DG Standard Updates. IEEE 1547, UL 1741 SA, and Rule 21 CHASE SUN GII/PG&E 3/28/18

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DG Standard Updates IEEE 1547, UL 1741 SA, and Rule 21 CHASE SUN GII/PG&E 3/28/18

DER Interconnection Standards Chronology Arab Oil Embargo 1973 Gas Rationing. Oil went from $3/barrel (gas at $ 0.35/gal) to $12/barrel in one year PURPA 1978 Requiring Interconnection of Qualifying Facilities (Alternative Energy) to reduce oil consumption CPUC D.82 04 071 1982 PG&E Rule 21 Issued using existing PG&E requirements IEEE 929 2000 For PV inverters 10 kw or less. Established the certification methodology D.00 12 037 2000 Developed the Rule 21 Initial and Supplemental Review screens to enable fast interconnection for small units at low penetrations. Adopted certification methodology IEEE 1547 2003 National interconnection standard issued. Adopted certification methodology for DER units up to 10 MW Multiple CA legislations, mandating high renewable penetration levels, 33% RPS (energy) by 2020 and 50% RPS by 2030. The goal is to reduce/eliminate GHG emissions. Grid support was left to the existing conventional generators.

Need For Revising Standards Some areas, such as Germany, with higher renewable penetration are experiencing adverse impact, such as a large block of DER trips and high voltages, due to the simplified low penetration approach In 2012, Germany proceeded to retrofit over 315,000 inverters at hundreds of millions of dollars to avoid potential system reliability impact at high DG penetrations Previous requirements specified in IEEE 1547, 2003, and CA Rule 21, 2012, were based on simplified low penetration methodology, similar to Germany, which may cause unintended consequences at high penetration scenarios. Desire to use potential inverter capabilities, to mitigate the potentially higher impacts and to improve distribution level service reliability, i.e. microgrids, and power quality. 3

Existing Rule 21 requirements The existing Rule 21 recognized that DG operating within the existing distribution system design parameters, with no reverse flow, has minimal system impact. It identified the low impact conditions (Initial Review Screens) and provided simplified requirements to allow small DG units at low penetration levels to be interconnected quickly so long as safety issues are addressed. Using the existing grid s operating margin to enable fast DER interconnection significantly simplified the review/approval process and reduced the interconnect review time for the small units. Currently, the NEM PV units less than 30 kw can be approved and interconnected in 3 days at PG&E. 4

CA Smart Inverter Requirements Rule 21 Smart Inverter Phase 1, Autonomous Functions, is mandatory since 9/9/17, Certified to UL 1741 SA. Anti islanding Extended ride through for voltage and frequency Volt/var control Frequency watt (Optional) Normal Ramp Rate Connect/Reconnect ramp rate Microgrid exemption on ride through Phase 2 Communication capability 9 months after national communication test standard is issued (SunSpec certification document pending) California Common Smart Inverter Profile (CSIP) adopted using IEEE 2030.5 as the default protocol 5

Summary of Rule 21 Smart Inverter Phase 3 Proposed Changes, CPUC approval pending Function Description Rule 21 Section Requirement Date One Monitor Key DER Data Hh.7 Later of March 1, 2018 or 9 months after the release of SunSpec Alliance Approved Test Procedure Table (or 1 another industry-recognized protocol standard) Two DER Disconnect and Reconnect Command Hh.8 12 months after IEEE 1547.1 standard revision approval (Cease to Energize and Return to Service) Three Limit Maximum Active Power Mode Hh.8 12 months after IEEE 1547.1 standard revision approval Four Set Active Power Mode Hh.2.n Optional Upon Mutual Agreement between Utility and Applicant Five Frequency Watt Mode Hh.2.I 12 months from Commission approval of the Phase 3 Advance Function Advice Letter Six Volt-Watt Mode Hh.2.m 12 months from the Commission approval of the Phase 3 Advance Function Advice Letter Commission Seven Dynamic Reactive Support Hh.2.o Optional Upon Mutual Agreement between Utility and Applicant Eight Scheduling Power Values and Modes Hh.6 Later of March 1, 2018 or 9 months after the release of SunSpec Alliance Approved Test Procedure (or another industry-recognized protocol standard)

