2.5 What Could or Should Other Jurisdictions Do?

2.5.2 “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.