:14.104
Okay, although I think we may Ronnie, uh, may have already covered this already.

1028
Yi Li SDG&E 05:16:14.764 --> 05:16:18.454
Yeah, I was disappointed about that, but yeah, we can move on.

1029
Aliaga-Caro, Jose 05:16:19.084 --> 05:16:23.764
Okay, well you you, if you have anything else to add, you know, feel free.

1030
Yi Li SDG&E 05:16:24.304 --> 05:16:25.714
No, no, I think we can move.

1031
Aliaga-Caro, Jose 05:16:26.492 --> 05:16:26.944
Okay.

1032
Yi Li SDG&E 05:16:29.674 --> 05:16:49.684
Cool. Uh, so the next topic is a slide that we put together, um, based on some of the discussion in the last workshop, uh, regarding, you know, getting asked about the risk with projects as to why the utilities are concerned about project.

1033
Yi Li SDG&E 05:16:49.746 --> 05:17:10.866
Necessarily treat them differently versus customers. We just want to kind of provide a quick comparison as how we currently understand. This is not obviously not final given. We're still working on how is gonna get implemented right now as currently standing row, 21 on the process for knowledge.

1034
Yi Li SDG&E 05:17:10.894 --> 05:17:30.364
Is that when during the screening process, when we evaluate the project outputs is that we'll be comparing the generator generating facility aggregate gross the complete ratings to the 90% of the lowest value and the.

1035
Yi Li SDG&E 05:17:31.324 --> 05:17:51.634
And also, we'll also do a comparison between the aggregate gross nameplate rating to the 90% the lowest value in the operating flux profile. So, in comparison to that, the new potential process that will be having for the projects is that.

1036
Yi Li SDG&E 05:17:51.876 --> 05:18:12.904
The customers output will only be compared to the 90% of the lowest value. So we kind of trying to giving to message here 1 is to really remind folks to, you know, consider they are a significant amount of benefits to.

1037
Yi Li SDG&E 05:18:12.936 --> 05:18:34.054
Customers for using versus the current process at the same time, you know, what comes with that there are some risks that are not presented if a customer is following the normal process, for example, on 1 thing that is pretty clear basis. Comparison. Is that customer they're operating on a high capacity.

1038
Yi Li SDG&E 05:18:34.114 --> 05:18:55.204
An, which may result in reversal on the little side of the bus that currently does kicking consideration but does not take into consideration. Also, in general refers to, on false regulators and switching devices is not considering these icl limits and this type of decrease operating flexibility.

1039
Yi Li SDG&E 05:18:55.208 --> 05:19:16.354
It really means that they're more likely to have issues during a system of reconfiguration has why we stated before that there was increased risk with projects. And another thing that, you know, we've been talking about this a lot in the previous conversation is that, you know, operating at a higher capacity for element. Most of the year there's just more like.

1040
Yi Li SDG&E 05:19:16.384 --> 05:19:37.504
To have on the distribution Transformer and low side. Right? Because as we all know, that analysis doesn't really take any secondary, you know, limits into consideration when it comes to value. Um, I, I wasn't there for the process, but I think what initially came out part of the proceeding. Uh, it started as a.

1041
Yi Li SDG&E 05:19:37.536 --> 05:19:58.654
Tool to help the developer to find the optimal location to install this regeneration. Uh, over the past years we have been working closely, you know, all of us on the call to hoping to use it to streamlining the connection. Um, process has, you know, uh, most recent use cases is.

1042
Yi Li SDG&E 05:19:58.714 --> 05:20:19.804
Use it to a part of the screen, and instead of what was previously in screen, ham basically use it to replace, uh, screening or get integrated into some of the screening process. But we do want to, you know, just as a general reminder that it's, it's not at the end of day, it's still a computed value based on a lot of forecasting elements and estimate.

1043
Yi Li SDG&E 05:20:20.014 --> 05:20:40.924
And also simplified modeling process so, um, using, uh, more granular limits, uh, in general creative risk of having issue on the distribution systems without going through the full study process, um, last but not least, I think there's a question from say previously on, um, since we're only talking about.

1044
Yi Li SDG&E 05:20:40.984 --> 05:21:02.074
Screen, I'm in this particular slide, what did you want to point to that presentation now we presented, I think believe part of the November 10th meeting, uh, there are also going to be a screen and screen oh. In some aspects screen key may be impacted to study projects, using exporting sort of a nameplate.

1045
Yi Li SDG&E 05:21:02.494 --> 05:21:07.834
Um, obviously those are need to be hashed out in the next steps a workshop for 530.

1046
Yi Li SDG&E 05:21:09.964 --> 05:21:13.596
Skype, go ahead. Can you can unmute yourself and ask your question.

1047
Sky Stanfield 05:21:14.854 --> 05:21:20.674
Thank you, let me start with that last comment and work backward. So.

1048
Sky Stanfield 05:21:23.944 --> 05:21:42.634
I thought that in our last conversation, we had agreed that it was the export capacity and not the name plate. That would be you were basically gonna follow rule 21 for any screens where the nameplate would be used. And then only in the screens where.

1049
Sky Stanfield 05:21:43.024 --> 05:22:04.114
Export capacity is, is identified per, et cetera and then full 1 through 4 and that what I want to make sure you're saying. Are you saying that you're going to treat customers differently than a limited export non customer.

1050
Sky Stanfield 05:22:04.176 --> 05:22:05.224
What you're suggesting.

1051
Yi Li SDG&E 05:22:07.294 --> 05:22:25.294
I think, um, feel free any other colleagues jump correct me? I believe so there are gonna be some screening that are different for customer using export versus same place. We do have a slight issue with that, which is what's been covered under the next slide under topic. 8.

1052
Yi Li SDG&E 05:22:25.324 --> 05:22:46.264
Certain customer that has the own sites bold. We have to take those a little, um, you know, study them a little more closely versus a generation application. That's pure generation. That doesn't have, um, you know, onsite load, but based on what we previously discussed and what's in the decision I think we're leaning towards.

1053
Yi Li SDG&E 05:22:46.474 --> 05:22:57.964
The export for the all should be customer, even though if you go back to the decision, there's a lot of sentences that uses export in our generation output interchangeably.

1054
Yi Li SDG&E 05:22:58.384 --> 05:23:07.594
To be to be completely transparent. Like, I'm relatively new tools now I was trying to read the decision. It was a bit harder for me to digest and understand. So we.

1055
Yi Li SDG&E 05:23:07.624 --> 05:23:14.824
We talk a lot internally trying to figure out exactly what we meant but, you know, I'm not changing our previous.

1056
Sky Stanfield 05:23:14.824 --> 05:23:15.244
Yes.

1057
Yi Li SDG&E 05:23:15.724 --> 05:23:16.804
That's what I'm trying to say.

1058
Sky Stanfield 05:23:17.584 --> 05:23:28.744
Okay, so I, I think if I understood 1st of all, I know there's a little term terminology goes back and forth and that's what I'm trying to clarify as well. But what I think I heard you say to paraphrases.

1059
Sky Stanfield 05:23:28.774 --> 05:23:49.864
That you guys are thinking, you want to apply the supplemental review screens differently for an customer compared to just a limited export customer, not using a profile, but if that's correct I didn't hear why, what what, what would be the thinking about that they would need to look at the profile, obviously.

1060
Sky Stanfield 05:23:49.926 --> 05:24:00.214
Versus there's the a single export amount, but I don't is there some reason why if you could explain more what you mean? So that we know what you're saying you're going to do differently that would be helpful.

1061
Yi Li SDG&E 05:24:01.686 --> 05:24:11.044
Yeah, I'm not really getting to exactly which screen I don't have all of that in front of me. Uh, but in in a in a high level, they are changes.

1062
Yi Li SDG&E 05:24:11.048 --> 05:24:32.194
Using to implement that we don't currently do for the limited profile, limited, export customer. We haven't. Uh, I think we submit it in the device letter, which is the 1 that got approved with modification under resolution 530 kind of what screen are going to be impacted part of the.

1063
Yi Li SDG&E 05:24:32.200 --> 05:24:41.734
Screen, but I think there is for the discussion that I warranted both internally, and with stakeholder on exactly what those screen look like.

1064
Aliaga-Caro, Jose 05:24:43.624 --> 05:25:04.624
Are the associate, uh, there are some outstanding screens, but I do, I was looking over the, uh, November, 10, smarter working group slides, and they did commit to screen and M, and oh, and aspects of P would be studied.

1065
Aliaga-Caro, Jose 05:25:04.954 --> 05:25:07.684
Jp.

1066
Sky Stanfield 05:25:08.314 --> 05:25:25.744
Right, well that and that makes sense to me, I'm trying to understand as I think what you're saying is they would apply it differently than just the flat export and I'm trying to make sure I understand. They would need to apply the profile. But are the thresholds. And everything the same, like, I guess, I'm not sure if I'm understanding.

1067
Sky Stanfield 05:25:25.780 --> 05:25:31.804
Then looking at the profiles and alignment, what would be different.

1068
Roger Salas SCE 05:25:32.374 --> 05:25:38.434
He may be good to go to the next slide. If he has some of that expense, you can always come back to this, but maybe go to.

1069
Sky Stanfield 05:25:38.434 --> 05:25:38.974
Right.

1070
Roger Salas SCE 05:25:39.034 --> 05:25:43.144
That's a little bit more information. I think it's the next slide.

1071
Yi Li SDG&E 05:25:45.692 --> 05:25:47.852
Yeah, good recommendation. Can we go to the next slide?

1072
Yi Li SDG&E 05:25:50.284 --> 05:26:03.874
I, I do agree with you sky. I think terminology is is really important to get on the same page here. I, I think that what would benefit us and benefit the stakeholders too. Um, so our next slide.

1073
Yi Li SDG&E 05:26:06.634 --> 05:26:26.314
We provide a kind of a simplified diagram of obviously, so don't read too much into this. This is, uh, just for a discussion only so on this circuit. We're assuming there's 2 Transformers and, uh, 2 customers, uh, load, which is what the L is indicating for. And the meter is really.

1074
Yi Li SDG&E 05:26:26.410 --> 05:26:33.366
Referring to you that you showed you mean her, and also considered as point of coupling between the utility and the customer system.

1075
Yi Li SDG&E 05:26:36.724 --> 05:26:57.424
Sorry, I'm, uh, all of a sudden start to cough, um, apologize for that and we also marked, uh, what we believe would be the PCs located, which is really, uh, at the generation outputs. Right? So, um, again, this is just a hypothetical example. We are assuming there is a battery.

1076
Yi Li SDG&E 05:26:57.484 --> 05:27:18.006
And there's also a solar system, and please don't look at this, um, take this for any electrical consideration. I'm not really referring to this as AC, couple of system RTC, couple system. What? Not just a symbol sort of symbol representation of a generation system that has multiple assets behind the 1 PCs. So.

1077
Yi Li SDG&E 05:27:18.934 --> 05:27:39.694
What, as we were trying to, um, discuss these internally as to okay if profile, right 1st of all limited generation profile. That's that's what sold me off initially right? Cause when you think of generation profile, we would assume initially it's referring to the aggregated output.

1078
Yi Li SDG&E 05:27:39.754 --> 05:28:00.874
Of, you know, the generation system right. Does not include any of the low reduction that the customer also have on site, but as we're reading through the decision. Uh, and also what's in, you know, there are 205,230 that a commission is asking the utility to clarify if the is.

1079
Yi Li SDG&E 05:28:00.878 --> 05:28:21.934
Bring to the export or the outputs. Um, we believe that the intention was to use the export, which, in this case would be the reading at meter, which equivalent to the total generation on site minus the load on site. Right? That makes sense.

1080
Yi Li SDG&E 05:28:22.054 --> 05:28:22.984
So far.

1081
Yi Li SDG&E 05:28:25.474 --> 05:28:25.834
Okay.

1082
Sky Stanfield 05:28:26.524 --> 05:28:42.604
Wait hold on, it would be the limited generation, the limited generation on site. So what the export amount that the utility that the customer is saying, they will export to using a PCs or other controls not the nameplate amount.

1083
Yi Li SDG&E 05:28:42.994 --> 05:28:45.844
Yeah, not the name play, right? So it would be.

1084
Yi Li SDG&E 05:28:46.802 --> 05:29:07.052
Export, but, you know, given we are only measuring the meter, right that's the value that we're comparing if we're thinking to what, you know, a customer will be submitting. Right? Let's just sync. Hypothetically, there's a table with 12 values that value will be equivalent to what the customer.

1085
Yi Li SDG&E 05:29:07.504 --> 05:29:18.212
Is proposing their system to have, uh, at the point of this meter right? Which reflects, um, you know, the generation minus the.

1086
Yi Li SDG&E 05:29:21.632 --> 05:29:22.742
So, in this scenario.

1087
Sky Stanfield 05:29:22.954 --> 05:29:42.392
1 thing, that's how we've defined it for limited generation profiles or limited generation without a profile. It's not. It's just they set an expert capacity limit using the PCs, for example, and I don't think that there my recollection is there isn't anything in the rule that says that they need.

1088
Sky Stanfield 05:29:42.398 --> 05:29:46.204
Back out the load usage is that what you're saying?

1089
Yi Li SDG&E 05:29:47.104 --> 05:30:03.542
Yeah, that's that's sort of the issue we're having. Right so when I was reading the resolution 50, 30, I, I understand Justin that it's, it's not approved. Uh, but the language did say that, you know, commission believes the.

1090
Yi Li SDG&E 05:30:03.548 --> 05:30:24.664
Pe is referring to the export at the meter, not export at the generation PCs. Obviously the PCs in the scenario needs to have a at the low side to measure the actual boat and use the schedule to regularly.

1091
Yi Li SDG&E 05:30:24.724 --> 05:30:45.844
What the export at the meter will be back to the utility system right? I think that's and someone who's more familiar with that can correct me. I'm mistating that, but, um, the reason we bring this up is that, let's say we are using the export at the meter um, as the reference point for the.

1092
Yi Li SDG&E 05:30:46.624 --> 05:31:06.934
We do have an issue when we compare that directly to the icaay. Right? Cause at the end of the day is estimating amount of generation. It's allowed to host at that 3 phase no. Without triggering any limitation or trigger any violation on electrical system. So.

1093
Yi Li SDG&E 05:31:07.082 --> 05:31:28.142
In that model, right? In that electrical model, this particular customer's mode is already modeled in the system. So, as we're measuring the export at the meter and compare that to the value at the point of the 3 phase note that no onsite low technical gets double counted.

1094
Yi Li SDG&E 05:31:28.892 --> 05:31:49.052
So, again, this wouldn't be a problem if someone is just applied for regeneration, there's no onsite mode, right? They're establishing a new generation system. It's a simple comparison. Right? The generation, um, at each of these 12 value needs to be lower than the limit at each of those 12 values right?

1095
Yi Li SDG&E 05:31:49.414 --> 05:31:54.424
Yeah, it's more complicated when those onsite mode, because that gets Tom double counted.

1096
Sky Stanfield 05:31:55.864 --> 05:32:08.794
Help me understand though again why this is a special circumstance for the versus any limited generation customer with onsite load what is it about?

1097
Yi Li SDG&E 05:32:09.034 --> 05:32:09.934
What's the limit?

1098
Yi Li SDG&E 05:32:10.864 --> 05:32:14.884
Customer, you're referring to you're referring to the current limited export customer.

1099
Sky Stanfield 05:32:15.214 --> 05:32:16.984
Yeah, sorry limited export customer.

1100
Yi Li SDG&E 05:32:17.434 --> 05:32:18.934
Can we go back 1 slide.

1101
Yi Li SDG&E 05:32:24.212 --> 05:32:38.462
So, in the current screening process, where the limit is used to evaluate the application for the currently, uh, limited export customer, it's their generation nameplate.

1102
Sky Stanfield 05:32:38.462 --> 05:32:42.874
It's not though that's not right so, 1 of the big problems and.

1103
Sky Stanfield 05:32:42.934 --> 05:32:49.924
Adamantly did not want to have happen, but for the utilities requests in each of.

1104
Sky Stanfield 05:32:49.930 --> 05:33:09.696
And for it identifies how those screens are applied, and those screens, if you are doing a limited export system, that qualifies under 1 of those PCs options, it identifies that you will, depending on the option selected, be screened using your export capacity. And not your name plate rate.

1105
Yi Li SDG&E 05:33:10.506 --> 05:33:11.074
So.

1106
Yi Li SDG&E 05:33:11.078 --> 05:33:27.784
I have to go back to my team on that, but that's the case. We'll have the same exact issue for those. That's a problematic as well in the scenario that I just named. Right? Because when you're comparing the export to the value.

1107
Sky Stanfield 05:33:27.962 --> 05:33:28.594
Mm, hmm.

1108
Yi Li SDG&E 05:33:28.684 --> 05:33:31.624
Oh, that's on site is getting double counted.

1109
Yi Li SDG&E 05:33:35.642 --> 05:33:37.082
If we want to walk that through.

1110
Alex Mwaura PG&E 05:33:38.912 --> 05:33:39.242
If I.

1111
Alex Mwaura PG&E 05:33:39.304 --> 05:33:42.604
If I may chime in, so I think the issue excuse me.

1112
Alex Mwaura PG&E 05:33:45.456 --> 05:34:06.064
What's being shown on the screen is specific to screen M, I think sky what you're mentioning may be true for other screens right? But for screen name for projects that are using nameplate because this is 3 options for screen name. Right? Is the typical PV profile option is.

1113
Alex Mwaura PG&E 05:34:06.068 --> 05:34:24.392
That option, and then, when I say is not available, we should go back to the 15%. So, for projects that are non typical PV, this is a loan for it. We would make sure that the project name plate is below 90% of and 90% of.

1114
Alex Mwaura PG&E 05:34:25.864 --> 05:34:31.082
But for like, screening for screen D, for example, that will be based on the export.

1115
Sky Stanfield 05:34:33.694 --> 05:34:45.542
All of our time negotiating, we spent, like, 6 months negotiating that if you're using the whole point of all of that. But difficult negotiation was so that if you were using a for that, you're you would have.

1116
Sky Stanfield 05:34:45.724 --> 05:35:06.694
I screen them and screen and the transformer, I think screen as well using the limited export amount. I'm not saying that again I'm hoping Brian can help me out with this issue of the load, but I'm not saying that you haven't identified an issue potentially. But what I, what I think we're doing is.

1117
Sky Stanfield 05:35:06.724 --> 05:35:27.844
Characterizing what would happen for a limited generation profile project incorrectly the whole point of all those months of work on the limited generation profile was to make sure the screen end was not applied or screen M as in Mary. And M, and as a Nancy not applied using the nameplate rating what would.

1118
Sky Stanfield 05:35:27.850 --> 05:35:40.474
Be the point of limiting your export if that was not done and that was why we spent all working through all the utility concerns around the different PCs configurations in response time.

1119
Sky Stanfield 05:35:42.334 --> 05:35:45.844
It sounds to me, like, this is sort of a separate issue from the although it means.