UL 1741 SA For Certifying Smart Inverter Phase 1 Autonomous Functions Issued on 9/8/16, mandatory in CA on 9/9/17 Developed specific test procedures for each required function in Rule 21 Using dead band & droop control for Volt/var control Test each function for the full range of adjustability. Test anti islanding with the new settings. Provide flexibility for different jurisdictional requirements

Impacts Reviewed/Mitigated during interconnection Safety DER should separate from grid and do not backfeed during abnormal conditions, such as during faults and downed conductors. Equipment Overload DER operation should not cause distribution equipment overloads Voltage DER shall not cause steady state voltage to exceed Rule 2 limits Transient voltage DER shall not sustain high transient voltage during ground fault Protection coordination DER fault current contribution shall not cause mis coordination of existing protective equipment

IEEE 1547 Re write Status Used Germany documents, Rule 21, NERC document as starting reference points. Reconcile the requirements for inverter based generators and machine based generators to the extent possible. Due to the different characteristics between inverter and synchronous generations, the current approach is to use two or more performance categories. Balloted in 2017with 78% approval rate and 1457 comments. All comments were addressed by the Comment Resolution Team. Recirculated and approved by IEEE Standards Board on 2/15/2018 Target issuance Q2 2018

IEEE 1547 IS: A Technical Standard Functional Requirements For the interconnection itself the interconnection test Technology neutral, e.g., does not specify particular equipment nor type A single (whole) document of mandatory, uniform, universal, requirements that apply at the PCC or Point of DER Connection. Should be sufficient for most installations. IEEE 1547 Is NOT: a design handbook an application guide an interconnection agreement prescriptive, e.g., does not address DR self-protection, nor planning, designing, operating, or maintaining the Area EPS. 10

P1547 New Requirements for Ride Through Three Categories of DER Operational Responses to Support the Grid Based on Local and Farther Reaching Grid Requirements and DER

P1547 voltage regulation Two performance categories are defined for DERs with voltage regulation capabilities: a) Category A covers minimum performance capabilities needed for Area EPS voltage regulation and are reasonably attainable by all state of theart DER technologies b) Category B covers all requirements within Category A and specifies additional requirements to mitigate voltage variations due to resource variability

P1547 Example New Reactive Power Requirements The DER shall be capable of injecting reactive power (over-excited) and absorbing reactive power (under-excited) equal to the minimum reactive power (kvar) corresponding to the value given in Table 7 at all exporting active power output greater than or equal to 20% of nameplate active power rating (kw) or the minimum steady state power capability of the DER, whichever is greater. For active power output greater than or equal to 5% and less than 20% of nameplate active power rating (kw) or the minimum steady state power capability of the DER, whichever is greater, DER of Category A and B shall be capable of exchanging reactive power corresponding to a triangular shape with base in the origin.

P1547 Example New Voltage Regulation Requirements Voltage-Real Power (Volt-Watt) Mode When in this mode, the DER shall actively control the active power output as a function of the voltage following a Volt-Watt piecewise linear characteristic. Two example Volt-Watt characteristics are shown in Figure 7. The characteristic shall be configured in accordance with the default parameter values specified in Table 10 for the given DER category. The characteristic may be configured as specified by the Area EPS Operator using the values in the adjustable range. If enabled, the Volt-Watt function shall remain active while any of the voltagereactive power modes are enabled. P pre v Active Power (Generation) (P 1,V 1 ) P pre v Active Power (Generation) (P 1,V 1 ) P 2 (P 2,V 2 ) V 1 V 2 V H Voltage V 1 V 2 V H Voltage V H : Voltage upper limit for DER continuous operation P 2 (P 2,V 2 ) Active Power (Absorption)

Frequency Droop Example Example of a frequency-droop function with a 5% droop, 36 mhz deadband, and 20% minimum active power output Active power output in percent of nameplate 120% 100% 80% 60% 40% 20% shall trip Frequency Droop 0% 56 57 58 59 60 61 62 63 64 DER with 90% loading DER with 75% loading DER with 50% loading shall trip

1 Preparing for the Future As California moves toward high renewable penetrations, interconnection requirements set up for low penetration, contained in IEEE 1547, UL 1741, & Rule 21, are being modified to account for high penetration effects Cumulative DG impacts at projected high levels are no longer negligible Aggregated impacts to grid has to be considered Proactively planning using hosting capacity methods to determine where and when additional hosting capacity is needed and can be implemented cost effectively on grid to accommodate high penetrations At high penetration levels, there may not be as many conventional generators available to provide system support and DG will need to be designed and operated to help maintain grid safety & reliability Additional granular visibility in grid will require investments in tools that improve: Forecasting DG impacts on grid Predicting DER behavior Viewing real time DER response At higher DG penetrations, there also may be more opportunities to capture potential benefits of DG, when cost effective, such as providing distribution services as non wires alternatives for distribution capacity, voltage management and resiliency 16

