Our Community Microgrid regulatory work
In 2018 the California Legislature passed SB 1339, with the goal of facilitating the commercialization of microgrids across the state. A proceeding at the California Public Utilities Commission (CPUC) is tasked with implementing SB 1339.
Since 2019, the Clean Coalition has been active in the SB 1339 proceeding, arguing in our filings for these elements and more:
- Creating standard tariffs for microgrids in California that:
- Properly value the resilience provided by renewables-driven microgrids, using the Clean Coalition’s value-of-resilience (VOR123) methodology.
- Provide value streams for the secondary markets that microgrids can participate in and the ancillary services microgrids provide when not in island mode. Alternatively, all the value streams can be aggregated into a single straightforward Dispatchable Energy Capacity Services (DECS) contract with a load-serving entity (LSE).
- Cover both behind-the-meter (BTM) and front-of-meter (FOM) solar+storage microgrids.
Thus far, SB 1339 has not lived up to its promise due to the conservative approach being taken by the CPUC, as we detailed in this September 2020 blog post.
The Clean Coalition has also submitted microgrid-related policy filings at the California Energy Commission (CEC).
CPUC microgrid policy filings
Microgrids for Emergency Reliability — Reply comments on the Track 4 Phase 1 proposed decision | 16 November 2021
Clean Coalition reply comments remind the Commission that the core principle of this proceeding is to increase the commercialization of microgrids and that the decision making process should continue to prioritize input from local governments and tribal communities. With that in mind, we urge the Commission to approve the Regional Microgrid Pilot Program proposed by the County of Los Angeles.
Microgrids for Emergency Reliability — Opening comments on the Track 4 Phase 1 proposed decision | 10 November 2021
Clean Coalition comments critique the Proposed Decision for ignoring the vast majority of party proposals and failing to reduce the inhibitions to the widespread proliferation of microgrids. We urge the Commission to consider the proposal made by the County of Los Angeles to deploy Critical Facility Community Microgrids and then explain why a Resilient Energy Subscription (RES) is the missing piece needed to cost-effectively expand a Community Microgrid at the cost of service.
Microgrids for Emergency Reliability — Opening comments on the Track 4 Phase 1 proposed decision | 10 November 2021
In these Joint Comments, parties lambast the Commission for taking a step in the wrong direction by approving fossil-fuel generation. In addition, comments point out the inherent cost shift in SDG&E’s proposal and decry the Commission’s choice to reject the majority of party proposals as a sign that it isn’t properly carrying out the mandate laid out in the Governor’s Emergency Proclamation.
Microgrids — Reply to Opening Comments in Response to Emergency Proclamation Proposals | 1 October 2021
In reply comments, we recommend the approval of behind-the-meter distributed generation aggregations and Community Microgrids rather than continuing to rely on temporary contracts with fossil fuel generators. Due to looming reliability concerns, we also support a relaxation of Rule 18/19 rules on private energy sharing between adjacent properties and continue to stress the importance of swift interconnection reform.
Microgrids — Opening comments in response to emergency proclamation proposals | 24 September 2021
Using examples from the VGES Front-of-Meter Energy Storage Interconnection Case Study, Clean Coalition comments underscore the need for front-of-meter interconnection reform to truly enable Community Microgrids. We also urge the Commission to consider a joint report we drafted with the Green Power Institute on Automation on the behind-the-meter interconnection process.
Microgrids — reply comments | 6 July 2021
In reply comments the Clean Coalition notes that the CPUC has not done a comprehensive analysis of the benefits a microgrid provides, nor has a study of any costs to the grid been completed. As a result, the proceeding has been needlessly limited, and while the Proposed Decision is an important step forward, it is only a portion of much broader solution necessary to overcome the barriers to the commercialization of microgrids.
Microgrids — opening comments | 29 June 2021
In these opening comments on the Proposed Decision, the Clean Coalition supports the proposed exemption for microgrids from capacity reservation charges, and urges the CPUC to take it a step further. We request that all emergency charging situations prior to widespread outages not be counted toward increased demand charges and suggest that verification of microgrids be dependent on the emissions from component resources. Comments conclude by suggesting that microgrids that export fully during the critical peak period of the day should receive a full exemption from non-bypassable charges.
Microgrid Track 3 Amended Scoping Memo and Questions — reply comments | 10 March 2021
Our comments focus on the fact that all parties agree that discussing microgrid exemptions to standby charges is premature without first quantifying the value-of-resilience (VOR). The Clean Coalition underscores the need for the Commission to approve standby-charge reform in the microgrids proceeding and calls for exemptions for small microgrids under 1 MW and critical community facility microgrids.