1120
Sky Stanfield 05:35:45.904 --> 05:35:48.814
An issue that needs to be discussed.

1121
Roger Salas SCE 05:35:49.114 --> 05:36:03.094
Yes, and I think when you're talking about though, I think is not necessarily with screen em, all of the discussions that we had was related ready to screen I, you know, the various options of, you know, so so, maybe we just need to go back to what we actually.

1122
Roger Salas SCE 05:36:03.124 --> 05:36:12.274
Putting the 4 screen, em, itself and all those discussions that we have, where related to screen em.

1123
Sky Stanfield 05:36:13.054 --> 05:36:15.514
I think you need, do you have real 21 in front of, you?

1124
Alex Mwaura PG&E 05:36:20.074 --> 05:36:20.464
I.

1125
Alex Mwaura PG&E 05:36:22.234 --> 05:36:22.384
I.

1126
Alex Mwaura PG&E 05:36:24.934 --> 05:36:25.322
Sky.

1127
Sky Stanfield 05:36:25.354 --> 05:36:28.742
So, are you looking at look at section?

1128
Roger Salas SCE 05:36:29.882 --> 05:36:31.292
But again is.

1129
Roger Salas SCE 05:36:31.324 --> 05:36:32.344
To screen.

1130
Alex Mwaura PG&E 05:36:32.734 --> 05:36:33.124
Yes.

1131
Roger Salas SCE 05:36:33.394 --> 05:36:34.294
Screen name.

1132
Sky Stanfield 05:36:34.714 --> 05:36:35.524
You read it.

1133
Sky Stanfield 05:36:39.184 --> 05:36:58.084
It falls is the is the this is the whole oddity around how we did this. I agree. It's confusing as heck, so don't so bear with me, but screen I is the screen about whether using acceptable export controls. But then it says if you're using this export control, go to go to section in them to.

1134
Sky Stanfield 05:36:58.356 --> 05:37:19.234
Or, or what depending on which 1 you're using, and then it explains how the screen the other screens would be applied. And in particular it identifies, for example, J. K. L. M. N. O. and how those would be applied using the export capacity email, or the name play rate. If you were above.

1135
Sky Stanfield 05:37:19.266 --> 05:37:40.234
2nd response time, for example, you don't get the benefit of using your export capacity amount, but the whole point of creating all those additional, and then, et cetera was to ensure the customers get reviewed using your export capacity. There's no point if that doesn't happen, nobody would ever do this. Why would you agree? Why would you.

1136
Sky Stanfield 05:37:40.388 --> 05:37:45.874
In your export, if you're just saying you're going to study me as though I'm when would you study the limited export them out?

1137
Alex Mwaura PG&E 05:37:47.614 --> 05:37:51.874
For screens, not not screen name for screen D for example, who would apply.

1138
Sky Stanfield 05:37:51.874 --> 05:37:57.904
Alex, you have the tariff in front of you tell me what section 2 sets.

1139
Sky Stanfield 05:38:01.834 --> 05:38:07.264
Particularly is under the evaluation of limited export system, requesting interconnection under this section.

1140
Alex Mwaura PG&E 05:38:09.874 --> 05:38:10.714
Give me 3rd.

1141
Alex Mwaura PG&E 05:38:25.384 --> 05:38:32.494
I'm looking for it's guy cause, uh, I was looking at the advice letter, but let me actually pull the tariff itself. So I can see it.

1142
Alex Mwaura PG&E 05:38:32.704 --> 05:38:33.604
So.

1143
Younes, Amin 05:38:34.836 --> 05:38:36.456
256 is what you want to think.

1144
Alex Mwaura PG&E 05:38:36.816 --> 05:38:47.946
Yeah, and to to, uh, so if maximum value, um, impacts of grid under screens D. I. J. K. M. N.

1145
Alex Mwaura PG&E 05:39:00.454 --> 05:39:00.694
Yeah.

1146
Sky Stanfield 05:39:10.562 --> 05:39:28.954
So, the 1st sentence in that section is, if the maximum value is greater than 1% of the PCs controlled name, play as provided by the middle, utilize the requested limited export value, plus maximum, steady state value of the times the PCs.

1147
Sky Stanfield 05:39:29.134 --> 05:39:34.204
To evaluate the impact to the grid under screens. D. I. J. K. L. M. N. O.

1148
Yi Li SDG&E 05:39:37.024 --> 05:39:43.534
What is the but what is the control nameplate and whoever driving this? I can't go to the next slide. Please.

1149
Yi Li SDG&E 05:39:47.614 --> 05:40:06.364
Scott in this scenario, let's forget about the when you see the names of the PCs, are you referring to the combined export of the generator only or they combine export minus the low, which is at the meter? Is it export to the grid or the generator?

1150
Sky Stanfield 05:40:06.364 --> 05:40:06.994
Export.

1151
Yi Li SDG&E 05:40:07.324 --> 05:40:09.574
You are using this export too loosely here.

1152
Sky Stanfield 05:40:11.286 --> 05:40:32.404
So maybe Brian can help me out here a little bit but I I think that what we were envisioning was the export pass the, um, and that was kind of the whole point, especially because when we talk about adding so if you have a storage plus solar system as you have envision here, what we wanted to avoid is a project being studied. This is the storage.

1153
Sky Stanfield 05:40:33.336 --> 05:40:53.554
Putting simultaneously that was the that's the most basic use case. Here is just saying, I'm not going to export from the battery and the solar system simultaneously. It will be limited by the. So, we'll never export and it could be, you know, the number is up to the customer. What that is as long as you're using.

1154
Sky Stanfield 05:40:53.582 --> 05:40:57.124
Pcs that meets all those criteria we identify.

1155
Roger Salas SCE 05:40:59.494 --> 05:41:10.204
Yeah, wonder, I wonder if we're I know that, you know, I'm, I'm wondering if we focus a little bit on on the issue here, rather than debating everything I was I, I think.

1156
Sky Stanfield 05:41:10.204 --> 05:41:10.414
Call.

1157
Roger Salas SCE 05:41:10.414 --> 05:41:20.344
Okay, which is needle, I will say re, familiarizes with that, but let's go back to the issue here at hand and why this is a problem because I think maybe this is a.

1158
Roger Salas SCE 05:41:20.374 --> 05:41:28.804
Soon, why we need to continue to discuss is the main issue here is that if we have an.

1159
Roger Salas SCE 05:41:30.062 --> 05:41:49.954
Uh, you know, a data electrical node that you see there with the, that, that I see profile, um, accounts for the load of these customers, right? It assumes that this customer has 1 megawatt 1 megawatt.

1160
Roger Salas SCE 05:41:50.704 --> 05:42:11.104
And when we do our modeling, we, uh, we model 1 Meg will load and that's the reason why at allocation you have to maybe 2.5 megawatts of right? It assumes that these location, what has 1 megawatt load right now if if you know an example here you take the 2.5.

1161
Roger Salas SCE 05:42:11.134 --> 05:42:32.254
It doesn't say, okay. Yeah, I have 2.5 megawatts here, but you actually are able to export 2.5 megawatts and serve the local load. Now you will double counting the problem. Meaning like meaning like the original value that you believe I met was originally.

1162
Roger Salas SCE 05:42:32.554 --> 05:42:40.446
The 1 megawatt or Valley 1 megawatt load in the simulation and that's the reason why we had a 2.5 megawatts.

1163
Roger Salas SCE 05:42:41.016 --> 05:43:01.866
Uh, if if the logo wouldn't have been there, it probably would have been 1.5 megawatts of but because of the loads there, we have 2.5 megawatts of. And so if the generator exports, the full 2.5 megawatts of, and serves the 1 megawatt load, then essentially.

1164
Roger Salas SCE 05:43:01.984 --> 05:43:08.794
We're double counting the 1 megawatt load that we got there. Right? It would be like having 2 megawatts of load.

1165
Regnier, Justin 05:43:10.984 --> 05:43:11.584
Here though.

1166
Roger Salas SCE 05:43:11.944 --> 05:43:12.334
Mm, hmm.

1167
Regnier, Justin 05:43:12.754 --> 05:43:14.254
Just with a direct question.

1168
Regnier, Justin 05:43:17.586 --> 05:43:29.766
Is this issue so, my understanding of this issue is that if you start with no generation system, if you start looking at just these 21 megawatts of load.

1169
Roger Salas SCE 05:43:30.336 --> 05:43:30.726
Mm, hmm.

1170
Regnier, Justin 05:43:31.956 --> 05:43:37.086
You've got an value of, you know, it says the thermal here is 2.5 megabytes.

1171
Regnier, Justin 05:43:37.144 --> 05:43:37.564
Sure.

1172
Regnier, Justin 05:43:40.204 --> 05:43:52.594
Whether the generation facility is a static permission to operate so 1 megawatts all the time. Mm. Hmm. Or limited generation profile.

1173
Roger Salas SCE 05:43:52.984 --> 05:43:53.374
Yeah.

1174
Regnier, Justin 05:43:54.304 --> 05:43:56.404
Varying is the same problem.

1175
Roger Salas SCE 05:43:56.824 --> 05:43:57.574
Same problem. Yeah.

1176
Regnier, Justin 05:43:57.574 --> 05:44:00.304
Understanding the same problem is that the.

1177
Roger Salas SCE 05:44:00.694 --> 05:44:00.964
Right.

1178
Regnier, Justin 05:44:01.116 --> 05:44:06.154
Factor in the diminishment of existing load when a generator is added.

1179
Roger Salas SCE 05:44:06.606 --> 05:44:07.054
That's right.

1180
Regnier, Justin 05:44:07.536 --> 05:44:18.814
So, I don't see that this meets the criteria that we've discussed in the resolution of only imposing restrictions upon projects that are triggered by particularly.

1181
Yi Li SDG&E 05:44:19.324 --> 05:44:22.234
No, I, I wouldn't agree with that. It.

1182
Yi Li SDG&E 05:44:22.266 --> 05:44:32.044
Right, right so think of the current generating customer, when they apply, they are getting value based on nameplate. Right? So.

1183
Yi Li SDG&E 05:44:36.002 --> 05:44:54.602
So, when name please being compared to the icaay, it is fair comparison. So, I, I don't think the problem is that if it's static or if it's dynamic it, the problem is really is, what are we referring to as the point of measurement and what we're are we comparing it to we again. Um.

1184
Yi Li SDG&E 05:44:55.144 --> 05:45:14.914
I'm speaking for in here, right? We, we don't necessarily have our self position married to any particular way of measuring this. We're just saying that, yes, if we consider that, we're measuring at the point of meter and we have to remove the load in words. You have a proper comparison with the.

1185
Yi Li SDG&E 05:45:15.934 --> 05:45:36.392
We wanted to measure at the PCs, and we do not have to measure to remove the load to do this comparison because that the PCs is representing the output of the generation. But that does pose a challenge to our previous topic meter. Right? Because now when we get the data.

1186
Yi Li SDG&E 05:45:36.970 --> 05:45:55.176
That's not representing what the output is, because the output is what's at the PCs. So again, we're not trying to cause trouble here. We just want to talk this out because I think the important now we're talking, you know, in the same language, because these are a little confusing. Right? Let's just be I'll be transparent with that.

1187
Sky Stanfield 05:45:55.536 --> 05:45:58.026
That's fair. So what I hear you saying.

1188
Sky Stanfield 05:45:58.144 --> 05:46:05.914
Is that I don't think this is an issue. I think when you said the reference to the.

1189
Sky Stanfield 05:46:06.784 --> 05:46:27.662
Again, protested the, the need for quarterly reporting on the same basis that you're using a certified system. And what you're saying is, you want a verification of the certified system works and that's not our exposition is that that's not necessarily the commission hasn't decided that 1 or the other and I appreciate the middle ground. You guys offer there but this is not.

1190
Sky Stanfield 05:46:27.902 --> 05:46:48.874
A unique issue, it may be an issue that we need to have a broader conversation about but I still didn't hear anything that actually has to do the distinguishes the performance of the system from the performance of a limited export system in terms of how the screen should be applied I'm not. And again I.

1191
Sky Stanfield 05:46:48.904 --> 05:47:06.544
To be clear that Brian and I are texting on the side. Like we do, we might need to have another conversation about this issue as it applies to any system that's controlling export when when we're applying the IC it. But I don't I'm not hearing that. This is a profile issue.

1192
Yi Li SDG&E 05:47:09.754 --> 05:47:28.984
So, this is not necessarily issue for 511 right? But for 5 to 30, I use our asked to clarify that when we speak of, we are talking strictly to the export at the point of the, to the grid, not the output of the generation.

1193
Yi Li SDG&E 05:47:30.092 --> 05:47:50.912
Saying that before, we can clarify that. We need to reach the common ground to your point that we may have an issue with the current language in the row, 21 of having the same issue. But that's a separate conversation that I don't think it falls into any of these roles in scope but I understand it's not an issue but we are direction now.

1194
Yi Li SDG&E 05:47:50.920 --> 05:48:07.984
To working on the tariff changes too far advice letters to propose the language what's you know, it's it's important we get it right, right. If we have a language in the original that needs to be corrected, let's tackle that. But for the language that we're going to propose, let's make sure we do it. Right?

1195
Sky Stanfield 05:48:08.224 --> 05:48:12.064
Okay, yeah, I can agree on that. I just wanted to distinguish to make sure we.

1196
Sky Stanfield 05:48:12.068 --> 05:48:33.212
They're all on the same page with what the problem is. So, I think for Iraq, what I, what I can say, unless brand wants to jump in and has passed or processing skills and I do, you know, I think we're going to need to digest this. Not just for, but also for limited export projects overall, whether they're using a relay or a.

1197
Sky Stanfield 05:48:33.516 --> 05:48:54.276
Or or something, um, but it does sound like, you may have potentially identified an issue, we need to think about broadly. Um, and maybe the time to think about it here is that I just wanted to make sure we were distinguishing what is specifically caused by the profile versus caused by just limiting export as a whole, um.

1198
Sky Stanfield 05:48:54.370 --> 05:48:58.954
Can we go back to the earlier slide? I think I'm afraid I've lost the other questions I may have had, but I'm hoping.

1199
Yi Li SDG&E 05:49:00.334 --> 05:49:04.984
Has his hands raised, Alex? Do you want to comment on something on that topic? 8.

1200
Sky Stanfield 05:49:05.104 --> 05:49:06.724
I mean, as is.

1201
Alex Mwaura PG&E 05:49:07.324 --> 05:49:15.514
Yeah, I just I just wanted to confirm, um, to sky. I think I did already, but it might have been somebody else talking that, you know, you.

1202
Alex Mwaura PG&E 05:49:15.692 --> 05:49:17.732
Correct that under.

1203
Alex Mwaura PG&E 05:49:18.516 --> 05:49:35.946
Is included in analyzing, uh, using the limited export value. So, I mean, obviously, as we've discussed this, uh, direct conflict between the current screen and language, and so, as part of maybe.

1204
Sky Stanfield 05:49:36.846 --> 05:49:39.484
I just want to pause there is not a conflict. This was.

1205
Sky Stanfield 05:49:39.664 --> 05:50:00.456
Unintentional it was intentional. That was why we did it the way. This was the way you guys wanted to do it. You did just want to put it in screen. You wanted to put it in. It is not a conflict. It's expressly stating. This is how you will apply it and that was the preferred approach. It doesn't mean that this issue goes away, but this is not this this was.

1206
Sky Stanfield 05:50:00.754 --> 05:50:04.774
Exactly what we were trying to accomplish through M.

1207
Alex Mwaura PG&E 05:50:04.804 --> 05:50:05.074
Yeah.

1208
Sky Stanfield 05:50:05.494 --> 05:50:21.784
Et cetera now again, it doesn't mean we don't need to work on it. So I don't think we should spend time fighting about it but it is really important. That today if you're proposing to interconnect the project that's limited export. It sounds like there's some disagreement about how you guys are actually doing it. Um, so I feel like we've raised a much bigger.

1209
Sky Stanfield 05:50:21.814 --> 05:50:26.494
Issue here, which is worth debating or figuring out, but it's not.

1210
Alex Mwaura PG&E 05:50:26.494 --> 05:50:35.134
The reason I say, yeah, the reason that's the conflict is because screen and language is very clear, but obviously, you know.

1211
Alex Mwaura PG&E 05:50:36.124 --> 05:50:53.404
I don't want to spend too much time on this, but the issue here, I think what happened is we were so focused on resolving the ones and the screen. I language that we completely kind of forgot about this screen him. You know, changes that we're making to the tariff. We didn't really reconcile the 2 things, but anyway, that's that's all I have to say.

1212
Younes, Amin 05:50:54.034 --> 05:50:57.034
Can I jump in? I I think, and I'm not.

1213
Younes, Amin 05:50:57.064 --> 05:51:18.184
Super familiar with the limited export profile. I'm just reading about it. In fact, the 1st, time ever but in glancing through it. I believe that. That is measuring export at the, not at the, at the and so, the word export. If you talked about limited export, profile and limited generation profile, those export words are not the same thing they're talking about.

1214
Younes, Amin 05:51:18.214 --> 05:51:39.184
Different types of export 1 is export from a combined power system. 1 is export at the point and I think that is why yeah, so the PCs in the BCC so that is why there's a difference between how a limited export system would apply in a limited.

1215
Younes, Amin 05:51:39.366 --> 05:51:41.016
Generation profile would apply.

1216
Sky Stanfield 05:51:41.376 --> 05:52:00.484
Well, I don't think we've decided that that's I think the question here is, I don't, I don't recall any conversation about playing the at a different point than than the limited export is obviously it's something we're going to need to work out, but I don't think I don't know what you're where you're reading not from but I don't recall ever that being a conscious.

1217
Sky Stanfield 05:52:00.490 --> 05:52:05.286
Conversation so, Brian, did you want to weigh in here?

1218
Brian Lydic - IREC 05:52:06.276 --> 05:52:21.634
Yeah, I just wanted to say that I think the original concept was that, you know, a power control system is managing export, whether it's for the limited limited generation. Um, whatever we call it limited export.

1219
Brian Lydic - IREC 05:52:21.784 --> 05:52:42.784
Which is just a steady state limit. Um, it's doing the same thing as you would do with the. But it's just doing it at 1 static limit. Um, and you know, how the exactly where the PCs lies in the system is up to the developer to determine where the best appropriate spot is but we're really.

1220
Brian Lydic - IREC 05:52:42.814 --> 05:53:03.634
Takes effect, from the rule standpoint is the export, and that's most likely also the place that it would technically take effect. So that, you know, if they have load at the site, they would also be able to account for all the load and serve their load before exporting. So, I think we can think about it logically as.

1221
Brian Lydic - IREC 05:53:04.024 --> 05:53:14.464
The same type of system same equipment doing the same thing, but the PCs is doing it by schedule in 1 case with the, and it's just doing it. Statically. In the other case.

1222
Roger Salas SCE 05:53:18.454 --> 05:53:37.714
And, for me, as simpler solution, Here's what we propose on, down down at the bottom, which is consistent with what there's other on the other sections. So, other of the, uh, order, which basically, if you reduce, if you're reducing your own load in impacting the IC values, then let's just be wrong.