Slide 16 A1 Lets be more strong with this point since it is key to GII's Integrated Grid Strategy messages. Therefore, I've reworded this bullet to be: "DG will need to be monitored and controlled by the distribution system operator at high penetration levels in order to maintain the current safety and reliability levels." Author, 8/21/2017

The need for advanced DER Traditional Electric Grid Modern Electricity Choices Utility Scale PV Power park Wind Farms Rooftop Photovoltaics Hydrogen Storage Industrial DG Fuel Cells Remote Loads 17 17 EV s Load as a resource Smart Substation Combined Heat and Power

Appendix 18

Voltage: Typical Distribution Mitigation If and when voltage issues are identified, PG&E mitigates with voltage regulators and capacitors, and/or reconductoring small primary lines, and upgrading service equipment VOLTAGE REGULATORS FORCES VOLTAGE TO SET POINT CAPACITORS PRODUCES REACTIVE POWER TO RAISE VOLTAGE LINE CONDUCTORS REDUCE VOLTAGE LOSSES UPGRADE SERVICE REDUCE VOLTAGE RISE/DROP ` SUBSTATION TRANSFORMER CIRCUIT BREAKER Uncorrected Voltage Profile with PV Back Feed Corrected Voltage Profile 126V 120V 126V VOLTAGE REGULATORS RAISE VOLTAGE CAPACITORS RAISE NEARBY VOLTAGE LINE CONDUCTOR UPGRADE REDUCES RATE OF CHANGE 120V SERVICE UPGRADE Substation Voltage Along the Feeder REDUCES RATE OF CHANGE Customer 20

Current DER interconnection status The vast majority of the existing inverters are designed for grid interactive mode, set at unity power factor, and certified not to operate when the grid is de energized, i. e., certified anti islanding, to address safety concerns. A major benefit of the current simplified low penetration approach is that these inverters produced the maximum asavailable renewable energy by relying on the grid for voltage and frequency support, for absorbing excess power, and backup service when the DGs are not generating. By using the simplified low penetration process, PG&E currently has 3,700 MW and 340,000 installations of DER interconnected. 21

Existing Rule 21 Sec H, Voltage Settings, still in effect for non inverter based DG. Table D.1: Voltage Trip Settings Voltage at Point of Common Coupling Maximum Trip Time (1) % of Nominal Voltage # of Cycles Seconds Less than 50% 10 Cycles 0.16 Seconds 50% < V < 88% 120 Cycles 2 Seconds 88% < V < 110% No Trip 110% < V <120% 60 Cycles 1 Second Greater than 120% 10 Cycles 0.16 Seconds 22

Existing Rule 21 Sec H, Frequency Settings, still in effect for non inverter based DG. Table D.2: Frequency Trip Settings Generating Facility Rating Frequency Range Maximum Trip Time (1) Less or equal to 30 kw Less than 59.3 Hz Greater than 60.5 Hz 10 Cycles 10 Cycles Less than 57 Hz 10 Cycles Greater than 30 kw 59.8 Hz > f > 57 Hz 10 18,000 Cycles 2,3 Greater than 60.5 Hz 10 Cycles 23

New R21 Table Hh.1: Voltage Ride Through Table Region Voltage at Point of Common Coupling (% Nominal Voltage) Ride-Through Until Operating Mode Maximum Trip Time High Voltage 2 (HV2) V >120 0.16 seconds High Voltage 1 (HV1) 110 < V < 120 12 seconds Momentary Cessation 13 seconds Near Nominal (NN) 88 < V < 110 Indefinite Continuous Operation Not Applicable Low Voltage 1 (LV1) 70 < V < 88 20 seconds Mandatory Operation 21 seconds Low Voltage 2 (LV2) 50 < V < 70 10 seconds Mandatory Operation 11 seconds Low Voltage 3 (LV3) V < 50 1 seconds Momentary Cessation 1.5 seconds 24