Microgrid Track 3 Amended Scoping Memo and Questions — opening comments | 3 March 2021
Clean Coalition comments make it clear that discussing exemptions to standby charges without defining and quantifying the grid services a microgrid can offer — resilience, in particular — makes the debate much less meaningful and granular than it otherwise would be. We argue that standby charges are outdated and the concept of the utility as the “provider of last resort” does not account for the reliable service a microgrid provides. We conclude that the Commission needs to entirely reform standby charges and that exemptions should be granted for multiple different types of microgrids, including critical community facility microgrids, microgrids that provide grid services, and microgrids completely disconnected from the grid.
Proposed Decision Directing PG&E, SCE, and SDG&E to Seek Contracts for Additional Power Capacity for Summer 2021 — reply comments | 2 February 2021
In reply comments, the Clean Coalition aligns with party positions arguing that this proceeding should be used to set the stage for long-term solutions deployed in 2022, 2023, and beyond. While we still push for the necessary prioritization of energy storage, we suggest that the Commission tie energy storage together with other renewable resources in the optimal configuration, a series of Community Microgrids. Comments include Clean Coalition analysis showing that Community Microgrids are a more economical investment than gas peaker plants.
Proposed Decision Directing PG&E, SCE, and SDG&E to Seek Contracts for Additional Power Capacity for Summer 2021 — opening comments | 28 January 2021
Clean Coalition comments request that the Commission prioritize the procurement of energy storage over any investments in fossil fuel generation. We argue that energy storage is dispatchable and offers other benefits to the electrical system — resilience, a reduction in greenhouse gas emissions, and lower demand during peak hours — that fossil fuel generation cannot compete with.
Microgrid Track 2 Proposed Decision Comments — reply comments | 4 January 2021
In this reply to opening comments, we agree with parties that the Commission should make a strong statement to the legislature about the need to change the over-the-fence rule (section 218(b) of the Public Utilities Code). We also concur with the Microgrid Resources Coalition about the need for clarify foundational definitions such as “commercialization” and “cost-shifting,” adding the “value of resilience” as another phrase that will change the outcome of the proceeding. We end with a request that the Commission further discuss the value of microgrid grid services and specify some of the unintended consequences that caused them to limit proposals during Track 2.
Microgrid Track 2 Proposed Decision Comments | 28 December 2020
Clean Coalition comments open with a strong critique of the Commission for rushing Track 2 of the proceeding, ultimately culminating with a Proposed Decision that does not achieve any of the goals listed in SB 1339 — commercializing microgrids and reducing greenhouse gases — and that does not even attempt to quantify the value-of-resilience (VOR). We make a number of suggestions, including calling for all critical facilities to be eligible for the Rule 18/19 exemption, asking for microgrid grid services and resilience to be valued in a microgrid rate schedule, and requesting that the utilities be held to a stricter standard for transitioning to renewable microgrids for substation-level backup power.
Policy Questions on an Interim Approach for Minimizing Emissions from Generation during Transmission Outages | 25 September 2020
The Clean Coalition lambasts the Commission for waiting to take action on the issue of substation backup power until August 2020, defaulting to the use of diesel fuel for 2021 after explicitly stating only three months earlier that it would only be acceptable for use in 2020. Instead of diesel fuel as a primary energy source, Solar Microgrids should be installed with diesel fuel as a secondary backup, to be disconnected as more PV resources are aggregated. Solar+storage resources provide everyday power and grid services that fossil fuel resources cannot, making them much more cost-effective in the long term.
Community Microgrid Enablement Program | 8 September 2020
The Clean Coalition response supports PG&E’s Community Microgrid Enablement Program, lauding PG&E for taking a role as a community partner to deploy Community Microgrids. The program creates a framework that allows communities to identify their resilience needs, promoting the inclusion of as many customers as possible that can be supplied with 20 MW of renewable resources. The filing concludes with a few Clean Coalition recommendations to increase transparency for the benefit of local governments.
Microgrid Track 2 — reply comments | 28 August 2020
Parties, including the Clean Coalition, consider the lack of focus in Track 2 on Community Microgrids and the need for a full microgrid compensation tariff to consider normal instances when a microgrid is not in an islanded mode. Comments strongly address the conservative nature of the proposals in the Staff Proposal, lambasting the Commission for slowing the pace of progress by delaying the definition for a value of resilience and failing to value the public benefit it provides.
Microgrid Track 2 comments | 14 August 2020
The Clean Coalition comments focus on criticizing the Staff Proposal for the lack of a standard microgrid tariff, including any type of discussion on resilience and the Value of Resilience. Before getting to the Staff Proposal, the comments note the complete absence of logic in choosing to include a detailed concept paper and then not allow any comments on the Concept Paper into the record for Track 2. For the five proposals, the Clean Coalition supports ambitious positions that enable Community Microgrids and Feed-In Tariff-like pilot programs rather than the Commission’s typical conservative steps that kick the can further down the road.
Microgrids and strategies for valuing resilience – reply comments | 26 May 2020
This filing represents the Clean Coalition’s support of requests from other parties, primarily related to issues surrounding utility transparency with the CPUC and other stakeholders, for assurances that fossil fuel generation is temporary and will be transitioned into renewable resources, including proposals to expedite microgrid interconnection.