1223
Roger Salas SCE 05:53:37.780 --> 05:53:43.564
What the real values at our location to get the most updated I see your values, assuming that they sort of load.

1224
Regnier, Justin 05:53:46.294 --> 05:53:53.676
Roger, it sounds like you are proposing that solution for both static, limited, export and limited generation profile.

1225
Roger Salas SCE 05:53:54.244 --> 05:53:54.516
Yeah.

1226
Regnier, Justin 05:53:55.116 --> 05:53:56.734
Ca value it's not to.

1227
Roger Salas SCE 05:53:57.964 --> 05:54:06.756
It'd be easy to address, you know, if we're going to be doing, it can be an export in whether it's, you know.

1228
Regnier, Justin 05:54:09.454 --> 05:54:28.414
Valuable that we've delighted this issue, um, at the top of this meeting was they did articulate the, you know, changes in how the is computed rather than the scope of this particular discussion. So, I mean, I think it is valuable that we delighted. And I think it's something we need to think about stakeholders.

1229
Regnier, Justin 05:54:28.654 --> 05:54:49.684
Commission, um, but I'm not sure this is the venue for resolving that particular question because fundamentally, it's a question, as I understand, that fundamentally is a question of when the is computing hosting capacity. Should it remove the load on site that the renewable energy.

1230
Regnier, Justin 05:54:49.714 --> 05:55:04.324
Generation facility is located prior to determining the value and it's all value. It doesn't have to do so much with the screens of the applications is what the IC value returns for consideration in.

1231
Roger Salas SCE 05:55:07.714 --> 05:55:11.044
Yeah, usually that's the case. I mean, that's that's kind of the issue, right?

1232
Regnier, Justin 05:55:12.604 --> 05:55:14.284
Yep, so I mean, I'm.

1233
Regnier, Justin 05:55:18.992 --> 05:55:32.222
Very noisy, because there's a facilitator, but I think we'd be okay with ruling this 1 out of the scope of this discussion thinking about it and bring it back up as necessary rather than discussing this particular topic.

1234
Roger Salas SCE 05:55:33.094 --> 05:55:33.332
Yeah.

1235
Regnier, Justin 05:55:33.632 --> 05:55:37.024
Computation update here.

1236
Aliaga-Caro, Jose 05:55:37.654 --> 05:55:45.394
So, uh, Justin, uh, thank you. Uh, so it looks like we need more discussion on how these screens will be applied.

1237
Aliaga-Caro, Jose 05:55:48.694 --> 05:55:57.332
That's my take away from the last few minutes that we've had on this topic, 7 and 8.

1238
Aliaga-Caro, Jose 05:55:59.614 --> 05:56:14.314
Uh, you know, from the November, 10 smarter were the working group might take out of that with that and oh, and parts of P would study the value. But now.

1239
Aliaga-Caro, Jose 05:56:15.934 --> 05:56:22.954
In the last few minutes I am now, my brain is a little muddy on, you know, what's going on here.

1240
Roger Salas SCE 05:56:24.394 --> 05:56:45.304
Yeah, I mean, it seems to me that again, um, you know, we can resolve this relatively quickly, or or make make a make it more complicated, but consistent with what I believe is like, or in paragraph 3 or 4. we basically said something like, when the IC values needs to be updated, you Theresa, allow to.

1241
Roger Salas SCE 05:56:45.308 --> 05:57:00.454
Basically update the IC value when, you know, when, when when when, um, determining whether or not the project passes the, um, the IC values there. I mean, that's essentially what.

1242
Sky Stanfield 05:57:00.632 --> 05:57:06.094
Was like for the limited scenario where the, the value had changed in the 1 month, period.

1243
Sky Stanfield 05:57:08.104 --> 05:57:27.274
Doing this, but I think I think this is something we're all gonna have to discuss and I want to like, I think we should probably everybody should be able to adjust this. But I want to say that the idea that the whole idea of streamlining all of this and adopting an, was that you could go to a map and you could plan your system based on a profile.

1244
Sky Stanfield 05:57:27.634 --> 05:57:48.454
It takes a lot of work as as as was explained earlier, um, a customer's going to do a lot of math and a lot of deliberation to figure out a profile that works. If the isn't, they aren't going to know what the profile is. That's the problem. Now, I'm not saying that's off the table, Robert. Maybe that that's what we have to do to fix this but I think.

1245
Sky Stanfield 05:57:48.786 --> 05:58:09.904
We haven't had a chance to digest this and think through the solution. It's helpful that you put 1 forward. But I think that, that 1, my initial gut on that is that that undermines the ability for customer to even design a profile because I don't actually know what the profile is being designed around. If I say it has to be rerun on the customized basis. And so I.

1246
Sky Stanfield 05:58:09.936 --> 05:58:31.054
Think that we have to think more about whether this is a real issue how it's accommodated and I'd like to Jose and Dustin I think, you know, credit to the utilities. We're identifying this as a potential issue. Overall. Maybe we need to talk about what they have a separate call or something to think about this. I think again, I don't think it's really an issue, but it's, it's an issue potentially.

1247
Sky Stanfield 05:58:31.082 --> 05:58:34.322
An issue that we all need to digest and confer on.

1248
Roger Salas SCE 05:58:35.794 --> 05:58:36.094
Yeah.

1249
Sky Stanfield 05:58:36.394 --> 05:58:36.964
Um.

1250
Sky Stanfield 05:58:38.854 --> 05:58:44.794
If we're agreeing that we should pause this for that reason, I wanted to go back into some of our customers. The other slide.

1251
Aliaga-Caro, Jose 05:58:47.344 --> 05:58:58.894
Uh, yeah, go ahead. Slide. Uh, I did want to say that, you know, my, and thank you for this graph, uh, to utilities cause I had not considered this at all. Uh, my take from export.

1252
Aliaga-Caro, Jose 05:59:00.036 --> 05:59:20.164
Was basically what is actually being put outside onto the grid itself after load has been after load that's its job and consumes, you know, whatever comes out of the. So, because that ultimately is what.

1253
Aliaga-Caro, Jose 05:59:20.410 --> 05:59:21.634
Fix the, um.

1254
Aliaga-Caro, Jose 05:59:24.062 --> 05:59:37.114
The quality and reliability of the grid. So I like I said, I think you, uh, to utilities for putting this, uh, diagram because I had not considered this scenario before.

1255
Sky Stanfield 05:59:38.312 --> 05:59:44.374
The other thing to keep in mind too, just for everybody's digestion is, is that the ice as we talked about the 24.

1256
Sky Stanfield 05:59:44.404 --> 05:59:58.744
Our profile, it's not being designed around actual, an actual profile. So some, there's some other issues with the way the load is already being incorporated into the, and it'll have to be in this mix as well.

1257
Sky Stanfield 06:00:00.484 --> 06:00:05.464
I think, okay, going back, go back to the earlier slide. If you could please.

1258
Sky Stanfield 06:00:09.094 --> 06:00:21.004
So, uh, 1 other and this is maybe a smaller well, I shouldn't say that I've never never end up being that way. So I appreciate the difference between the application versus the.

1259
Sky Stanfield 06:00:21.064 --> 06:00:42.184
In terms of what you might be looking at, in terms of, like, what actually happens though, when there is an operational flexibility issue, and there needs to be an emergency reconfiguration. It seems to me, like, the options that are on the table at the same either way, you're going to do the emergency reconfiguration. The customer is going to be curtailed. Like we talked about already what would happen in those.

1260
Sky Stanfield 06:00:42.190 --> 06:01:03.334
Circumstances it may be that it that happens could happen more often if you didn't reject the project because of, which is a whole, another big conversation. But I just wanted to confirm what, if you do that reconfiguration you're not going to have the project exporting. You're going you have the ability under.

1261
Sky Stanfield 06:01:03.340 --> 06:01:14.164
Our emergency emergency conditions, or whatever we want to call it to curtail that project until the reconfiguration is reversed back to normal essentially. Right?

1262
Yi Li SDG&E 06:01:15.574 --> 06:01:24.276
Yeah, so to provide some background, we're providing this just to, to lay out the risk right? Cause that was the discussion of the worst stop number 1.

1263
Yi Li SDG&E 06:01:24.876 --> 06:01:45.574
We're not saying that this doesn't change our position as how we're gonna handle in the emergency situation but that is something that we don't have to deal with as often if a project did stay under the. Right. So I think that's something that we should probably agree to is that there is a different level of likelihood that.

1264
Sky Stanfield 06:01:46.654 --> 06:01:48.844
I don't know that that is quite right.

1265
Yi Li SDG&E 06:01:48.874 --> 06:01:49.834
Because.

1266
Sky Stanfield 06:01:50.464 --> 06:02:06.724
We don't know how you guys are applying the, what you're doing when a project fails the, and it gets to something That'll review. This has been a big problem, right? Is you guys haven't defined what you're actually going to do? Are you going to say that a project a regular project?

1267
Sky Stanfield 06:02:06.790 --> 06:02:27.904
Whether it's limited generation or not limited export or not. Is are you going to reject projects that go below the and might require them to do upgrades? If so we're pretty much it's going to be radically expensive interconnection across the state of that's the case that you guys have sort of been said.

1268
Sky Stanfield 06:02:27.940 --> 06:02:39.304
We're going to do it on the case by case basis, I think, with no guidance on what how that will actually be evaluated but you haven't said every project that violates will actually have to do upgrade.

1269
Yi Li SDG&E 06:02:39.514 --> 06:02:49.084
No, I, I disagree that we provide no guidance. I mean, our rule 20 ones very clearly laid out what the process will be. If a project fell icaay. No.

1270
Yi Li SDG&E 06:02:49.116 --> 06:02:51.634
And when it's, you know, novel.

1271
Yi Li SDG&E 06:02:52.266 --> 06:02:52.536
Right.

1272
Sky Stanfield 06:02:53.644 --> 06:02:55.026
That language is that.

1273
Yi Li SDG&E 06:02:55.054 --> 06:02:55.624
Kind of.

1274
Sky Stanfield 06:02:55.624 --> 06:02:56.494
What you're going to do.

1275
Yi Li SDG&E 06:02:56.616 --> 06:02:58.564
Yeah, my screen, I'm Ashley, I took the.

1276
Sky Stanfield 06:02:58.564 --> 06:02:59.134
3.

1277
Yi Li SDG&E 06:02:59.134 --> 06:03:12.696
1 yeah, screen yeah, you can see that. I have a project sales is going to go to technical screening and our engineer will do an analysis to see what's causing this to be on. And the problem here is that we're seeing, is that.

1278
Yi Li SDG&E 06:03:13.082 --> 06:03:34.204
Without screening, we don't have the ability to do studies. Right that's the whole point of using to fast track. These application. That may be it'll allow it to operate above. So, we don't have the ability to perform the studies to even understand what those limit violation is, to your point.

1279
Yi Li SDG&E 06:03:34.774 --> 06:03:55.354
If we did do those studies, we, our engineer may be coming up with scenarios that we can do, we can implement some steps to mitigate the issue. Right. For example, switching or we know that there was a problem. That will cause reverse flow on this particular application. But what we're saying here is that for customer, they don't even get.

1280
Yi Li SDG&E 06:03:55.360 --> 06:04:13.474
Probably against the right so there's no further study no technical review against that point because they don't really like, unless, you know, someone who's not doing mass, they wouldn't really even go through and fail screen, em, in the scenario for customer.

1281
Yi Li SDG&E 06:04:19.714 --> 06:04:23.884
Just so I, I don't know if your hands are from before, or you have a question here.

1282
Yi Li SDG&E 06:04:30.664 --> 06:04:32.344
Dustin, hey, there.

1283
Regnier, Justin 06:04:33.124 --> 06:04:34.564
Yeah, um.

1284
Regnier, Justin 06:04:36.392 --> 06:04:57.242
No, my comment, I wanted to make sure that we got into the discourse here has to do with sky's point last time about not only risks to the system, but benefits for systems. So, I think we, we do want to make sure that we daylight the benefits for the system unique benefits through the system.

1285
Regnier, Justin 06:04:57.482 --> 06:05:00.604
Not just the ones for the customers.

1286
Regnier, Justin 06:05:01.714 --> 06:05:08.824
Operating at a higher capacity factor was represented in the last 1 as a benefit for rate Paris.

1287
Regnier, Justin 06:05:10.116 --> 06:05:29.346
I can see why that would be, but we don't have a record built around us. So we should probably speak to what that benefit is at some point. Um, I think that the non parties have been very Frank and direct about, um, you know.

1288
Regnier, Justin 06:05:31.596 --> 06:05:52.384
The fact that more full utilization, higher capacity, factor of existing infrastructure reduces the flexibility of the to manage the grid. So they have less options available to them potentially. So, we're, we're making that trade off.

1289
Regnier, Justin 06:05:52.414 --> 06:06:04.654
On a conscious basis, I just want to make sure that we get into the record what we started. The benefits of a higher capacity factor grid are are running the grid at a higher capacity factor on.

1290
Yi Li SDG&E 06:06:06.064 --> 06:06:13.504
When you say running a good a higher capacity, provide benefits to all the repairs, what are the.

1291
Yi Li SDG&E 06:06:13.564 --> 06:06:14.314
Record on that.

1292
Sky Stanfield 06:06:16.864 --> 06:06:18.634
I think what he's asking is, is that we.

1293
Regnier, Justin 06:06:18.634 --> 06:06:19.384
Trying to build.

1294
Sky Stanfield 06:06:19.504 --> 06:06:21.094
To build the record on that.

1295
Regnier, Justin 06:06:21.124 --> 06:06:21.394
Yeah.

1296
Sky Stanfield 06:06:21.904 --> 06:06:37.504
And Justin, we can talk about where that comes in, I guess, but I don't think I think there's a real basic element here that is clear that there's, I don't know if any of you guys are an customer.

1297
Sky Stanfield 06:06:37.536 --> 06:06:58.654
But if you get between 5 and 60 PM a request to reduce your load all the time, during those hours, it's because we don't have enough energy. And what we're trying to do is provide more energy during those critical hours. That's the whole story here. And without having to upgrade the grid, because it's not needed, but California has a.

1298
Sky Stanfield 06:06:58.660 --> 06:07:19.804
Position shortage during those critical hours that either we're going to solve by reducing load through demand response, which is 1 thing that's being explored. We're going to build more generation and potentially have to build more generation plus more grid essentially to do that. And we can avoid that. If we allow projects to perform with.

1299
Sky Stanfield 06:07:19.832 --> 06:07:40.954
The system constraints, that's our basic characterization of the issue. And I think that means point whenever nobody's modeled all that that's not but I don't think it's very far off basic conceptual understanding of that's what the point is is and we know, I mean, it's headline national news that California needs more power during certain.

1300
Sky Stanfield 06:07:40.984 --> 06:08:02.104
Hours of the day, especially during certain times of the year and that grid constraint if we decide that they have to upgrade the grade, even though it doesn't need to be upgraded to provide that that is going to raise cost. I mean, that's just as simple as kid who's going to pay those costs. That means point. That will be decided, depending on how the rates are.

1301
Sky Stanfield 06:08:02.110 --> 06:08:11.404
And so on, but the interconnection customer, or the developer will certainly be paying the cost if they have to upgrade the grid in order to provide it, because that's how the cost allocation rules.

1302
Yi Li SDG&E 06:08:16.594 --> 06:08:35.914
Um, I, I, I think I've been sick for too long intelligence level has jobs. I'm not drawing a direct line between, like, when we're having a big issue and how is necessarily going to help that problem. Um, and cause I.

1303
Yi Li SDG&E 06:08:35.974 --> 06:08:56.884
To say that, you know, it's not really threatening or there's not enough. At least to me that LGB is really going to, like, avoid up your costs. Maybe you can defer it. Cause utility are still incurring a lot of costs for the down the road to install the upgrade. If it's inevitable you need it.

1304
Yi Li SDG&E 06:08:57.184 --> 06:09:00.364
And let's not forget all the costs that's encouraged right now.

1305
Sky Stanfield 06:09:00.484 --> 06:09:02.824
But if they don't really wouldn't be needed is the.

1306
Roger Salas SCE 06:09:03.814 --> 06:09:18.244
Right, the only way to prevent that from happening is to not allow any more are below 1 mill what require upgrades because what really is going to happen here.

1307
Roger Salas SCE 06:09:18.248 --> 06:09:19.652
Is that analogy the.

1308
Roger Salas SCE 06:09:19.660 --> 06:09:37.294
Project is going to take this, look it up to the maximum level. They don't have to pay for the upgrade then a few months later a less than 1 megawatt. Any price is going to come in. We can tell them that that project and therefore we're going to do the upgrades of the customer repair.

1309
Regnier, Justin 06:09:45.664 --> 06:09:56.044
I don't think anybody's got a crystal ball in terms of how things will happen after inner connection. But that is thank you for sharing perspective on likely outcome.

1310
Yi Li SDG&E 06:10:03.754 --> 06:10:06.844
Uh, I I actually believe these are my last slides.

1311
Yi Li SDG&E 06:10:07.564 --> 06:10:10.474
Collecting the slides sorry?

1312
David Schiada 06:10:10.504 --> 06:10:20.284
Just, yeah, this is Dave just before we move on just Dave shot just a question, Justin so I'm understanding kind of the, uh, expectation.

1313
David Schiada 06:10:20.290 --> 06:10:41.104
On on getting benefits on the record was, is it that, that the, I owe you advice letters would include something like W. W during workshop discussions. There was consensus that the extent there were tools and processes that allowed.

1314
David Schiada 06:10:42.064 --> 06:10:50.194
More, uh, higher efficient use of the grid. Those should be encouraged because they could benefit customers. Is that.

1315
David Schiada 06:10:51.332 --> 06:10:53.042
That or is there anything more than that?

1316
Regnier, Justin 06:10:55.954 --> 06:11:15.274
I think, unfortunately, Brad is not here and he's the 1 that articulated it. And this is something that came out of our review of the, the video last time. But there's an assertion that a higher capacity running, the greater, the higher capacity factor provides benefits. Um, we want to make sure that.

1317
Regnier, Justin 06:11:15.280 --> 06:11:20.494
We understand what stakeholders mean by that. So it captured in the record um.

1318
Regnier, Justin 06:11:23.912 --> 06:11:24.184
Yeah.

1319
David Schiada 06:11:24.364 --> 06:11:24.844
Yeah.

1320
Regnier, Justin 06:11:24.844 --> 06:11:36.662
Get a conjecture about Brad man, I can think of of ways. That that might be true, but I want to make sure that we hear from the stakeholders what they're seeing as the benefit to our capacity factor.

1321
David Schiada 06:11:39.274 --> 06:11:50.014
Okay, then just be helpful to get that input from Brad or others to the extent that there's any expectation that that would be reflected in an advice letter. So thanks.