New R21 Table Hh.2: Frequency Ride Through and Trip Settings System Frequency Default Settings (Hz) Minimum Range of Adjustability (Hz) Ride-Through Until Ride-Through Operational Mode MaximumTrip Time f > 62 62-64 No Ride Through Not Applicable 0.16 seconds 60.5 < f < 62 60.1-62 299 seconds Mandatory Operation 300 seconds 58.5 < f < 60.5 Not Applicable Indefinite Continuous Operation Not Applicable 57.0 < f < 58.5 57-59.9 299 seconds Mandatory Operation 300 seconds f < 57.0 53-57 No Ride Through Not Applicable 0.16 seconds 25

DER Wholesale Market Participation Before and After Impacts on Distribution Grid October 2013 October 2016 26

P1547 Revision: Draft Standard for Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces. Scope: This standard establishes criteria and requirements for interconnection of distributed energy resources (DER) with electric power systems (EPS), and associated interfaces. Note: Interfaces defined in IEEE 2030: a logical interconnection from one entity to another that supports one or more data flows implemented with one or more data links. Purpose: This document provides a uniform standard for the interconnection and interoperability of distributed energy resources (DER) with electric power systems (EPS). It provides requirements relevant to the interconnection and interoperability performance, operation, and testing, and, safety, maintenance and security considerations.

1547: Interconnection Is The Focus IEEE Std 1547 covers: - INTERCONNECTION TECHNICAL SPECIFICATIONS & REQUIREMENTS - INTERCONNECTION TEST SPECIFICATIONS & REQUIREMENTS Distributed Energy Resource (DER) unit Interconnection System Note: P1547 full revision started in year 2015. it also addresses interoperability and interfaces Area Electric Power System (EPS) 28

29 Are voltage regulation and ride through requirements proposed to be mandatory? The ride through capability and performance are proposed to be mandatory. The voltage regulation capability is proposed to be mandatory but the performance category and specific settings are proposed to be at the utility s discretion (The DER will provide this capability and the utility will decide to enable/disable it and choose the proper operating modes).

P1547 Example New Requirements for voltage Ride Through 1.30 1.20 1.10 1.00 may ride through 0.16 s or may trip 2 Permissive Operation Continuous Operation Category I (based on German requirements for sync. gen.) 1 s may ride through 1.20 p.u. 13 s 1 1.10 p.u. shall trip NERC PRC 024 2 Voltage (p.u.) 0.90 0.80 0.70 0.60 0.50 0.40 0.30 0.20 Permissive Operation may ride through or may trip Mandatory Operation 0.16 s German MV Code for syncr. DER 0.16 s 0.16 s 2 0.50 p.u. 2 s 1 2 s 0.88 p.u. 0.10 0.00 p.u. 0.00 p.u. shall trip 0.00 0.01 0.1 1 10 100 1000 Time (s) may ride through or may trip 21 s Legend range of adustability default value shall trip zones may ride through or may trip zones shall ride through zones and operating regions describing performance 0.88 p.u.

P1547 Example New Requirements for frequency Ride Through (work in progress) 63.0 62.5 62.0 61.5 61.0 60.5 60.6 Hz may ride through or may trip Mandatory Operation 66.0 Hz 66.0 Hz 62.0 Hz 0.16 s 2 Category I, II, and III (harmonized) shall trip 180 s 299 s 1 1 000 s 61.0 Hz 1 000 s may ride through or may trip Frequency (Hz) 60.0 59.5 Continuous Operation (V/f 1.1) 59.0 59.0 Hz 58.5 Legend 180 s 1 000 s may ride through or 1 Mandatory Operation range of adustability may trip zones 58.0 299 s default value shall ride through zones and operating regions 57.5 shall trip zones describing performance 57.0 Hz 57.0 may ride through 0.16 s may ride through or may trip 1 000 s 56.5 or may trip 2 shall trip 56.0 0.01 0.1 50.0 Hz 1 10 100 50.0 Hz 1000 Time (s) 31

Voltage and Reactive Power Control The DER shall provide the capabilities of the following modes of reactive power control functions: 1.Constant Power factor mode The capability is mandatory for categories A and B 2.Voltage reactive power (Volt var) mode The capability is mandatory for categories A and B 3.Active power reactive power mode (watt var) The capability is optional for category A and mandatory for categories B 4.Constant reactive power mode The capability is mandatory for categories A and B