Microgrids and strategies for valuing resilience | 19 May 2020
This filing represents the Clean Coalition’s argument that PG&E (or any other IOU) installing natural gas generation for resilience should be required to submit a plan detailing a transition to DER and solar+storage microgrids within five years. We promote proposals to expedite interconnection, although we lambast the CPUC’s lack of interest in smart metering. The Clean Coalition also applauds decisions to remove energy storage sizing limits, though we request that the CPUC requires islanding — either in this track or in track 2. Our comments also focus on ensuring that this Proposed Decision promotes progress, not more of the business-as-usual approach by utilities and policymakers; to that end, we request that the Proposed Decision is modified to ensure that the CPUC considers key details (like the value of resilience) and promotes transparency in information sharing between IOUs and key stakeholders.
Proving microgrid resilience benefits – reply comments |6 February 2020
This filing represents the Clean Coalition’s reply to the staff and investor-owned utility (IOU) proposals on short-term resilience strategies. The Clean Coalition’s comments prioritize holding the IOUs accountable by tracking the total cost of fossil-fuel generation (proving that renewables-driven microgrids are a more effective solution), sharing information with local agencies, annual verification reports, and pushing for a more widespread deployment of smart meters with islanding capabilities across IOU service territory.
Proving microgrid resilience benefits | 30 January 2020
This filing represents the Clean Coalition’s reply to the CPUC administrative law judge’s questions about the staff and investor-owned utility proposals for microgrid resilience strategies. Our comments lambast the potential use of fossil-fuel generation near substations and prioritize DER generation, along with an increase in grid isolation switches, and we illustrate effective use of data sources to map priority microgrid siting. The Southern California Edison proposal includes a portion in Montecito, so our comments use the Montecito Community Microgrid Initiative and greater Goleta Load Pocket area to demonstrate the resilience that a true Community Microgrid can bring and a few of the policies inhibiting them from being built.
Valuing resilience with Community Microgrids – reply comments | 4 November 4 2019
This filing represents the Clean Coalition’s reply comments on the opening comments made by 36 parties about the Preliminary Scoping Document for Rulemaking 19-09-009. The Clean Coalition called for a focus on Community Microgrids and focused on comments by parties explaining that they are an important alternative to expanding the transmission system for the sake of grid hardening and provide both baseload and backup power for a community. We recommended that based on the consensus about the importance of Community Microgrids as a resilient solution, an essential part of this proceeding must be to create a standard value of resilience. These comments were made regarding California Microgrid Bill SB 1339.
Valuing resilience with Community Microgrids | 21 October 21 2019
This filing represents the Clean Coalition’s opening comments advising the CPUC to focus the upcoming proceeding on Community Microgrids, with a focus on the Goleta Load Pocket as the ideal location for a pilot program. We recommended the CPUC properly value resilience by using VOR123 as well as implementing a Feed-In Tariff mechanism, with Market Responsive Pricing and a Dispatchability Adder (DECS), to streamline the procurement of renewable resources for Community Microgrids. These comments were made on the Order Instituting Rulemaking (OIR) Regarding Microgrids Pursuant to SB 1339.
CEC microgrid policy filings
Research on Valuation of Investments in Electricity Sector Resilience — Written comments for the docket | 19 November 2021
Clean Coalition comments urge the Energy Commission to consider our value-of-resilience (VOR) methodology, VOR123, and Resilient Energy Subscription (RES) market mechanism in its research on the valuation of investments in electricity sector resilience. VOR123 and RES will provide a pathway to the widespread deployment of Solar Microgrids and Community Microgrids, as well as helping to finance and expand Community Microgrids.
IEPR comments | 30 July 2020
In this comment letter, the Clean Coalition advocates that the CEC develop a Community Microgrid pilot in a comprehensive grid area or on a substantial feeder (containing critical facilities). A CEC-sponsored Community Microgrid pilot will run in parallel with the CPUC microgrid proceeding, forcing the CPUC to consider current market distortions, including the assessment of Transmission Access Charges (TAC) and the lack of a standard value-of-resilience. The Clean Coalition offers the Goleta Load Pocket as an ideal location for the siting of a Community Microgrid pilot.
Climate adaptation and the Clean Coalition’s work | 27 November 2019
This filing represents the Clean Coalition’s comments on the CEC’s Integrated Energy Policy Report Workshop on Climate Adaptation. The Clean Coalition appreciates the focus on supporting microgrids with DER for critical facilities and believes it is crucial for the IEPR to consider measures needed to proliferate Community Microgrids in California. This proliferation can be ensured by reforming the way Transmission Access Charges (TAC) are assessed, divesting the IOUs of their transmission assets, streamlining interconnection for wholesale distributed generation (WDG), establishing effective procurement methods like a market-responsive Feed-In Tariff (FIT), and standardizing a value-of-resilience for all electric loads (VOR123).
See all Clean Coalition regulatory filings