1322
Sky Stanfield 06:11:50.284 --> 06:12:00.364
Can I just I'm, I'm not sure. Did my explanation not make sense to anybody I, I don't understand. I, this is in my mind very simple. And what I'm hearing is, is that we need Brad doing.

1323
Sky Stanfield 06:12:00.424 --> 06:12:09.332
Explain it, and maybe, maybe if we have him explain it better than I, but I'm not sure if I'm understanding why this isn't pretty simple.

1324
Regnier, Justin 06:12:09.962 --> 06:12:14.524
Understood what you said, not sure that it's the entirety of what Brad would have said. Right Hmm.

1325
Sky Stanfield 06:12:14.552 --> 06:12:21.542
I'm sure that's fine but okay. And but today's question are you not are you do disagree.

1326
Sky Stanfield 06:12:21.548 --> 06:12:42.454
With my characterization, or what I want to make sure that I do understand if I'm wrong about the basic concept here that providing more energy during the times when California most needs it, it's going to be no specific, et cetera without upgrading the grid is a better a lower cost way.

1327
Sky Stanfield 06:12:42.724 --> 06:12:50.854
providing the energy than it is to upgrade the grid when it doesn't need to be upgraded to provide that additional energy 

1328
David Schiada 06:12:52.864 --> 06:13:12.364
Yeah, yeah, I understand that why I'm just looking at, from the perspective of, you know, when I asked my managing director to sign off on the advice letter of what's being represented cause it's not I think it's still an advice letter that will be filed. And if it's representing, you know, that these were discussions that were held during the workshop.

1329
Sky Stanfield 06:13:12.392 --> 06:13:12.722
Yeah.

1330
David Schiada 06:13:12.754 --> 06:13:13.684
And it was.

1331
David Schiada 06:13:13.746 --> 06:13:34.866
Consensus that, you know, more efficient use of the grid while being able to operate reliably and safely can provide a benefit to, uh, customers, you know, if it's along those lines. I think that's something we could probably represent if it goes beyond that. Or if I'm not fully aware of either your position or brad's position, it's hard.

1332
David Schiada 06:13:34.894 --> 06:13:38.134
To incorporate that in the advice that are given the time we have.

1333
Sky Stanfield 06:13:40.234 --> 06:13:40.894
I mean.

1334
Younes, Amin 06:13:41.920 --> 06:14:03.064
When you say to customers, I just want to clarify that. The point that that guy had mentioned is that that exact way that those ddrs are compensated, makes a huge difference in terms of whether, or not there's a benefit to the customers. I would say that there's a potentially a societal benefit from animating or using those low cost resources, or those existing resources.

1335
Younes, Amin 06:14:03.274 --> 06:14:12.274
Without without upgrade integrated, but whether or not that provides a benefit to rate pairs, certainly, you know, it depends on exactly exactly how that happens.

1336
Sky Stanfield 06:14:13.322 --> 06:14:24.212
And I think that's, I hope I made that clear that I am. I understand that. That's the case. But I also think this is where we have the sort of bifurcated we need to design and interconnection policy.

1337
Sky Stanfield 06:14:24.246 --> 06:14:45.366
separate from the rate structures and the commission can take this into account in the rate structures but if the interconnection policy does not allow a project to do a limited generation profile and requires the upgrades to happen that that value can't be captured even whether it's captured by the customers or just the developer the interconnection rules are separate from the rate rules and that's part of the problem we're having 

1338
Sky Stanfield 06:14:45.394 --> 06:15:06.514
We're trying to set up the International was to enable those, those pricing opportunities and so on. So there's a chicken and egg a little bit. But but the interconnection policy is that the customer pays for the upgrades, unless you allow them to do an, and that cost is going to get built into the project either way. Now, whether they get competent.

1339
Sky Stanfield 06:15:06.542 --> 06:15:27.602
Fully for that, or not goes into the rate proceedings, but here that's why if we don't enable it, it will never happen. You can never capture that benefit if the customer, or you can never capture the savings. You can get the customer to upgrade the grid. If you pay them even more, but that's and I think it would be fabulous to have some.

1340
Sky Stanfield 06:15:27.696 --> 06:15:48.814
Data numbers, I don't know this, but I think that's not going to happen in our proceeding. I think what we're trying to do, I'm trying to do is to enable that capability, so that the commission can do the right rate setting around it. But without that capability, there will be no no option for the customer to do what the commission is trying to encourage, which is performance.

1341
Sky Stanfield 06:15:48.844 --> 06:15:51.124
During peak hours and non pccoe.

1342
Eva Wang TotalEnergies 06:16:08.914 --> 06:16:26.884
I want to comment on, um, into his comments about the whole point of, to defer upgrade instead of, you know, the eliminate upgrades. If that's the case right? If we have to have some sort of upgrade.

1343
Eva Wang TotalEnergies 06:16:26.914 --> 06:16:48.034
Sound road then I would say, like, all of our customers won't be interested in doing this, because that that's just saying that we have to pay anyway down the road sometime down the road. And then that also like a hanging thing, like the uncertainty that on top of what we are going to.

1344
Eva Wang TotalEnergies 06:16:48.040 --> 06:16:57.064
Here, and then still have to go through like, 10 years limited generation. Um, other than full export.

1345
Eva Wang TotalEnergies 06:17:00.364 --> 06:17:09.542
So the whole point is to eliminate upgrades here for the out GP customers, not to defer the upgrades.

1346
Regnier, Justin 06:17:10.412 --> 06:17:20.374
Well, and that's why I stepped in when Roger spoke that I think the entire idea is to eliminate upgrades where possible and maximize the hosting capacity that.

1347
Regnier, Justin 06:17:20.470 --> 06:17:41.556
Already has been paid for by rate. Paris is Brad articulated in last workshop. If you assume on every limited generation profile application, there will be a subsequent upgrade that is required. Um, negate at least some of the benefit. I don't know that the are taking the position that they think.

1348
Regnier, Justin 06:17:41.620 --> 06:17:54.604
But every limited generation profile application will be followed by a subsequent upgrade that cost is born by the repair. That seems a bit of an extreme position based on the record. But I don't want to put words in their mouth.

1349
Roger Salas SCE 06:17:55.564 --> 06:18:02.764
Yeah, I mean, I, I think that does get to be determined in my opinion, because the reality in general, I think is going to be that you can.

1350
Roger Salas SCE 06:18:02.792 --> 06:18:23.792
With 1, limited generation project per circuit, because, as we've shown before and LGB project essentially maximizes why you can put on that circuit. That's exactly essentially what what he's doing. And so, let me know, capacity left over for future projects, you know so if you have any.

1351
Roger Salas SCE 06:18:24.154 --> 06:18:45.064
That comes afterwards that is, you know, up to 1 megawatt and, you know, we cannot tell that, that any project that they have to curtail, we have to connect them and, you know, we'll see what happens, you know, that's my prediction. And I'm having, you know, nearly 15 years of condition experience, but.

1352
Roger Salas SCE 06:18:45.094 --> 06:18:53.162
I think that was going to happen is probably gonna take it off, blow it to his maximum value. Any enterprise is gonna come in and we'll have to re, upgrade.

1353
Sky Stanfield 06:18:53.972 --> 06:18:54.332
I think.

1354
Regnier, Justin 06:18:54.332 --> 06:18:54.572
Well.

1355
Regnier, Justin 06:18:56.374 --> 06:19:13.384
I would, I would point back to our last workshop discussion where we kind of all had consensus that the most likely outcome is that we're not going to run into future issues with the parting load that, that, uh, require a subsequent upgrade. So, I think.

1356
Regnier, Justin 06:19:14.706 --> 06:19:15.484
We don't know.

1357
Roger Salas SCE 06:19:15.904 --> 06:19:16.294
We don't know.

1358
Regnier, Justin 06:19:16.294 --> 06:19:35.464
We don't know what's going to happen with increased blood and electrification. There are a whole bunch of different variables that we just can't know about. So, I don't, I don't know if the are taking an official position that they think that I see I had handshake from Rogers. Maybe I don't even need to finish that but.

1359
Roger Salas SCE 06:19:36.184 --> 06:19:56.972
That's my my personal opinion, that position, John, my personal opinion, having done, you know, nearly 15 years of, you know, conditions customers like to go where there's no upgrades and any projects the only way to care. Right? There's any price less than 1 megawatt. Connect me. And they don't care whether they're or non and.

1360
Roger Salas SCE 06:19:56.978 --> 06:19:59.374
You know, we will have to connect them anyways 1 way or another.

1361
Younes, Amin 06:20:01.174 --> 06:20:05.912
That it phase 2 could change that. Right? That's my understanding. Phase. 2. this proceeding could.

1362
Roger Salas SCE 06:20:07.082 --> 06:20:12.124
Not for 1 megawatts and less then 1 megawatt less we're required to pay for the upgrades.

1363
Regnier, Justin 06:20:13.504 --> 06:20:15.992
That would be an proceeding that's outside of scope.

1364
Roger Salas SCE 06:20:16.292 --> 06:20:17.764
Yeah, W, the DNA proceeding, right?

1365
Younes, Amin 06:20:18.184 --> 06:20:19.834
My understanding of the scope of.

1366
Younes, Amin 06:20:20.104 --> 06:20:20.674
2, is that.

1367
Younes, Amin 06:20:23.524 --> 06:20:24.934
Allocation broadly.

1368
Roger Salas SCE 06:20:26.494 --> 06:20:27.184
I don't think enough.

1369
Sky Stanfield 06:20:28.294 --> 06:20:28.594
And that.

1370
Alex Mwaura PG&E 06:20:28.594 --> 06:20:29.104
Actually, come.

1371
Sky Stanfield 06:20:29.104 --> 06:20:43.504
From another statute, not just from the commission that the costs would be way and I think it's also important to remember that those upgrades directly have been very affordable as its own device letter just points out that raises the cost for a small amount. So.

1372
Sky Stanfield 06:20:43.510 --> 06:20:57.366
I don't think this is a big point of should be a big point of contention. Yeah, Jose can we? I think we're we only it's 230 and we haven't gotten direct proposal and I'm wondering if we should just move off of this.

1373
Aliaga-Caro, Jose 06:20:57.394 --> 06:21:04.624
Yes, uh, sky was just gonna, uh, recommend that. So it seems like, uh, regarding this.

1374
Aliaga-Caro, Jose 06:21:04.660 --> 06:21:23.196
Topic and the screens, we do need further discussions, uh, which are part of, uh, you know, the upcoming resolution uh, 5,230. so, uh, Cory, could you bring up, uh, presentation? Please, thank you.

1375
Sky Stanfield 06:21:32.464 --> 06:21:32.734
But.

1376
Aliaga-Caro, Jose 06:21:33.004 --> 06:21:34.234
go ahead 

1377
Sky Stanfield 06:21:35.134 --> 06:21:36.694
Can you move on to the next slide?

1378
Sky Stanfield 06:21:40.082 --> 06:21:59.552
All right, I'm going to try to move us through some of this fairly fast, because I think most of the basic points have been talked out. What I, what I set up in these. 1st slides is just sort of layout Narratively where I think we stand. Um, in terms of of what to help us get to what the core issues are.

1379
Sky Stanfield 06:21:59.764 --> 06:22:20.792
We've talked about most of this on here, we've already addressed that the permanent grid modification and future expansion of the grid are non specific issues per se. And I think the main thing that that there seems to be some agreement around is that the risk of the long term reduction is the primary sticking point.

1380
Sky Stanfield 06:22:20.824 --> 06:22:38.644
The potential emergency reconfiguration, which are curtailment, which could apply to other projects. I haven't heard concerns from any parties about that. Especially with the understanding they're going to be treated as other customers. So, next slide please.

1381
Sky Stanfield 06:22:43.114 --> 06:23:01.564
So, focusing in here, I think what we've heard from the utilities, in terms of the safety reliability issues that they had done that they think could trigger or could be triggered are largely going to come from reductions or changes in the load profile.

1382
Sky Stanfield 06:23:02.164 --> 06:23:22.744
They're quoting from the earlier slides that would be the most impactful grid condition and those could result in either expenses a voltage or thermal limits. The problem underlying all of this is that no data has been provided to characterize the likelihood that this would.

1383
Sky Stanfield 06:23:24.332 --> 06:23:43.954
Or how likely how often it would occur, or we're completely operating on basic assumptions that it won't happen often, but nobody has any grasp on the magnitude of how often it could potentially happen in the future. Similarly. If it did occur, we're also operating on a lack of data.

1384
Sky Stanfield 06:23:43.990 --> 06:24:05.134
About what the potential costs could be, if it did occur. So these 2, I think unknowns, which aren't necessarily which, to some extent, are always unknowable because they will always rely on speculation about future grid conditions, but potentially could be modeled out further to, to means point earlier, I think, are really driving.

1385
Sky Stanfield 06:24:05.164 --> 06:24:26.284
Where the difficulty is here, because what these come down to is that neither the ratepayers, nor the interconnection customer has ability to grasp what the risk is. And that makes financing a project difficult. And it also makes it difficult for the utilities and rape her advocates.

1386
Sky Stanfield 06:24:26.314 --> 06:24:47.434
Included to know what the potential impacts could be for repairs. If they were on the hub. I just wanted to put that basic data problem out there. Because I think that is what underlines all the all the discussion we're really having. And then from an applicant standpoint, applicants have little if any ability really to know.

1387
Sky Stanfield 06:24:48.004 --> 06:25:07.624
Whether the conditions will arrive the data problem and because they're entirely dependent on a factor that's out of basically everybody's hands, which is the, a hypothetical customer or customers on the grid, changing their behavior in a way that nobody can predict. So, next slide please.

1388
Sky Stanfield 06:25:12.632 --> 06:25:29.732
So, we're looking at with that sort of background what really been trying to do is think around well, how do we manage that risk and what is the right way to a portion that risk or mitigate or manage that risk? And whether it's.

1389
Sky Stanfield 06:25:30.154 --> 06:25:50.856
Fully on the, the customer fully on the right payer or some combination they're in. I think that that's the major sticking point. And this is really a summation of what we've already talked about. Utilities are proposing that minor upgrades or mitigations. They'd be willing to do, but for any longer term or a major of.

1390
Sky Stanfield 06:25:50.888 --> 06:26:12.034
That that would be on the shoulders of the introduction customer. Um, and that what that means for the interconnection customer, is that the only limitation on the risk is that they would not be reduced below the minimum, which translates to.

1391
Sky Stanfield 06:26:12.064 --> 06:26:33.184
Again, I'm sorry, if I'm being super simplified here, what it translates to is that the economics of the project potentially have to be such that any additional capacity you build on top of the is entirely profit, because they have no ability to absorb under.

1392
Sky Stanfield 06:26:33.214 --> 06:26:54.334
And the risk, the likelihood it would happen, or the potential costs for any upgrade, should they be required to do 1? So they're working on and this is somewhat simplified. But basically, the idea is that the economics would have to work out that the rate structures, or the procurement vehicles are structured. So that, anything above that.

1393
Sky Stanfield 06:26:54.338 --> 06:27:15.062
C. A. S. G is purely access profit and the project would have to already pencil out otherwise. So, my, I don't have any economic data to say whether that is the case. And as the, they don't know either. But I think that it is highly unlikely that that is.

1394
Sky Stanfield 06:27:16.054 --> 06:27:33.394
Um, I don't think the project economics are so wonderful, especially when it comes to batteries at this point that that's likely to incense a lot of projects to build capacity without having any guarantee that they could recover some additional profit from it. Next slide. Please.

1395
Sky Stanfield 06:27:37.082 --> 06:27:56.374
So, what I want to do with that sort of basic background, is I want to talk about what been trying to do, and where we've gotten to in our conversations with the development community. And this, of course, is where we need to invite lots of participation from the developers and other non party.

1396
Sky Stanfield 06:27:56.378 --> 06:28:17.524
And then put on the table a, I wouldn't call it yet on direct proposal, but an alternate approach that we've come up with to try because we haven't been successful in the 1st column. So, let's get to what we, we had a call with the, with some members of the development community.

1397
Sky Stanfield 06:28:17.530 --> 06:28:38.644
Have been participating in these calls yesterday to try to really talk about what I'm broadly calling our costs and it could be characterized either as a cap on what the upgrades would be or a cap on the amount of the project or the duration in which the project would be reduced. We can see both pros and cons to doing a.

1398
Sky Stanfield 06:28:38.706 --> 06:28:59.824
+, and I kind of lead those out on this slide. But the conclusion that we've come to is that because of all the different unknowns and variables that we have right now, both in terms of the basic data problems that we've already characterized, and the fact that every profile is different and.

1399
Sky Stanfield 06:28:59.854 --> 06:29:20.882
We have a sort of a still emerging market to provide the price signals around that time of use again, the chicken and egg problem. We weren't able to come to an approach that would enable us to arrive at a rational cap that could be applied in the terror as a generic application.

1400
Sky Stanfield 06:29:21.242 --> 06:29:42.124
Every single example, would would require a huge amount of customized modeling analysis on a project by project basis. Um, so that's, that's where I rec, landed at the end of the conversation about how to impose a cost. Not that developers aren't willing to absorb some of the risk meaning if they.

1401
Sky Stanfield 06:29:42.154 --> 06:30:03.244
Operate with some bounds around what the risk is, they could potentially make projects work, but what those bounds would have to be. We were stumped on how to actually get there, especially within the timeframe that we're working with. I want to pause there and make sure everyone's following. Why where I'm at with that and also open up the.

1402
Sky Stanfield 06:30:03.280 --> 06:30:24.394
Conversation with does do others have ideas on how we would get to a rational cap? Oh, and I guess I should say the idea with the cap again, whether it's an upgrade upgrade amount or a reduction cap is that we would be splitting splitting the sharing the risk. The risk would be some of the.

1403
Sky Stanfield 06:30:24.430 --> 06:30:45.574
This would be on the customer, the initial risk would be on the customer, but in the end, the rate pairs would still be on the hook to some extent. And again, that is unknowable based on the data gaps that we have. So, I'll pause to see if anybody has thoughts on that, or has other creative ideas.

1404
Sky Stanfield 06:30:45.578 --> 06:30:51.844
On how we would develop a rational approach to designing a cap.

1405
Roger Salas SCE 06:30:55.024 --> 06:31:13.354
Yesterday, my comments more about just no, no, no the proposal server, which is what we are allowed to do here. I mean, are we even allowed to put repairs in as part of the discussion here? I mean, I just don't know whether that's even borrowed. What's allowed here?

1406
Aliaga-Caro, Jose 06:31:14.014 --> 06:31:15.034
So, uh, Roger.

1407
Aliaga-Caro, Jose 06:31:15.244 --> 06:31:22.594
That would fall into phase 2, but right now we do need some sort of path forward to make this happen.

1408
Aliaga-Caro, Jose 06:31:23.822 --> 06:31:36.902
So, ultimately, you know, that would be determined into phase 2 of the proceeding. So, but we do need something to feed into phase 2.

1409
Roger Salas SCE 06:31:38.072 --> 06:31:44.792
So, just for me to understand what you're saying is that, you know, a proposal would proposals with.

