2.4   What Are Some Recent Major Issues Being Discussed by Regulators?

2.4.4 What Could or Should Other Jurisdictions Do?

Other jurisdictions do not have the same utility structures or the same regulatory environment as California, Hawaii, or other States that are actively addressing distribution and DER issues. So some pertinent questions may be asked by these regulators and utilities:

“My jurisdiction is much simpler than California’s. Why should I pay any attention?”

Some jurisdictions have very limited numbers of DER systems already installed and there are few incentives to encourage more DER installations. The idea of including mandates for smart inverters or distribution resource plans seems unnecessary and excessively complicated. However, some possible issues to explore in this situation are:

• Maybe regulatory mandates are not important at this time, but possibly some of the “smart inverters” functionality could be useful in special situations. Since the DER manufacturers will soon have products that will be certified for many of these smart inverter functions, a requirement to include such functionality could be part of those special utility-customer agreements.
• Utilities and regulators could use some of the financial and technical data that are being discussed during the development of the California Distribution Resource Plans. The actual data would be different for different jurisdictions and some may not be relevant, but using the types of data as a checklist (see 2.4.2) could help utilities provide good arguments for their plans while regulators could use the checklist in their assessments of the utility distribution plans.
• Given that the advanced DER technology is available, some commercial or industrial customers may feel it could be in their best interest to offer certain ancillary services to the utility if the incentives were right. They might pressure the utility and/or regulators to allow them to either establish a customer agreement or develop a special tariff. Seeing what California or Hawaii or other States could provide guidelines for such discussions.
• The utility might become interested in providing some DER-based services, including owning and operating DER systems in “rent-a-roof” schemes. The utility could learn from these other States on both the challenges and the benefits of such efforts.

“My jurisdiction has a growing number of DER systems but the regulatory environment is completely different. What can I learn from those other States?”

Some jurisdictions could have a growing number of DER systems being installed, but do not have any real concerns yet about high penetrations of DER systems, nor do they any regulatory requirements for advanced DER functionality. Some possible issues to explore in this situation are:

• Since DER systems with advanced functionality will be on the market soon as the California Rule 21 regulations take effect, utilities could require some of the same DER functionalities even if these are not mandatory in their jurisdiction. These requirements for advanced DER functionality could be as broad as in California (all DER systems, regardless of size, shall include the Phase 1 functions) or could be tailored to specific situations where the functionalities could be particularly beneficial.
• Utilities with secondary networks (see 3.2.2) could review what some utilities are doing to permit additional DER systems on these networks. This issue is being addressed again during the IEEE 1547 update process, so utilities could either directly participate in these discussions or at least follow the discussions. Regulators could urge such participation if customer demands for additional DER interconnections to secondary systems appear to warrant it.
• Utilities and other stakeholders could request the regulators in their jurisdiction to start the process for making some of these DER capabilities mandatory, particularly once the IEEE 1547 interconnection standard is updated to reflect the California-like requirements.
• Utilities and regulators could use some of the financial and technical data that are being discussed during the development of the California Distribution Resource Plans. The actual data would be different for different jurisdictions and some may not be relevant, but using the types of data as a checklist (see 2.4.2) could help utilities provide good arguments for their plans while regulators could use the checklist in their assessments of the utility distribution plans.
• If it is expected that the number of electric vehicles (EVs) (see 3.4.6) could grow significantly, discussions with utilities which already are experiencing pockets of EV clustering could be useful. In particular, the management of EV charging could be explored, including limiting charging rates during peak times, establishing “charge-by” policies, and recommending the inclusion of energy storage facilities at charging stations to smooth out demand.

“My jurisdiction is starting to see distribution problems related to DER systems but utilities are concerned about using these new advanced DER functionalities. What could the Hawaii, Europe, and other high penetration experiences help us with?”

The use of the advanced DER functionalities is still in its infancy. Although some basic understandings have been developed, it is clear that additional research is necessary, particularly for anomalous or emergency situations. Some possible issues to explore in this situation are:

• Utilities can explore the use of other feeder equipment, such as static var compensators, to determine if these are more cost-effective and more reliable for handling voltage problems than DER systems using either fixed power factors or dynamic volt-var control.
• Some utilities are undertaking research and lab projects to try to better understand the impacts, both good and bad, of the advanced DER functionalities. The results of these efforts could be provided to other utilities and/or used as a basis for further pilot projects.
• Utilities could partner with other stakeholders to explore specific issues, such as coordination of DER volt-var capabilities with the utility feeder equipment and determining the most appropriate DER voltage ride-through settings for ensuring safety as well as reliability of service.

• Utilities could review both the Hawaiian situation and the European situations where high penetrations of DER are being experienced. These differences in situations have to be carefully assessed before they can be applied to other situations, since Hawaii is an island, while the distribution systems of Europe have very different configurations to US distribution systems . That said, Hawaii (see 3.5.3) is permitting far more DER generation on its feeders than in most other locations, and, with support from DER systems that can “cease to energize” at high voltage levels, can ride-through over-voltage situations.