Preparing Energy Storage Systems for Public Safety Power Shutoff Events
Modernizing the NEM tariff to allow pre-PSPS charging involves utilities proposing modifications to allow energy storage systems to temporarily import energy from the grid upon advanced notification of a PSPS event. This process includes coordination with developers/aggregators and consultation with stakeholders. Current NEM tariff revisions include options for customers to install protection relays and Power Control Systems. Utilities have established notification processes for PSPS events, and Power Control System certifications are outlined based on import/export capabilities.
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Microgrids & Resiliency OIR Pre-PSPS Charging under NEM June 25, 2020
Modernizing NEM Tariff To Allow Pre-PSPS Charging D.20-06-017 requires the utilities to file Tier 2 Advice Letters by July 17 that: 1) propose the necessary modifications to their NEM tariffs to allow energy storage systems that are interconnected under the condition that they charge from solar to temporarily import from (but not export to) the grid upon receiving advanced notification from the utility of an upcoming PSPS event; 2) discuss how they coordinated with developers/aggregators to create a process that allows energy storage systems that are interconnected under the condition that they charge from solar to temporarily import from (but not export to) the grid upon receiving advanced notification from the utility of an upcoming PSPS event; and 3) summarize how they consulted on this process with the SIWG. 2
NEM Tariff Revisions NEM tariffs currently require the following options: Customer can install non-export relays (reverse or minimum power protection) assuring no export from the storage to the grid. Customer can request a net generation output meter (NGOM) to measure the renewable energy production. Customer can install a Power Control System (PCS) certified to a national standard (UL PCS CRD). Minor, if any, tariff revisions are required: SDG&E has a CPUC-approved attestation form that customers using a PCS device must sign stating that they will not change modes on their device. This form must be modified. 3
Notifications Process for Public Safety Power Shutoff (PSPS) Each utility has an established process to contact customers by phone, text, or email to conduct PSPS notifications. Customers will need to contact the energy storage device operator to opt-in and authorize them to modify the settings. 4
Power Control System (PCS) Certifications The UL CRD for PCS allows certification to one of four options: Import only: No recertification is necessary to facilitate pre-PSPS charging, since the customer can already import from the grid and will not export. Export only: The PCS allows export from the storage device to the grid but prevents import from the grid for storage charging purposes. Recertification is necessary. No Exchange Mode: The PCS will not allow the battery to import from or export to the grid. The battery can only charge from the onsite PV and discharge to serve onsite load. Recertification is necessary. Unrestricted: No recertification is necessary to facilitate pre-PSPS charging. However, to maintain NEM integrity, this option is not permitted. Customers have the option to have the installer set the PCS in import-only (i.e., grid-charging) mode. D.20-06-017 Ordering Paragraph 5, which adopts the ability to switch from export-only to import-only, applies only to customers using devices that can be changed from export-only to import-only. There are currently no devices on the market that can be modified from import to export or vice versa without recertifying under the UL PCS standard. 5
Process Coordination Among Utilities, Developers, and Aggregators To mitigate compromising NEM integrity, updates to the UL CRD for PCS need to be developed by the UL PCS Working Group and approved by UL. SCE proposes the following necessary steps to allow the UL PCS Working Group to determine the appropriate updates to the UL PCS CRD standard: UL PCS Working Group to complete its recommendations. UL PCS Working Group to present its recommendations to the SIWG. UL PCS Working Group to submit PCS UL CRD changes to the UL for approval. 6