1410
Roger Salas SCE 06:31:44.798 --> 06:32:02.284
Be developed standard under these work. Those proposals would then be sent over for phase 2 and phase 2 would then approve the proposal the proposal or maybe. Is that the sequence or or the wrong.

1411
Aliaga-Caro, Jose 06:32:02.734 --> 06:32:05.824
Uh, yes, that would be the sequence cause the advice letter.

1412
Aliaga-Caro, Jose 06:32:05.974 --> 06:32:27.094
Not do any, uh, rate making, uh, advice letters do not handle rate making issues, but, you know, these advice letters are feeding into phase 2 of the r170707. So, without any type of thing.

1413
Aliaga-Caro, Jose 06:32:27.124 --> 06:32:36.034
Information to discuss costs then there is no information for phase 2 to.

1414
Aliaga-Caro, Jose 06:32:40.384 --> 06:32:42.514
Not continue, but to, uh, you know.

1415
Aliaga-Caro, Jose 06:32:44.042 --> 06:32:46.712
You start up discussions.

1416
Sky Stanfield 06:32:48.752 --> 06:33:05.162
I think the other thing I'll say there is, I mean, maybe the, the intent with phase 2 was just discuss the cost of implementation of the, um, I don't think it's not exactly how it's characterized, but I'm going to be clear that from the beginning that we.

1417
Sky Stanfield 06:33:05.676 --> 06:33:26.106
We're trying to be practical here and I I believe that the commission will also allow us to be practical here. And what we have identified is that no project is going to go ahead if there's not some risk mitigation on way that they can mitigate. I don't know what the right way to exactly characterize. It is but have some certainty.

1418
Sky Stanfield 06:33:26.374 --> 06:33:47.462
And they might be able to bear some risk, but they need to know what that risk is. And ideally it probably needs to be kept in some now. Um, beyond, just the, that's what we're assuming. And if the commission wants to say, nope, then again, no benefit of that it seems unlikely to mean that the commission would.

1419
Sky Stanfield 06:33:47.556 --> 06:34:00.006
To throw up our hands in that way I don't speak for the commission, but as a, as a, you know, long term interview, I do think the commission probably wants us to be practical and that's what we're trying to grapple with.

1420
Sky Stanfield 06:34:13.234 --> 06:34:14.944
Justin, you waiting for me to call on, you.

1421
Aliaga-Caro, Jose 06:34:17.434 --> 06:34:18.572
Oh, go ahead.

1422
Regnier, Justin 06:34:20.254 --> 06:34:20.972
Um.

1423
Regnier, Justin 06:34:24.036 --> 06:34:27.336
Yes, I was waiting for it to be called on, um, the.

1424
Regnier, Justin 06:34:30.062 --> 06:34:50.732
Per discussion earlier today, it sounds as though the parameter that concerns a developer is risk of loss of revenue on 1 end and imposition of upgrades at a later point, or in position on the cost of upgrades at a later point.

1425
Regnier, Justin 06:34:51.846 --> 06:34:55.324
In prior conversations, um.

1426
Regnier, Justin 06:34:57.392 --> 06:35:15.034
And smarter working group, at least, there's been a discussion that the once the developer has developed the project having to go back and then pay for things is is very difficult to accountants. So it seems as though.

1427
Regnier, Justin 06:35:16.324 --> 06:35:37.444
Locking in the maximum exposure at the time of application would be beneficial to developers. Um, what that what seems to fall from that in my mind is rather than having a cap amount. Well, I guess the 3rd element.

1428
Regnier, Justin 06:35:37.450 --> 06:35:51.754
That right now, uh, business, as usual is that rate pairs pay for upgrades to allow interconnection agreement terms to be honored just as a matter of course.

1429
Regnier, Justin 06:35:54.274 --> 06:36:13.444
1 of the concerns that the have raised is paying an exorbitant amount of money for an upgrade that has minimal benefit to either the customer or the rate pair. Where all that leads. My simple brain. Is that rather than a cost cap on upgrades later.

1430
Regnier, Justin 06:36:14.524 --> 06:36:23.104
Um, we haven't established even there's a separate customer category where they'd have to pay for upgrades later.

1431
Regnier, Justin 06:36:25.594 --> 06:36:46.534
It may make sense to take a look at a threshold for upgrades that restore the original export values that some percentage loss of revenue to the developer because that front.

1432
Regnier, Justin 06:36:46.594 --> 06:37:07.654
All of the considerations to the time of interconnection, but also limits the rate pairs exposure to what would be turned by some as an imprudent investment. Um, let's I'm not sure any of that made sense but that's that's where my brain goes upon seeing.

1433
Regnier, Justin 06:37:07.744 --> 06:37:08.914
Dave shade of Scott.

1434
David Schiada 06:37:13.474 --> 06:37:33.036
Yeah, um, if I can get on video here. All right. Um, yeah, I was just trying to just conceptually understand how the cost cap, um, concept would work and it is it I get the time of interconnection. There would be, um, and I'll make up a number here.

1435
David Schiada 06:37:33.094 --> 06:37:38.642
Because I I do agree arriving at a rational cap is challenging. Um, but if you said.

1436
David Schiada 06:37:40.174 --> 06:38:01.264
Let's say, 50,000 dollars if if the, um, so the customer would interconnect and if down the road, let's say, load departed and then the utilities would, um, necessitate an upgrade to restore the introduction agreement. Um, uh, capacity value, then the utility would.

1437
David Schiada 06:38:01.922 --> 06:38:20.462
Pursue that upgrade and if it costs 60,000 dollars, then the customer would pay 50,000 the generator generator. And then 10,000 would be recovered by the utility through distribution rates from, from ratepayers is that the basic construct there or.

1438
Sky Stanfield 06:38:20.582 --> 06:38:22.412
So, there's 2 ways to do it. I think that's.

1439
Sky Stanfield 06:38:22.420 --> 06:38:43.446
A contract, if you assume the upgrade gets happens, the other way to do, it might be to compensate the customer or a reduction. So, the customer's modeled out what their expected revenue is of the life of the project and if they had to curtail to mitigate, there could be some again.

1440
Sky Stanfield 06:38:43.594 --> 06:39:04.712
On how much reduction they can have, but you don't have to say it as a compensation, but if there was a cap, it would lead to potentially the need to upgrade or to compensate the customer for the delta. It seems like there's 2 different ways of thinking about it either around saying the customer will be reduced and avoid the need for.

1441
Sky Stanfield 06:39:04.746 --> 06:39:25.836
The upgrade, but they need to be able to have some visibility or our, our belief based on without actual data, is that the getting all the way down to the is probably not going to be financially viable. So, something that would cap the amount of reduction in a way that makes the.

1442
Sky Stanfield 06:39:25.894 --> 06:39:41.344
Project still palatable. Now, I get there. Does that make sense, Dave in terms of just trying to say there's either way of thinking about it around around upgrades happening or, as Justin was characterizing just revenue reduction from the curtail.

1443
David Schiada 06:39:44.224 --> 06:40:05.344
Yeah, I think that's adds another layer of complexity, but I understand the concept the other 1. um, so it can maybe to Jose and Justin on the kind of what's in play here. I think Roger raised it as well for advice. Letters. Is it? And again, not agreeing to anything here, but just kind of conceptually, if there was this cost.

1444
David Schiada 06:40:05.374 --> 06:40:26.494
Cap approach is that something that would be like, in the advice letter? It would say, here's how the is proposed to be ordering paragraphs 15 and 16 in addition the workshop talked about a cost cap and That'll feed into phase. 2. is that kind of the thinking or just trying to understand.

1445
David Schiada 06:40:26.524 --> 06:40:28.472
Kind of what what's in play here so.

1446
Aliaga-Caro, Jose 06:40:29.972 --> 06:40:47.582
So, uh, that is my thinking is speaking that is by thinking, uh, uh, Dave, that, you know, items within the advice letters are daily, uh, or clearly delineated between what's in.

1447
Aliaga-Caro, Jose 06:40:48.034 --> 06:40:54.482
What can be approved in the advice letters and then, you know.

1448
Aliaga-Caro, Jose 06:40:56.110 --> 06:41:16.984
Another section for phase 2, this was proposed on how this could be implemented and therefore, now, for phase 2, we have a, you know, uh, you know, we have something to kick off and start, you know.

1449
Aliaga-Caro, Jose 06:41:17.286 --> 06:41:19.266
Getting down to the logistics.

1450
David Schiada 06:41:20.346 --> 06:41:22.714
Okay all right. Thanks.

1451
Aliaga-Caro, Jose 06:41:22.714 --> 06:41:35.404
I haven't answered that. I had a, I guess a general question in terms of cost sharing. I'm wondering what benefits would be.

1452
Aliaga-Caro, Jose 06:41:37.742 --> 06:41:57.962
In there for rate pairs for that particular circuit, for example, you know, and it's been a while since I've been involved in data and the whole distribution planning process but, you know, the utilities, I remember, they prioritize their upgrades.

1453
Aliaga-Caro, Jose 06:41:58.174 --> 06:41:59.674
Or, or or their.

1454
Aliaga-Caro, Jose 06:42:01.386 --> 06:42:19.356
And I'm wondering whether let's say 1 circuit gets impact, has that LGB customer, low drops and this cost cap cost sharing mechanism comes into play.

1455
Aliaga-Caro, Jose 06:42:22.324 --> 06:42:29.524
With that, and let's say originally in the distribution planning process, let's say that was.

1456
Aliaga-Caro, Jose 06:42:30.694 --> 06:42:51.722
On the list, but now, because, you know, uh, developer is partly paying for it, it would it come up in the, you know, from being 10th on the list because it's being now paid for partly by a developer.

1457
Aliaga-Caro, Jose 06:42:51.812 --> 06:43:03.482
It would come out too, like, let's say, number 2 on the list of work to be performed, you know, would that be, uh, you know, would that be beneficial to rate.

1458
Roger Salas SCE 06:43:10.052 --> 06:43:26.882
And also, it's a little bit difficult to understand the scenario there. What I would say though, is that that most of the projects that are going through the process are because we have very highly loaded systems. So we.

1459
Roger Salas SCE 06:43:26.978 --> 06:43:47.462
I want to have a situation where a project is under the process, because we are doing a system upgrades for capacity needs and have this condition where, you know, you probably won't even need an for that project because you have so much load. You probably have last month.

1460
Roger Salas SCE 06:43:48.544 --> 06:44:02.284
You know, generation capacity, so you probably don't even need to apply a project. But nevertheless, if you did, I, I don't think I don't think you have both conditions at the same time. If if that's what you're referring.

1461
Aliaga-Caro, Jose 06:44:06.094 --> 06:44:09.484
Okay, thank you. I think it that may have answered my question.

1462
Sky Stanfield 06:44:23.166 --> 06:44:24.816
Okay, so, um.

1463
Sky Stanfield 06:44:26.224 --> 06:44:30.694
I guess I'm gonna leave that there unless there's have additional comments that this is.

1464
Sky Stanfield 06:44:32.944 --> 06:44:52.982
General confusion conclusion is that developers overall would be willing to bear some risk for the, for the expected return as we discussed. But to determine that they have to be able to understand what the magnitude of the risk is. And or, and ideally how it.

1465
Sky Stanfield 06:44:53.016 --> 06:45:11.224
It's too high, but we can't we just didn't feel equipped to figure out how we get to that, especially because it's going to be a bit of a customized analysis under the current the current set of unknowns that we have. Um.

1466
Sky Stanfield 06:45:13.114 --> 06:45:33.722
The other thing, just to speak to the ratepayer or the phases, and the repair impacts discussion I think that it's really important to remember the data gaps here and that we are talking about a hypothetical risk that the utility is as indicated has never happened with current interconnection scenarios.

1467
Sky Stanfield 06:45:33.934 --> 06:45:37.264
Could potentially be more likely with that we still don't have data.

1468
Roger Salas SCE 06:45:37.264 --> 06:45:37.624
To work.

1469
Sky Stanfield 06:45:37.684 --> 06:45:54.634
And and is unlikely to occur in the future. So it's not like we're talking about actual costs necessarily that will arrive. We're talking about a hypothetical risk management on everybody's side. So, with that.

1470
Sky Stanfield 06:45:55.030 --> 06:46:15.424
Less people have additional comments or thoughts about how to design a cap of some sort of again, Eva upgrade cost cap or revenue loss cap. I was going to go into another sort of different approach that Iraq was thinking about potentially putting on the table.

1471
Sky Stanfield 06:46:17.256 --> 06:46:18.724
With that next line.

1472
Sky Stanfield 06:46:23.314 --> 06:46:41.554
So, because the way we've been thinking about this is around this, unlikely to ever occur. But if it did occur could be expensive, I guess, is the way to characterize it issue what? And the inability or the.

1473
Sky Stanfield 06:46:41.582 --> 06:47:02.492
Challenge at least I'm not going to say it's impossible. Capping it in another way is we were thinking around what about a compromise that still would would have repairs, carry the risk. But with understanding that the risk is even further reduced.

1474
Sky Stanfield 06:47:02.944 --> 06:47:23.854
So that's what, this what I'm going to sort of lay out as an idea for this purely for workshop discussion at this stage. So, 1 of the elements that we've, everyone's agreed that the issue here is load reductions. And I think the question is, is that risk of load reduction.

1475
Sky Stanfield 06:47:24.514 --> 06:47:31.144
Spread equally across all feeders. Is it possible? Or would it be possible for us to.

1476
Sky Stanfield 06:47:32.674 --> 06:47:53.434
Identify feeders where that risk is higher, um, and limit the applicability of the, during the test or interim period, at least, um, to not be able to propose an project on theaters where that risk is high. Um, again, we don't have any character.

1477
Sky Stanfield 06:47:53.470 --> 06:48:14.616
Position of the basic risk at this point. But if there are feeders where the risk of a load reduction is higher, that would be a way of a different way of thinking about this and mitigating the risk. And what we were thinking is that the biggest risk is probably.

1478
Sky Stanfield 06:48:15.184 --> 06:48:35.764
In the large customer disappearing, or a couple of large customers disappearing that's going to significantly reduce the load and potentially would introduce, you know, thermal equipment overload if you allow the scenarios to go forward. So that and we know already through.

1479
Sky Stanfield 06:48:35.852 --> 06:48:56.732
The application of the 1515 rule in the we actually already identified the feeders that meet either aspect of the 1515. that data is redacted from the, from the maps at this point. Um, whether the 1515%, a single customer being.

1480
Sky Stanfield 06:48:57.124 --> 06:49:18.036
Is the right metric of those higher risk feeders? I don't know. It's it's the same problem as afford. How do you get to that magic number? But I thought it was an idea that was worth exploring and putting out there both for the utilities to weigh in on on. The basic question of is this for, is higher on some Peters and other and if so.

1481
Sky Stanfield 06:49:18.094 --> 06:49:33.062
How would we characterize which Peter's the risk is higher on? Maybe that's the the 1st place to start the discussion. And then we could get into the details of how you would do that. If that ended up making sense.

1482
Yi Li SDG&E 06:49:39.936 --> 06:49:54.756
Scott sorry before digest this kind of making any technical signs at all, like mm, hmm. In the scenario here if say, there's a magical way that developers can decide which feeders has a lower risk versus which 1 has a higher risk and.

1483
Sky Stanfield 06:49:54.756 --> 06:49:56.044
Would it be too bad for.

1484
Sky Stanfield 06:49:56.164 --> 06:50:03.934
To be clear, it would be, we have to define them in advance. It would probably be the utilities identifying them in advance.

1485
Yi Li SDG&E 06:50:04.564 --> 06:50:16.264
Yeah, no forget about that part. I'm talking about the actual applicant, right? Whoever decides to use so, stays the applicant developer decides to some for the project.

1486
Yi Li SDG&E 06:50:17.288 --> 06:50:31.232
And based on the assumption characteristics low and the developers, nice enough financial incentive board a project. Are you saying that, that lower risk is still bearable by the ratepayers? Not the developer themselves.

1487
Sky Stanfield 06:50:31.742 --> 06:50:37.952
Yes, that's what I'm proposing. And again, with the understanding that I'm open to the repairs.

1488
Sky Stanfield 06:50:38.764 --> 06:50:39.664
We haven't been able to do.

1489
Yi Li SDG&E 06:50:39.814 --> 06:50:41.764
A repair, I'm feeling the pan.

1490
Sky Stanfield 06:50:41.974 --> 06:50:59.584
Yeah, I'm trying I'm trying out a different approach because of the challenges of the of the other approach. Um, and again I just, you know, and the idea behind this again is that we think it is pretty unlikely this is going to happen overall. But again, we don't have great that on that. We know that.

1491
Sky Stanfield 06:50:59.590 --> 06:51:11.134
It hasn't happened in the past, and we know that we expect a system wide base, a significant load growth from electrification on each node may or may, or may not arise.

1492
Roger Salas SCE 06:51:12.696 --> 06:51:20.464
Okay, let me ask a little bit broader question and see, I think goes along with this topic here. Um, obviously.

1493
Roger Salas SCE 06:51:20.974 --> 06:51:41.196
You know, for us as well, I mean, we'd want to impose more risk to the applicant than the necessary. I mean, for us, it would be good if the customer goes and submits an application or whatever kind of what full knowledge of what the risk is. And based on that, they can determine they want to proceed or not proceed. Right? So, I guess to that end.

1494
Roger Salas SCE 06:51:42.154 --> 06:52:02.734
What what what what, what do you think or maybe some developers here are here what would they need from us in order to sort of like, you know, evaluate whether or not they can take on these risk like, what, what would they need to know if you were to just, you know, throw things out there.

1495
Roger Salas SCE 06:52:03.038 --> 06:52:15.212
You know, and say, well, well, if I knew these facts about the circuit or the station or whatever is then I have enough information for me to know that I can take the risk or not take that risk.

1496
Sky Stanfield 06:52:16.082 --> 06:52:23.972
Yeah, I, I want to let the developers weigh in on that. What I heard is based on the same way. I identify the data needs.

1497
Sky Stanfield 06:52:24.274 --> 06:52:45.334
Is the risk, but the overall risk is unknown, but the more the bigger driving factor is, what is the magnitude of the risk? Um, is it capped? Essentially, if if there's a risk that is on that, we don't know how often it is, although we, we believe it is unlikely, but that could wipe the entire value of the.

1498
Sky Stanfield 06:52:45.340 --> 06:53:06.484
Project or below the additional capacity that was added clean. That that seemed like a non starter from what we were talking about. So, they I think that the primary thing is being able to know what how much you could be reduced in the end. I think or how much you would have to pay for.

1499
Sky Stanfield 06:53:06.516 --> 06:53:07.686
It's in the in.

1500
Roger Salas SCE 06:53:08.074 --> 06:53:27.544
Yeah, and I think that's that's a tough 1 to to determine but I think what I'm saying is like, is there information that we could provide as a utilities for them for the customer to sort of make a a almost say, calculated evaluation or not.

1501
Roger Salas SCE 06:53:28.774 --> 06:53:34.384
Is this is the information that we could provide that would allow them to say, you know what I'm willing to take this risk.

1502
Roger Salas SCE 06:53:39.366 --> 06:53:40.624
Sorry, I got you on mute.

1503
Sky Stanfield 06:53:42.876 --> 06:53:55.654
I was saying I can speak for developers. Um, I haven't I, it does seem to me, like, any sort of just unlimited risk is hard going to be hard to finance. But again, we need to hear from the developers that they think that they could finance that.

1504
Roger Salas SCE 06:54:01.204 --> 06:54:19.742
Discuss for me, I think that's where, where I would be interested in knowing. I mean, if if if stakeholders saying look if I know X Y, and C and based on that, I can determine whether or not it's it's it's, uh, it's it's the risk is slow. Based on my risk tolerance, or maybe.

1505
Roger Salas SCE 06:54:20.582 --> 06:54:26.372
Then then we should be looking as to whether or not, we can provide X. Y Z. right? Um.

1506
Sky Stanfield 06:54:26.402 --> 06:54:34.622
Yeah, I mean, I think the other question is here is this insurable you know, like, those are all the things, but I just don't have that that insight to offer.

1507
Yi Li SDG&E 06:54:39.034 --> 06:54:58.714
Yeah, I agree with Roger, this is really challenge for us to even comment on right? Cause the last workshop well, we've been hearing is that the issue with with is with a limited risk and state relatives are willing to take on some risk, but looking at this proposal, without, you know, getting to the detail. It's saying that even when the risk is low.

1508
Yi Li SDG&E 06:54:59.612 --> 06:55:04.622
Are still unwilling to take any risk and want to pass on to the customer. That's not my.

1509
Sky Stanfield 06:55:04.652 --> 06:55:20.432
It's saying that we don't know how to define how to limit it. I was very clear that we arrived at this not because we don't developers aren't willing to take on the risk is that we couldn't come up with the way to define it. That's why I asked you for your input. So don't I understand this is difficult. I'm not disagreeing with.

1510
Sky Stanfield 06:55:20.440 --> 06:55:30.424
You on that, but don't characterize it as people being unwilling to. It's a question of how would we do it and at least Iraq nor anybody here seems to come up with that approach.

1511
Frances Cleveland 06:55:44.582 --> 06:56:04.142
I guess I, I would like to understand a little bit more by what you would do or what's the, the risk, uh, you know, if you identify a particular level of risk, um, or a particular circuit, what would you.

1512
Frances Cleveland 06:56:04.148 --> 06:56:23.732
You expect to be done with that risk knowledge because it ultimately would result in revenue stream stream what you know, it's not it's not just the likelihood it's the impact.

1513
Roger Salas SCE 06:56:25.324 --> 06:56:46.444
Yeah, I mean, I think just again, you know, speaking out loud here and just this basic concept, right it's like, you know, big picture circuits. Right? You know, once it has a whole bunch of hundreds or small customers, residential, small commercial, uh.

1514
Roger Salas SCE 06:56:46.476 --> 06:57:07.566
1 of those customers can close and move somewhere else. Probably not an issue, right? Like, they're so small that is essentially a 11 customer closeness, almost non material for, for these purposes where you have a circuit where you have a pretty large customer.

1515
Roger Salas SCE 06:57:08.314 --> 06:57:28.714
And if that customer goes, so maybe 1 or maybe, you know, a few, you know, 2 or 3, that are dominating the, the capacity of the circuit then 1 of them going will have a significant outcome. So, you know, you have 2 scenarios there where, in 1, where you have the.

1516
Roger Salas SCE 06:57:29.014 --> 06:57:49.802
So, distributor among customers, that is probably very, extremely low risk that, that, you know, the will require to be, uh, uh, reduce, um, compared to the 2nd scenario. But, you know, maybe we can find what that is, you know, and also.

1517
Roger Salas SCE 06:57:49.898 --> 06:57:57.124
Asking earlier, like, what is the customer need to know to evaluate the risk between those 2 scenarios or something in between.

1518
Regnier, Justin 06:57:59.284 --> 06:58:19.354
So this guy's point about insurability, um, the customer doing a deterministic analysis may, or may not qualify for bank ability or insurability? Um, I guess I'd like to understand 1 thing here on the, it sounds like feeders.

1519
Regnier, Justin 06:58:20.164 --> 06:58:27.394
Where you've got a customer that's greater than 15 of it's all load are already omitted from the is that right?

1520
Sky Stanfield 06:58:27.426 --> 06:58:33.096
Yeah, the I see, Roger go ahead. You can characterize it.

1521
Roger Salas SCE 06:58:33.664 --> 06:58:40.654
I know the IC values are there, it says the, the certain values are redacted.

1522
Roger Salas SCE 06:58:40.712 --> 06:58:50.014
Like, the operational flexibility value is redacted. Um, the low profiles are rejected, but the IC values are still there.

1523
Regnier, Justin 06:58:51.242 --> 06:58:53.704
Okay, so.

1524
Regnier, Justin 06:58:55.414 --> 06:59:15.876
What seems to be coming into focus is the most likely customer, which should be an M, export customer greater than 1 megawatt on a feeder. That's got a high as as, um, Alex is saying, a high delta between Max.

1525
Regnier, Justin 06:59:15.934 --> 06:59:37.052
Minimum load and sounds like what sky is saying is to mitigate risk. We'd restrict the initial roll out of this to customers where the feeder load isn't dominated by any single customer, or.

1526
Regnier, Justin 06:59:37.562 --> 06:59:42.902
Any group of large customers or or whatever threshold we've got there and that that that.

1527
Regnier, Justin 06:59:44.494 --> 07:00:01.144
Seems to make sense absent feedback from other folks. There's, there's a persistent discussion here about having the interconnection customer beyond the hook for a later upgrade.

1528
Regnier, Justin 07:00:02.974 --> 07:00:22.444
I think we've discussed that a, a number of times in this meeting that, you know, there's no record for a different customer class and a different treatment of where the upgrade costs would be allocated. If it's necessary to.

1529
Regnier, Justin 07:00:23.590 --> 07:00:28.926
At the terms of the interconnection agreement back on track as it were.

1530
Regnier, Justin 07:00:31.234 --> 07:00:42.844
Um, so failing that, maybe we can take later a billing of the interconnection customer for an upgrade. Um.

1531
Regnier, Justin 07:00:44.946 --> 07:00:46.596
Off as a concern, I mean.

1532
Regnier, Justin 07:00:49.806 --> 07:01:04.776
So the kind of the, the conceptual framework that pops into my mind is if we look at that, that targeted customer right? So that over 1 megawatt M, export on a high Delta circuit with no big loads or no big single customer loads, right?

1533
Regnier, Justin 07:01:06.304 --> 07:01:27.034
And we look at the amount of revenue that they can get under static export versus limited generation export, and just pulling a number out of error say that they can get 30% greater revenue, um, in excess of the.

1534
Regnier, Justin 07:01:27.092 --> 07:01:29.192
Additional cost for their hardware.

1535
Regnier, Justin 07:01:31.682 --> 07:01:52.412
Um, you know, maybe it's if you split it right down the middle, it's if, if their revenue realized by taking option drops by more than 15, that triggers the requirement of, uh, you know, getting the circuit upgrade into the planning.

1536
Regnier, Justin 07:01:52.444 --> 07:02:10.864
That may be a framework that keeps us from spending a whole lot of money on upgrades, but the rate parents have to pay for, for a tiny amount of generation. I see. Sky may or may not intend to be neutral. But she is.

1537
Sky Stanfield 07:02:11.402 --> 07:02:12.392
I know I'm on mute. I was.

1538
Sky Stanfield 07:02:13.776 --> 07:02:15.366
Testing with Yogi. Sorry.

1539
Regnier, Justin 07:02:15.876 --> 07:02:18.096
All right no worries, no worries. Um.

1540
Regnier, Justin 07:02:21.154 --> 07:02:23.674
I mean, that's that's where my brain goes, and I don't know if the.

1541
Regnier, Justin 07:02:26.734 --> 07:02:47.314
If that is a framework for going forward, if if we've got consensus that are most likely interconnection customer would match those parameters. Um, and that setting a threshold of reduced revenue for.

1542
Regnier, Justin 07:02:47.408 --> 07:03:08.132
System upgrades is something that helps with bank ability and with insurability because I hear the frustration from Roger that, you know, just tell us what data you need to quantify the risk to satisfy your lenders and we'll get you that technical data and you can, you can quantify it, but I'm not sure that that will satisfy the lenders. I think what.

1543
Regnier, Justin 07:03:08.556 --> 07:03:20.732
Would make a bankable as an assurance that, you know, if you lose more than X amount of revenue, then you're gonna be in the queue for an upgrade. And that upgrades not going to be on your done.

1544
Sky Stanfield 07:03:23.702 --> 07:03:29.702
Just like for 1 comment um, I think that I don't think that.

1545
Sky Stanfield 07:03:29.794 --> 07:03:50.584
We should limit the idea of who the optimal customer is to this to, behind the meter. Only I think what what you're likely to see enabled through this and is is front of the meter systems with solar plus storage that are really capturing ultimately locational.

1546
Sky Stanfield 07:03:51.004 --> 07:04:12.004
Saying and those differentials now, whether those will be projects interconnected through rule 21 at this point. It's a question. I think that what we're trying to get to is, I think there's a smaller pool of customers doing this behind the meter. And the potential real benefits that we were talking about from the grid might come from actual front of the media.

1547
Sky Stanfield 07:04:12.036 --> 07:04:33.154
And maybe even like, the new community solar program, for example, which requires storage, maybe customers, depending on how their infrastructure there can capture some of this, I don't know enough about all those different procurement programs that exist today, or might be developed in the future. That's again. Part of what we're trying to chicken today care, but I don't think that we should assume that this is that.

1548
Sky Stanfield 07:04:33.184 --> 07:04:37.864
But if it is actually, our greatest opportunity comes from behind the meat of the customers.

1549
Regnier, Justin 07:04:39.482 --> 07:04:52.292
I didn't mean to assert that, uh, just within the confines of real 21, but that would seem the most likely candidate for exercising limited generation profile again within the confines of real time. So that's all we.

1550
Sky Stanfield 07:04:52.712 --> 07:04:54.302
Yeah, I mean, there's lots of ways the commissions.

1551
Sky Stanfield 07:04:54.306 --> 07:05:06.482
Structure programs that stay within rule 21, that that incentivize procurement on more of a time of use basis so to speak. But those aren't all on the table.

1552
Sky Stanfield 07:05:10.652 --> 07:05:13.292
I mean, I mean, is it, I mean, or a man, I don't want to keep.

1553
Younes, Amin 07:05:13.292 --> 07:05:13.684
But.

1554
Sky Stanfield 07:05:13.684 --> 07:05:14.944
Your name sorry?

1555
Younes, Amin 07:05:15.572 --> 07:05:16.024
Thank you.

1556
Sky Stanfield 07:05:16.024 --> 07:05:16.354
Me.

1557
Younes, Amin 07:05:17.524 --> 07:05:29.552
I just want to go back kind of to this conversation about risk level. Um, so it kind of seems like if, if a project's getting built and say you're building 20% in excess.

1558
Younes, Amin 07:05:29.582 --> 07:05:49.952
The value I understand that that Delta is entitled that Delta is 100% at risk, but the project itself is only, I forgot what I said, 20% or 10%. Um, you know, the relative risk downside risk of the project is is not necessarily that unlimited. Um.

1559
Younes, Amin 07:05:50.914 --> 07:06:11.704
And so, it seems like, I guess it seems like even if, um, projects had the risk of being permanently curtailed to the value, which we all agree is a small probability, but could be bearing impact could be high impact for some projects. But it might be that we actually do see interconnections. Um, it could very well be that.

1560
Younes, Amin 07:06:11.914 --> 07:06:33.004
Particularly with now, I can't, I guess this this could be utilized by them larger than 1 megawatt. So potentially with those types of installations, which get, you know, have a pretty short payback period potentially that those projects wouldn't see that much risk and using the.

1561
Younes, Amin 07:06:33.756 --> 07:06:53.974
And so we would see some projects like that coming online, uh, and then once that starts happening, then we can start gathering data and potentially say yeah. Oh, I mean, and actually, we wouldn't even necessarily necessarily need to do anything. Well, no, I guess, sorry at that point, we could reconsider and say, you know, that, that curtailment is going to go away. Uh.

1562
Younes, Amin 07:06:54.184 --> 07:07:15.302
That that rate parents would pay for the upgrade, because it's so rare, uh, you know, that it's 1 in a 1Million. Um, and then that that could lead to, to kind of more projects and long term I guess just to, to reiterate that cause I kind of wandered around a little bit. But the point is that what we might see customers using, and if we do, then we can gather the data and we don't need to have.

1563
Younes, Amin 07:07:15.332 --> 07:07:19.022
Have this risk born by rate pairs necessarily immediately.

1564
Sky Stanfield 07:07:20.402 --> 07:07:35.462
Yeah, it's it's, I certainly can't say it's not possible that will happen, you know, that if there's enough additional revenue that can be captured and the price signals exists that somebody could absorb that risk.

1565
Sky Stanfield 07:07:36.604 --> 07:07:46.624
It's, it's possible, it's a lot of work to get there. If that doesn't happen is the, the challenge and my sense when why we're kind of.

1566
Sky Stanfield 07:07:48.214 --> 07:08:08.286
Leaning on the face is because we think it's gonna be unlikely and that the overall cost, and I want to, you know, I don't want to sound like I'm, you know, using the rate base here. What I, my intent is, is that the rate base has this broad layer of security, right? Because it's spread across all the customers. Whereas the way that this works is, it has to be on a single customer and that's that.

1567
Sky Stanfield 07:08:09.064 --> 07:08:30.004
But the only way that it's reasonable to use the rate base is if it is truly unlikely. And, and therefore, it's, you know, in the ring base is used like this as an sort of an insurance policy of its own and a lot of cases. And whether we agree, and what the economics of it and are justified is part of our challenge.

1568
Sky Stanfield 07:08:30.062 --> 07:08:51.182
But I do think that that that if we put the risk on the developers, it seems logical that we're going to increase the costs of financing 1 way, or the other and maybe we don't need to do that. Because it's we're going to really arise is the problem, but we could, as you said, I mean, we could go.

1569
Sky Stanfield 07:08:51.214 --> 07:09:12.334
And design a whole program with the hope that the economics work out for a developer to absorb all the risk. My guide is that that's probably not where the market is right now, and it could be in 5 years, and when we finally do better pricing and so on. But my guess is that that's not going to give us a lot about that.

1570
Sky Stanfield 07:09:12.394 --> 07:09:15.606
My guess, but not based on any, any.

1571
Younes, Amin 07:09:17.256 --> 07:09:29.824
Yeah, I guess adding to that, I mean, we could also set in, in addition to the data collecting another piece of data collecting could be monitoring how many systems come online and revisiting in a year or 2 if we don't see any systems at all we could go back and look at this again.

1572
Sky Stanfield 07:09:30.634 --> 07:09:33.484
Yep, that's when we were doing it or or we can get some data on.

1573
Sky Stanfield 07:09:33.516 --> 07:09:54.606
Some actual projects and see how they perform and go back and revisit it if it raises, because it's a which 1 do you want to shift it to? And how strongly do you want it to happen? I think is the question in a timeframe. That's reasonable. That's the dilemma. Why don't we go into the next slide? What I did oh, actually, just go ahead and go on.

1574
Sky Stanfield 07:09:54.638 --> 07:10:02.344
I don't think the not following slide. Please next slide. There we go. Um.

1575
Sky Stanfield 07:10:03.124 --> 07:10:24.184
What I did again, these were kind of just throwing ideas on the table, as I did think regardless of whether we do this approach or another approach we have to, we haven't really defined. I mean, to your particular point, in the beginning, what data would we need to figure out the risk better? Um, and then on the next.

1576
Sky Stanfield 07:10:24.784 --> 07:10:45.392
Identify so we have, what data would we need even to make the current decision if we were making going to make it with an a more informed way and then the next slide gets into if we're going to do some sort of pilot, whether it's piloting it with with Frank paragraph, develop a risk or some combination there in what data do we need to collector? And our pilot would actually.

1577
Sky Stanfield 07:10:45.424 --> 07:11:02.552
Inform what we would do going forward because if nothing happens either, no upgrades are required and the thing or no developer builds a project under the other scenario. What how do we move ahead? Because we might just be right back where we started.

1578
Sky Stanfield 07:11:06.334 --> 07:11:15.844
And I, I admit that lack some of the, I feel like the skills to really think about exactly how we would nail these things down in a more certain way with the right.

1579
Aliaga-Caro, Jose 07:11:47.614 --> 07:12:06.994
So, Scott, I would say, so, uh, I'm just trying this idea out there. Um, I don't know if this fits into data or not, but 1 data point may be is an upgrade is needed, you know, the cost of that upgrade uh.

1580
Aliaga-Caro, Jose 07:12:07.322 --> 07:12:23.374
You know, specifically, if it's shared if the cost is shared by ratepayers, um, I do not know if you know what I mean? Uh, depending on how the utilities study, the various screens.

1581
Aliaga-Caro, Jose 07:12:25.510 --> 07:12:46.654
If they study it, let's say, at the highest value, which is, you know, which would be the highest value that they would need to bring it up to, uh, you know, with any medication option, assuming that just theoretically or, you know, I'm thinking what.

1582
Aliaga-Caro, Jose 07:12:46.684 --> 07:13:07.802
There they could identify a cost outright or estimate a cost saying that, well, you know, it's not going to cost you anything because you're staying within the for upgrades. But in order to assuming you were.

1583
Aliaga-Caro, Jose 07:13:07.806 --> 07:13:28.952
To export at the highest, uh, value upgrades would have cost you X amount of dollars. So let's say if those X amount of dollars, and I'm just throwing figures out here are.

1584
Aliaga-Caro, Jose 07:13:29.254 --> 07:13:50.104
Uh, if if the commission where to adopt, and so, like, cost sharing mechanism, you know, if those X amount of dollars are very small, let's say only 10,000 then rate pairs would bear. Let's say 50, 50 is throwing it out there.

1585
Aliaga-Caro, Jose 07:13:50.194 --> 07:14:08.134
The higher they go, then rate pairs would bear less because now the risk is higher, uh, for them to be, you know, on the hook for in costs. So, I'm just throwing that idea out there, you know, something to play around with.

1586
Sky Stanfield 07:14:13.686 --> 07:14:32.106
So, you know, we're thinking about this is using the with where we're not doing a customized study of what the and it again, it depends on the magnitude of the load. What the actual load loss would be. That would what upgrade cost would be. Right? So, there's a lot of variables.

1587
Sky Stanfield 07:14:32.434 --> 07:14:53.552
That make it again, this is why I went back to say, we really tried to work out what was the frame of cost cap of some sort, or cost share as you're describing it. And I, and we lack the ability to figure out how we do it. In a quasi generic fashion, um, partly because we don't know what the.

1588
Sky Stanfield 07:14:53.582 --> 07:15:14.672
Upgrade would cost, and we don't know where it would be triggered and we don't know how often it would be triggered. So, if we had 100 projects that went ahead in the next 2 years, we don't know if 1 or all 100 would trigger an upgrade. And then we don't know, for each of those upgrades what they would cost, which means we're back to the point where.

1589
Sky Stanfield 07:15:14.734 --> 07:15:35.824
The repair, or the developer has certainty, could we get closer to a comfort level of the, the risk that it will occur? Yes. That's the where I think that the utilities have provided historical data and had some good modeling on load growth. We'd be able to get to a better clarity around is this.

1590
Sky Stanfield 07:15:35.860 --> 07:15:51.874
Likely to happen at all, but I don't know how we get to a greater clarity, and we might be able to get the utilities to say, here's the highest cost separated that could be happened on all of our feeders and extrapolate from that that's sort of my questions here is, would that data really tell us something that would help us move forward?

1591
Roger Salas SCE 07:15:54.994 --> 07:16:15.334
I mean, I I think 1 thing is whether or not you can do the analysis back to justin's point, whether, or not others would accept that analysis. I mean, if you, I think if you're just looking at it from the purely analytical point of view, um, you know, 1 would argue that, you know, if you had certain information.

1592
Roger Salas SCE 07:16:15.366 --> 07:16:36.456
You can probably perform a pretty good evaluation to determine whether you want to take the risk on that. For instance, you know, you know, contingent on 1515 and whether or not. We can even provide this information or not just throwing things out things like, hey, how many how many large customers do you have any circuit? You know, just how many customers greater than 2.

1593
Roger Salas SCE 07:16:36.516 --> 07:16:57.634
What do you have on the circuit? As an example what type of customers are they are very, you know, are they large customers do this type of these type of customers? You know, then that may give someone, um, relatively good information as to, like, Ah, this type of customers are pretty stable. Uh, no. Or we don't even have any of these type of.

1594
Roger Salas SCE 07:16:57.664 --> 07:17:18.724
Customers in the circuit, and therefore it's likely that that, um, that any 1 customer going away is gonna create a problem um, things like company, you know, I'm just throwing things out, like, how many customers you have in the circuit you know maybe what is their relative size, you know, uh, all of those customers, things like that.

1595
Roger Salas SCE 07:17:19.202 --> 07:17:39.842
Again, not even sure that we can provide. This is throwing, you know, you know, from the perspective of, like, the 1515 rule, like confidentiality. But that's what I was asking. Like, what what what what our developers need to feel comfortable on taking this additional risk just like we provide, you know, other maps you provide information.

1596
Roger Salas SCE 07:17:40.294 --> 07:18:01.024
Amount of current generation, you know, uh, you know, type of, you know, other other information on the maps. Well, we will do that for them to take, uh, take all this information and determine whether they want to take the risk to interconnect the project or the location. So, if we knew what that information was, then we could think about, you know, whether.

1597
Roger Salas SCE 07:18:01.116 --> 07:18:04.446
We can provide a such that they could determine whether or not they can think of it.

1598
Eva Wang TotalEnergies 07:18:07.504 --> 07:18:10.742
Like, most developers, like, we are pretty predictable.

1599
Roger Salas SCE 07:18:15.604 --> 07:18:15.874
A.

1600
Jacob Willman (Consultant) 07:18:17.194 --> 07:18:17.644
This is.

1601
Jacob Willman (Consultant) 07:18:18.036 --> 07:18:21.696
Jacob woman from it if you could just speak up into your Mike please.

1602
Eva Wang TotalEnergies 07:18:24.902 --> 07:18:26.254
What can you hear me?

1603
Sky Stanfield 07:18:27.454 --> 07:18:28.142
Yeah.

1604
Jacob Willman (Consultant) 07:18:28.354 --> 07:18:29.732
Yes, that's that's better. Thank you.

1605
Eva Wang TotalEnergies 07:18:31.322 --> 07:18:33.812
For some reason my audio is weird.

1606
Eva Wang TotalEnergies 07:18:35.374 --> 07:18:44.792
I'm saying, like, most developers, we're, we're a pretty big developer, but most developers don't really have, unless they're intuitive.

1607
Eva Wang TotalEnergies 07:18:45.334 --> 07:19:05.944
But we're talking about customers, right? They don't really have a powerful engineer on site on their team. So all the constraints that you can provide on feeder or on the voltage, like all that information, a lot of them don't really have the capacity of analyzing it. We rely on utilities to give us the value to give us.

1608
Eva Wang TotalEnergies 07:19:06.366 --> 07:19:27.066
The upgrade cost, and I said, I mentioned earlier, like, what really driven, whether a customer's willing to participate in our GP profile is the revenue at the end of the day, right? What the they're paying and what the risks they're taking. And then for customer developer, you can entertain it's interchangeable.

1609
Eva Wang TotalEnergies 07:19:27.124 --> 07:19:48.154
That's because we're 1 group, we want to get more solar on the customer site and to have those data, some of data may be useful. But then at the end of the day, we're still relying on the utility to tell us what exactly. You know.

1610
Eva Wang TotalEnergies 07:19:48.248 --> 07:20:06.722
Triggering certain upgrade and we don't even know the well, we know some itemized upgrade costs right? But we can't determine what the total upgrade is until you until you tell us. So that's the challenging part.

1611
Roger Salas SCE 07:20:07.684 --> 07:20:09.124
Yeah, I was more referring to.

1612
Roger Salas SCE 07:20:09.482 --> 07:20:30.542
it will continue to provide that but i was more referring to like so all we're talking about the discussion today or all these times has been about what if customers assigned to close doors and go somewhere else and essentially reduce the load on the circuit that's kind of the main issue right so so again 

1613
Roger Salas SCE 07:20:30.574 --> 07:20:51.694
You know, what, if what, if you had a listing of 8, you know, these are the large number of new customers in this area um, you have, you know, 5 of them, 10 of them, whatever number, whatever the data makes sure. Yeah. I imagine that you could hire someone to perform an evaluation as to whether.

1614
Roger Salas SCE 07:20:51.726 --> 07:20:57.486
The risk is low, that any 1 of those customers going away from the customer problem or not. The problem is.

1615
Eva Wang TotalEnergies 07:20:57.486 --> 07:20:58.596
to go away right 

1616
Eva Wang TotalEnergies 07:20:58.748 --> 07:21:19.774
We can hire a consultant or whatever, but if they go away, we still need to have a dollar value attached to it. But I can say, it's, you know, it's 5% of chance that 1 of the factor would close. But then, what's the impact on the grid? And what's the average cost? I don't think.

1617
Eva Wang TotalEnergies 07:21:20.132 --> 07:21:32.132
Engineer like, even with hire consultant to perform that, because, you know, most of the data, uh, only you guys have access to it and, you know how to perform those analysis.

1618
Roger Salas SCE 07:21:32.764 --> 07:21:41.042
Yeah, yeah, all this would be is whether or not someone going away could create a problem. You know, the.

1619
Roger Salas SCE 07:21:41.048 --> 07:22:02.164
I was going to depend on each specific circuit circumstances. So that, that that is the 2nd element, but at least, you know, I think, you know, someone could take a look at the data and, you know, I'm going to say, do some calculations, but maybe some statistical evaluation.

1620
Roger Salas SCE 07:22:02.226 --> 07:22:19.836
Whether or not, you know, any 1 of those customers are going to going away, we'll create a problem just trying to figure out if there's any way that we can provide data for developers to feel comfortable. Um, because otherwise we will get away. We not want to be able to get out of this kind of, you know, who's taking this risk.

1621
Eva Wang TotalEnergies 07:22:21.666 --> 07:22:23.346
Does not solve the fundamental.

1622
Eva Wang TotalEnergies 07:22:23.434 --> 07:22:34.054
The problem here, right? It's it's still the risks unknown and still the, the cap is unlimited and the duration is.

1623
Younes, Amin 07:22:34.444 --> 07:22:44.494
I don't think the cap is unlimited as, as Justin said, you know, there's no or as Justin believes there's no way that the developer would be.

1624
Younes, Amin 07:22:44.524 --> 07:23:05.642
the upgrade cost but i guess that's not you know from the commission but from energy division what what the risk up to the developer is having a curtailment a permanent curtailment and that risk is known that you know what the value of that energy is and you know what the impact on your on your cash flow would be um so i do think that the impact of that risk is is quantifiable 

1625
Younes, Amin 07:23:05.648 --> 07:23:13.832
you know what those loads on the er yeah those loads on the circuit art which you could know i think the um you know s roger's atlas could provide that to you 

1626
Eva Wang TotalEnergies 07:23:15.632 --> 07:23:36.662
I said the cap I was, assuming that we have the option of performing upgrade to bring back the customer profile to the original value. Right? That's what I meant the cap for the upgrades. If we don't even have that option, then that's even bigger risk. Right?

1627
Eva Wang TotalEnergies 07:23:36.992 --> 07:23:57.424
Utility design, uh, year 3, right to limit our maximum GP value. Then our calculating like year, 33 year, 25 or are we with calculating? Like year? 24 to 25? You know, you're talking about a wide range.

1628
Eva Wang TotalEnergies 07:23:57.876 --> 07:24:08.734
Connecting after 2 months, what could be shutting down to, like, the minimum lowest, uh, value. So, having that range, it's not it's not acceptable.

1629
Younes, Amin 07:24:11.256 --> 07:24:22.384
yeah that may be my my point was that you you don't necessarily need to know you can make a risk assessment without knowing the cost of distribution upgrades if you assume that you want to be 

1630
Eva Wang TotalEnergies 07:24:22.384 --> 07:24:24.634
Don't have the option of going back to the.

1631
Younes, Amin 07:24:26.494 --> 07:24:31.446
Whether or not, you're willing to accept that risk is is your decision, but there is a way you can calculate them.

1632
Younes, Amin 07:24:31.684 --> 07:24:45.694
Potential maximum risk that you face without knowing anything about distribution upgrade costs now you may be able to mitigate that risk through distribution upgrades, but you can you can calculate the, the maximum risk. I mean, that that is quantifiable.

1633
Sky Stanfield 07:24:46.562 --> 07:24:50.194
You just can't calculate how how it is to occur.

1634
Sky Stanfield 07:24:50.822 --> 07:24:52.624
We know that, like, you can say.

1635
Sky Stanfield 07:24:52.832 --> 07:25:13.952
We'll just be back to we know that. The magnitude of the risk is the entire value of the could be wiped clean and I think the way you put it. Just now makes it. Really quick. Wasn't really striking to me. Which is like, if you think that if that could happen next year, I just think even if it's a 1 kilowatt more like, it's a very.

1636
Sky Stanfield 07:25:13.984 --> 07:25:17.794
To be very hard to justify that cost. Um.

1637
Sky Stanfield 07:25:19.624 --> 07:25:39.694
You know, my sense is, is that, from my perspective, at this point, I am still not comfortable with the basic premise here that LGB customer that we should be shifting the basic cost allocation principles. Utilities are in charge of the grid and how the historically managed it such that this has never result with all the interconnections.

1638
Sky Stanfield 07:25:40.774 --> 07:26:01.892
The 1Million dollar systems, and we've never had a system a situation where load dropped off enough to trigger upgrades and we know that load and things are changing, but likely in our favor. And I think that the planning process should accommodate this instead. And if we need to test that out over time, my, because of.

1639
Sky Stanfield 07:26:01.924 --> 07:26:22.954
The challenges that we've described with 1, putting the weight on 1 customer versus versus the rate base as a whole our, our inclination at this point is to lead on that approach. We've been very, I want to be clear that we've been super open and really trying to work out a different way of doing it and have just come up against a hardware.

1640
Sky Stanfield 07:26:23.284 --> 07:26:44.194
and that hardware is driven by the fact that we are fundamentally not sure we with the concept at all that a customer should interconnect and be responsible for conditions that arise after they've signed their interconnection agreement when they have no control over those circumstances that's a pretty 

1641
Sky Stanfield 07:26:44.226 --> 07:27:05.346
Fundamental shift in the policy, and they maybe get some benefit, but that benefit is not unlimited. Either. It's going to be specific based upon what the rates are and so on. So, it's that's where we've come back to at this point after sort of struggling with another, trying to find a different approach. And I think that that's.

1642
Sky Stanfield 07:27:05.884 --> 07:27:26.494
you know something that the commission is going to kind of need to face and i'm not sure that they did when they when they set up the whole program is the idea that this customer should be treated differently um based on circumstances they can't control that's why i think they sent back to define better what those circumstances were and those circumstances continue to be 

1643
Sky Stanfield 07:27:26.524 --> 07:27:27.992
Completely out of their control.

1644
Frances Cleveland 07:27:30.364 --> 07:27:47.462
So, I, I have a couple of thoughts here 1st of all risk is probability times the impacts and the impact is loss of revenue. So I don't think we can avoid trying to address the.

1645
Frances Cleveland 07:27:47.792 --> 07:28:08.434
Pack the loss of revenue. The other thing is that loss of load is not only customers going away, but it's also existing customers on that circuit, adding their own generation, and thus reducing, uh, load.

1646
Frances Cleveland 07:28:08.884 --> 07:28:29.764
For their own purposes, so we, you know, you can't look at it as just, um, the load going away. Um, and I think, you know, I, I hear, you know, that the risk is due to things that nobody can foresee but the utilities.

1647
Frances Cleveland 07:28:30.126 --> 07:28:51.096
Foresee it any more than the, um, folks can foresee it? So it seems to me that it's really a question of costs or upgrades getting to at least a a handle on what the costs might be. If there were this kind of upgrade or that kind of upgrade.

1648
Frances Cleveland 07:28:51.934 --> 07:29:11.494
Uh, and the cost for lost revenue, which should be easier to to figure out because you've got tariffs and et cetera, and then formulate and this is, I presume, part of phase 2, a way of sharing that risk. I I don't think you can say that, you know.

1649
Frances Cleveland 07:29:12.248 --> 07:29:33.062
Either side, uh, really, uh, house, uh, the reason for saying, I should not bear any risks sky. You've said that so I think it's really a formula for how do you share that risk once? You know what the costs might be? Um.

1650
Frances Cleveland 07:29:33.454 --> 07:29:54.274
Uh, and I think that that's the key, the key issues. Um, and it can be based, as you say, on, you know, you're better off going in the low risk areas for with but it's not just that it's really just coming up with a formulas for figuring out what the.

1651
Frances Cleveland 07:29:54.664 --> 07:29:59.584
Upgrades might be and the cost of lost revenue.

1652
Younes, Amin 07:30:10.744 --> 07:30:28.294
Just thinking out loud here and not something that we necessarily support, but a relatively simple way to think about it would be to just say, have have the utilities compensate for any lost any load that couldn't be, or any energy that couldn't be served due to.

1653
Younes, Amin 07:30:28.684 --> 07:30:46.114
Whatever conditions changes in conditions I'd say, half the rate. So that way half the, the rate periods, where half the cost, and the, um, the interconnects with customers have half the cost. And I think that the very use, if I'm thinking about that correctly, it's a very easy way to subdivide it without having to get into the nuances of the of the financing.

1654
Regnier, Justin 07:30:49.864 --> 07:30:54.094
So I want to speak a little bit to default. Um.

1655
Regnier, Justin 07:30:55.924 --> 07:31:14.552
The decision did not clarify the reduction of limited. The reduction of the Lumina generation profile to the value is permissible on an ongoing basis.

1656
Regnier, Justin 07:31:20.884 --> 07:31:37.474
That it can be used as a cure to safety and reliability issue that has not been established in the absence of establishing that utility practice is to.

1657
Regnier, Justin 07:31:37.534 --> 07:31:55.802
Perform the upgrades that are required as part of their planning process to restore the grid to a condition, such that the interconnection agreement as it's originally signed, can be honored the IO.

1658
Regnier, Justin 07:31:56.012 --> 07:31:58.502
Raise the concern that doing so.

1659
Regnier, Justin 07:32:01.052 --> 07:32:09.302
Has the potential to impose a disproportionate cost on rate there so.

1660
Regnier, Justin 07:32:10.232 --> 07:32:21.844
The situation I think that Roger put out in the last workshop was the 5Million dollar upgrade for 50 kilowatts of capacity. Um.

1661
Regnier, Justin 07:32:26.164 --> 07:32:29.164
I think the question we have to answer is.

1662
Regnier, Justin 07:32:31.382 --> 07:32:33.902
What is a reasonable balance?

1663
Regnier, Justin 07:32:36.906 --> 07:32:57.846
Between honoring our practice and not establishing a a separate class of customer that doesn't have the right to have their interconnection agreement honored versus putting rate pairs potentially.

1664
Regnier, Justin 07:32:57.964 --> 07:33:13.114
On the hook for large upgrade costs in edge cases, where it's just restoring a small amount of capacity but, you know, that's that's the default situation that we're in.

1665
Regnier, Justin 07:33:17.342 --> 07:33:19.832
So, if if we want to have.

1666
Regnier, Justin 07:33:21.846 --> 07:33:42.964
If we want to have some kind of a threshold or loss of revenue, it has to be met before the undertake the upgrades that's got to get justified current utility practices to provide those upgrades to restore the grid or the condition where the.

1667
Regnier, Justin 07:33:42.970 --> 07:33:48.666
Original interconnection agreement can be honored. That's the default.

1668
Aliaga-Caro, Jose 07:34:00.426 --> 07:34:05.914
So, Scott, I think you had 1 more slide or is that correct? Or not.

1669
Sky Stanfield 07:34:08.734 --> 07:34:14.644
Um, I don't think so I think I, I basically put up these 2 slides about the data needs, but.

1670
Aliaga-Caro, Jose 07:34:14.704 --> 07:34:15.634
Oh, okay. All right.

1671
Sky Stanfield 07:34:15.844 --> 07:34:18.994
We could talk through further, but frankly, I think everyone's too.

1672
Sky Stanfield 07:34:21.272 --> 07:34:28.652
And they're kind of built on hypotheticals about what dependent on which way we go with initial risk.

1673
Aliaga-Caro, Jose 07:34:28.922 --> 07:34:31.142
Okay, I just wanted to make sure we got through your slides.

1674
Sky Stanfield 07:34:31.292 --> 07:34:31.622
I think.

1675
Aliaga-Caro, Jose 07:34:32.012 --> 07:34:36.422
Discussions continued Gary has his hands up.

1676
gary holdsworth sdg&e 07:34:38.942 --> 07:34:42.122
Well, uh, this is a comment from, um.

1677
gary holdsworth sdg&e 07:34:42.214 --> 07:34:51.154
Is an observer of interconnection over 17 years like Roger, not from a position in San Diego or any other.

1678
gary holdsworth sdg&e 07:34:52.472 --> 07:35:12.332
Going back to and I know Justin was wrapping and and was trying to summarize and I, I don't disagree at all with what he was saying as far as summarization. But it does sure seem like this creation of, as you mentioned, Justin a 2nd.

1679
gary holdsworth sdg&e 07:35:13.208 --> 07:35:34.354
Type of customer of different type of customer with different, um, either a different risk profile or a different, you know, financing structure that it has worked for years, you know, just introduces. It's just an observation. Perhaps that just introduces more challenges than.

1680
gary holdsworth sdg&e 07:35:34.384 --> 07:35:35.914
Perhaps it's worth because.

1681
gary holdsworth sdg&e 07:35:38.374 --> 07:35:58.322
You know, despite the fact that, uh, sky will argue that the current system is doesn't work as well. It's worked well, for years it may not work ideally, for every party in every situation. But it's worked well for years and to kind of throw cost causation.

1682
gary holdsworth sdg&e 07:35:58.356 --> 07:36:13.536
Principles side to start talking about cross subsidization and, you know, determination forecasting load departing and when we can barely keep up with the work that we have in front of us.

1683
gary holdsworth sdg&e 07:36:15.902 --> 07:36:25.562
It sounds like more and more. This is way more complicated and it's going to provide any benefit just an observation. Thank you.

1684
Sky Stanfield 07:36:29.014 --> 07:36:49.084
I think Gary that you're right if it's implemented in the way we've been talking about it, we can make it super complicated or we can keep it super simple and that's kind of the choice we have in front of us. Um, I think I'd be curious for the utility is to take a look at some of the curves and think.

1685
Sky Stanfield 07:36:49.116 --> 07:37:10.176
What those curves represent? I think that I think very deeply. And the reason why you Eric has invested so much sweat and trying to come up with a complicated solution. Here is because it seems like there's a huge amount of value to the state of California broadly. Whether we characterize it as ratepayers or citizens.

1686
Sky Stanfield 07:37:10.266 --> 07:37:31.384
Role at, having energy, be able to be produced in a clean and local manner during the hours we need it and not during the hours. We don't need it and avoid thereby avoiding unnecessary grid upgrades. The speaks for itself in that area on the monthly profiles and in some cases.

1687
Sky Stanfield 07:37:31.504 --> 07:37:52.534
There are multiple megawatts of difference in there. That's a lot of energy being needed essentially. So I do feel like there's a huge amount of value potential here and indeed. It's the value potential utilities have been identified for years since the very 1st day is working with Roger on this. The complaint was that customers weren't able to design systems that matched the grid needs.

1688
Sky Stanfield 07:37:53.192 --> 07:38:13.682
That's what we're trying to do here with much resistance. Um, but I do think that you're right that the way the all these options are really complicated. Um, if we're if we're trying to change the cost allocation mechanism, the current, we are the current proposal. Utilities proposal is the 1 that actually is shifting the.

1689
Sky Stanfield 07:38:13.714 --> 07:38:34.834
Cost allocation proposal, the current approach is the customers don't bear the costs after they interconnect. It's it's a shift to they're having them bear the cost based upon the current framework, but I appreciate you sharing your thoughts. Gary I want to mostly wanted to respond that. I agree that we could get make this really complicated, but I also think there's a.

1690
Sky Stanfield 07:38:34.840 --> 07:38:38.884
We didn't do it simply based upon the overall risks in front of us.

1691
Sky Stanfield 07:38:40.478 --> 07:38:43.292
I didn't remember that. I had 1 more slide. Um.

1692
Aliaga-Caro, Jose 07:38:43.504 --> 07:38:43.892
If you know.

1693
Aliaga-Caro, Jose 07:38:44.132 --> 07:38:44.524
Go ahead.

1694
Sky Stanfield 07:38:45.754 --> 07:39:01.562
Uh, and this goes right to what I was just getting at, which this is a slide that's more of a heads up to everybody, um, as part of our work trying to really understand, um, the value so to speak but also how to do.

1695
Sky Stanfield 07:39:01.654 --> 07:39:22.774
How systems could be designed around this and what kind of profile makes sense to do we've been digging into the data that utilities provided us for phase 2 and both trying to look at some sample 24 hour profiles as well as sample 12 months profiles and.

1696
Sky Stanfield 07:39:23.284 --> 07:39:43.864
What we've found so far, is that the sample 24 hour profile by sample I mean, we pulled looked at the suburban feeders and suburban theaters in each of the territories and then we at each node. And then overall for the circuit, and what we're seeing.

1697
Sky Stanfield 07:39:44.132 --> 07:40:05.072
At this stage is not what we would expect, and not entirely explainable based on simple engineering understanding. I told Jose that I would give everybody a heads up about that that said we just got the data from our consultant last week and, um, thanks to having a holiday.

1698
Sky Stanfield 07:40:05.080 --> 07:40:26.224
We did not have not had a chance to fully digested um, we're going to spend hopefully the next week trying to really make sure we understand what we're seeing on our end. And but we do think it's probably going to be something, unless it's potentially something that we're going to need to discuss as a group both as we try to understand.

1699
Sky Stanfield 07:40:26.552 --> 07:40:47.344
Particularly, as we try to understand the 24 hour versus 12 month, or combination there in profile short story is, is that the IC data isn't lining up to what 1 would we typically describe it as looking like? Um, so that was a long winded way of saying there's something.

1700
Sky Stanfield 07:40:47.584 --> 07:41:08.224
We haven't quite understood yet and we're lagging it and I think it would be great if the utilities maybe on your end. Also I'm curious if you guys have ever done this yourselves, which is look at some 24 hour profiles across your systems. Um, because that's what we're going to want to come back to. If it turns out we can't explain it through some clear anomaly.

1701
Roger Salas SCE 07:41:09.034 --> 07:41:20.674
Yes, uh, just not not to go into much into that, but I said, when you say not expected, I said that the profiles are too low that they're fluctuate too much.

1702
Sky Stanfield 07:41:21.544 --> 07:41:29.674
Yeah, so there's a couple of different things and again, I don't want to spend too much too much time until we really digested them. They the main differences are.

1703
Sky Stanfield 07:41:29.678 --> 07:41:50.434
That the load, the thermal, and the voltage criteria do not follow a consistent curve and don't typically the thermal seems someone. Okay but the voltage is where things are seem odd, we would have expected the, not the flicker, but the steady state voltage to.

1704
Sky Stanfield 07:41:50.830 --> 07:42:11.766
Align fairly closely with the thermal curve, which would align fairly closely with the dot com or the load curve essentially. And in some cases, there are radical jobs. So you'll go 1 hour, 1, random hour. Not like, oh, everybody turned their lights on or at 50 PM something happened but like, at 11 0 am for some reason, you'll go from.

1705
Sky Stanfield 07:42:11.978 --> 07:42:33.124
An limit voltage, a limit of 1 megawatt to 5 megawatts or something while, um, so that's what we're seeing again, with a limited sample that we need to digest more down. Very much could be ways to explain why that is happening. Especially with how the 24 hour profile is set up. Um, but we had.

1706
Sky Stanfield 07:42:33.128 --> 07:42:54.274
Taking a look at those 24 hour profiles at the level of detail we need to to understand exactly what what the project would be doing and how they would be able to design the economics around it. So, it was kind of vague Roger, but I think you'll be able to see it. If you look at some of them yourself, they're going to look different for every feeder. So we looked at a sample.

1707
Sky Stanfield 07:42:54.904 --> 07:42:57.814
And and the samples were consistently confusing.

1708
Roger Salas SCE 07:43:01.174 --> 07:43:02.374
Look forward to seeing the data.

1709
Sky Stanfield 07:43:02.704 --> 07:43:03.184
Yeah.

1710
Sky Stanfield 07:43:06.482 --> 07:43:10.412
Um, can I just ask you Roger, if you guys have done that look yourself.

1711
Roger Salas SCE 07:43:10.472 --> 07:43:19.652
None, I don't think we done that type of evaluation and, I mean, we, we look at we generally just look at the actual. I see.

1712
Roger Salas SCE 07:43:19.658 --> 07:43:36.004
A profile, but that already encompasses the minimum value of the thermal voltage power quality. Um, and so those typically tend to be, I mean, are these, the ones that I've seen pretty well predicted, you know.

1713
Sky Stanfield 07:43:36.004 --> 07:43:39.962
When you're looking at the effort, what happens if you take the out.

1714
Roger Salas SCE 07:43:41.312 --> 07:44:01.952
I mean, I don't think I've seen any normalities, but but I think, uh, I mean, it seems that you're looking specifically at the, uh, the for voltage and the for Thermo individually and trying to make a sense of each of those individually. I don't think we've done the level, which is basic. Look like the 1 that has.

1715
Roger Salas SCE 07:44:01.958 --> 07:44:03.094
Everything on it, right?

1716
Sky Stanfield 07:44:03.724 --> 07:44:23.044
Yeah, so what we did, and again we'll get into it more. We did, we looked at the problem, which can be weird because it's and then we broke it down by the different criteria to see if we could understand why it was being weird. And that's where you see the, the differences. It's really interesting and we're going to talk a lot more about it.

1717
Sky Stanfield 07:44:23.494 --> 07:44:33.424
Um, but it is a little it does affect what we're doing here. Um, I don't know in in which direction quite yet. I mean, do you have a question.

1718
Younes, Amin 07:44:34.654 --> 07:44:38.014
No, I'm just very interested in what you're saying about that. Yeah, I, I've looked at.

1719
Sky Stanfield 07:44:38.014 --> 07:44:44.254
I'm not trying to hide things. We didn't want to share it until we all digested it ourselves just so that we could be coherent.

1720
Sky Stanfield 07:44:44.260 --> 07:44:52.144
And about it, and I talked with Jose about it, and he suggested just giving everybody a heads up. So that's what I'm doing. I'm not trying to be all sneakier.

1721
Alex Mwaura PG&E 07:45:00.152 --> 07:45:06.332
Is it possible to share that information Skype prior to the workshop, or this will be discussed so we can sort of.

1722
Alex Mwaura PG&E 07:45:06.542 --> 07:45:06.842
Into.

1723
Sky Stanfield 07:45:07.652 --> 07:45:16.682
I think what we haven't talked through it yet, because again, we need to digest it a few a bit more. But what we, what we could probably do is set up.

1724
Sky Stanfield 07:45:16.924 --> 07:45:37.834
Develop some slides that we share in advance of people to digest and then do a presentation and we can bring our consultant in. I mean, our consultants really just applying the data, like, taking what you guys sent us and putting it in a graph is the is the basic method. Um, but that's what we'd be happy to provide some.

1725
Sky Stanfield 07:45:37.866 --> 07:45:43.804
So, you guys can look at it and get some thoughts before the meeting and whenever that happens, that's what we still have to work out.

1726
Alex Mwaura PG&E 07:45:45.364 --> 07:45:46.624
I'm sorry, go ahead.

1727
Roger Salas SCE 07:45:47.254 --> 07:45:48.874
Please finish your reply.

1728
Alex Mwaura PG&E 07:45:49.174 --> 07:45:54.634
So this is based on 202,112 months so basically, January to December 2021.

1729
Sky Stanfield 07:45:54.694 --> 07:46:06.034
So, you guys provided us the data in March? I believe it was as March of 2021? No, March of 2022. so just earlier this year.

1730
Sky Stanfield 07:46:06.392 --> 07:46:27.182
Um, is that right? Yeah. Um, so it's, it's essentially the, the, for each of your territories that was stamped in March of 2022 that we're working off of and, and that happens to be beneficial, because the issues that came up with addison's, um, I see later. So, we're, we're kind of eliminating those and assuming that.

1731
Sky Stanfield 07:46:27.214 --> 07:46:41.584
The old data, the variations are not that different across the utilities. They're all unique in their own way, but it wasn't like, oh, this seems to be 1, utilities results versus and others again. I don't know what that means.

1732
Sky Stanfield 07:46:43.146 --> 07:46:45.066
Sharing what I what I can at this point.

1733
Roger Salas SCE 07:46:46.356 --> 07:46:48.336
I was going to ask about that because it's just.

1734
Roger Salas SCE 07:46:48.366 --> 07:46:58.804
We, we're in the process of updating our IC values over the next few months and so whatever data you had for cattle those discrepancies. So just.

1735
Sky Stanfield 07:47:00.154 --> 07:47:06.664
Shouldn't have had those discrepancies as far as I understand based on when you guys did the rollout.

1736
Roger Salas SCE 07:47:06.846 --> 07:47:07.324
Yeah.

1737
Sky Stanfield 07:47:07.414 --> 07:47:09.456
But we're happy to use the.

1738
Sky Stanfield 07:47:09.516 --> 07:47:26.946
That metadata, when you got it, but like I said, he doesn't look like it's, it's not the addison's. Was that different than the other? So I don't think there there was an anomaly from that again. It's really going to be helpful to get you guys as input. Once we and I feel silly telling you all about us so that we got to show it to, you.

1739
Regnier, Justin 07:47:28.836 --> 07:47:30.606
I think everybody's looking forward to the data.

1740
Sky Stanfield 07:47:30.994 --> 07:47:31.294
Yeah.

1741
Regnier, Justin 07:47:32.884 --> 07:47:39.664
So, I think we're starting to lose folks and it's been a long day. I just wanted to do a little bit of level setting before we wrap up. Um.

1742
Regnier, Justin 07:47:42.124 --> 07:48:03.062
Appreciate gary's frustration and concern um, but we are Ministerio and we have been instructed to implement this and we have to implement this. So, I, I don't know that there's any, any other option on the table. Um, at this point, I don't know that we've got any.

1743
Regnier, Justin 07:48:03.096 --> 07:48:24.214
Record that thanks, no worries. Um, I don't think that we've got any record that indicates that the have a viable path and permanently reducing the export values that are in the and.

1744
Regnier, Justin 07:48:24.220 --> 07:48:43.656
Connection agreement, the default is to go as we always have, um, where rate pairs pay for upgrades to return the grid to a condition where the interconnection agreement can be honored on a permanent basis.

1745
Regnier, Justin 07:48:45.394 --> 07:49:05.764
So, I think there's been a lot of flexibility by parties and trying to come up with designs that honor the concerns about inordinate costs per minimal benefit on edge cases. But.

1746
Regnier, Justin 07:49:07.532 --> 07:49:16.352
There needs to be a record if we want to deviate from the practice that has been common here.

1747
Regnier, Justin 07:49:19.564 --> 07:49:24.904
We need to get to, um, advice, letter language.

1748
Regnier, Justin 07:49:27.668 --> 07:49:29.344
Um, so.

1749
Regnier, Justin 07:49:30.516 --> 07:49:51.634
If we can't establish or values don't establish the, there's a rationale for treating customers, any different than any other customer. We're going to be on the default pathway. As far as I can see, we need a record to justify any deviation.

1750
Regnier, Justin 07:49:51.664 --> 07:49:58.894
From that, um, appreciate everybody's flexibility and trying to to find something that.

1751
Regnier, Justin 07:50:00.364 --> 07:50:02.194
Spies, everybody's concerns.

1752
Regnier, Justin 07:50:06.064 --> 07:50:14.914
I think we should bear in mind what the default cases, and what we need to do in terms of building a record. If we want to deviate from that default.

1753
Regnier, Justin 07:50:17.402 --> 07:50:17.882
I think.

1754
Regnier, Justin 07:50:19.956 --> 07:50:29.914
I'd leave it to, let's say, as the facilitator, but I think that we are at a, at the tail end of a very long day and we're starting to lose folks. So I don't know if.

1755
Regnier, Justin 07:50:31.120 --> 07:50:34.084
Have any other things we want to cover in today's conversation.

1756
Aliaga-Caro, Jose 07:50:39.334 --> 07:50:56.494
Um, I do not have anything, uh, left to say in my mind that this hour, other than I need sleep. Um, but, uh, you know, we're definitely going to have a workshop 3.

1757
Aliaga-Caro, Jose 07:50:56.674 --> 07:50:58.142
Logistics and date.

1758
Aliaga-Caro, Jose 07:50:59.320 --> 07:51:18.724
Still to be determined, um, we do need to get that in the books, though as soon as possible. So, you know, definitely not next week. Of course. But I am thinking some time the week of December.

1759
Aliaga-Caro, Jose 07:51:20.556 --> 07:51:24.426
Uh, to get that going, um.

1760
Aliaga-Caro, Jose 07:51:26.464 --> 07:51:36.124
The, uh, recording, uh, and the slides should be updated to the rule 21 webpage probably by Thursday or Friday this week.

1761
Aliaga-Caro, Jose 07:51:37.414 --> 07:51:38.254
Um.

1762
Aliaga-Caro, Jose 07:51:41.374 --> 07:51:42.694
I'm going to say is.

1763
Aliaga-Caro, Jose 07:51:44.440 --> 07:51:50.104
I don't know why bother making agendas with I mean, considering they never work out.

1764
Aliaga-Caro, Jose 07:51:53.492 --> 07:51:56.042
So, anyways, that's a joke.

1765
Aliaga-Caro, Jose 07:51:58.024 --> 07:52:00.274
Right now I'm thinking, I should just say.

1766
Aliaga-Caro, Jose 07:52:02.494 --> 07:52:22.474
1, to 5, everything in 1, big chunk but, uh, anyways, uh, kidding aside. Uh, thank you everybody for, uh, this, uh, great discussion today. Um, definitely this is a very complicated.

1767
Aliaga-Caro, Jose 07:52:22.510 --> 07:52:31.536
I think we do have some good ideas that we need to think about. Uh, thank you Scott for presenting this. Um.

1768
Aliaga-Caro, Jose 07:52:34.022 --> 07:52:54.542
So, I think I will follow up within the next couple of days with follow up items to the utilities and to the non parties. Once I review the recording again, and we can discuss next steps, uh, through email. And, you know, if you always.

1769
Aliaga-Caro, Jose 07:52:55.594 --> 07:52:56.464
Want to meet.

1770
Aliaga-Caro, Jose 07:52:57.760 --> 07:53:09.336
Discuss offline, or outside the workshop, uh, and talk for a little bit, you know, just shoot me an email and we can make that happen. So, um.

1771
Aliaga-Caro, Jose 07:53:10.506 --> 07:53:16.836
Just for a couple minutes, I guess I'll open it up to. And if anybody else has anything else to say.

1772
Sky Stanfield 07:53:18.934 --> 07:53:27.124
I just wanted to say, thanks for everybody for a good conversation as well. There's certainly a lot of part issues here and appreciate everybody's engagement.

1773
Aliaga-Caro, Jose 07:53:33.064 --> 07:53:37.024
All right, well, thank you again. Everybody.

1774
Roger Salas SCE 07:53:37.114 --> 07:53:37.714
Thanks everybody.

1775
Aliaga-Caro, Jose 07:53:38.104 --> 07:53:44.854
And, uh, I hope you have, uh, I hope you can, uh, decompress, uh, this evening somehow.

1776
Roger Salas SCE 07:53:47.164 --> 07:53:48.034
It.

1777
Aliaga-Caro, Jose 07:53:48.694 --> 07:53:50.134
All right thanks. Everyone.

1778
Frances Cleveland 07:53:51.814 --> 07:53:52.144
By.

1779
Aliaga-Caro, Jose 07:53:52.596 --> 07:53:52.804
Bye.