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1. a dures 9 0 lt 02 WIN NEM Interconnection Handbook February 2014 v 5 0 Appendix C Inverter Settings Request Company Logo Friday November 05 2010 SCE Project NM Inverter Model These settings apply to the following Serial Numbered Inverters 1234 56789 9876 54321 amp 4561 23789 Project Location Address Enter Address Here Base Voltage Nominal voltage Table 1 Voltage Trip Settings Description Actual Level Actual Time Extreme Under Voltage 5 or cycles Under Voltage 5 or cycles Extreme Over Voltage 5 or cycles Over Voltage 5 or cycles Under Frequency Hz 5 or cycles Over Frequency Hz 5 or cycles Best regards Signature of representative Manufacture Representative Manufacture Contact Information R 850 V5 0414 Appendix B 27 27 NEM Interconnection Handbook February 2014 v 5 0 Appendix D Maximum Borderline of Irritation Curve VOLTAGE FLUCTUATION DESIGN LIMITS SOUTHERN CALIFORNIA EDISON COMPANY CRITERIA MAY 1994 IN tN PERCENT VOLTAGE SAG oats TT eS CRS ______ 21 10 1 10 20 30 1 2 5 1 SAGS PER DAY SAGS PER HOUR SAGS PER MINUTE SAGS PER SECOND FREQUENCY OF SAGS R 850 V5 0414 2 8 Appendix B 28 NEM Interconnection Handbook
2. 07 22 2014 15 SCE s Schedule NEM defines Relevant Period as A twelve month period or portion thereof commencing on the anniversary Date of Final Interconnection of the customer s generator to SCE s electric system and on every subsequent anniversary thereof 16 A negative number indicates that the generating facility is generating net surplus kWh 17 The reflects that the prior Relevant Period just completed and data is yet available for the current Relevant Period 18 The reflects that the prior Relevant Period just completed and data is yet available for the current Relevant Period 19 The n a reflects that this meter has not yet completed a full Relevant Period 10 65911 12 11 2013 20 12 11 2013 2732 TwentyNine Palms to 07 22 2014 65911 12 11 2013 21 12 11 2013 3824 TwentyNine Palms to 07 22 2014 Each location that states negative energy usage demonstrates that the generating facility is currently producing net surplus kWh 3 Flaws Relating to Daniel Davis Analysis of Inverter Efficiency The testimony of Daniel Davis reflects a flawed critique of the Inverter Efficiency variable as it is used in Formula No 1 Daniel Davis incorrectly alters this variable changing it from inverter efficiency to system efficiency Daniel Davis s testimony states the following Mr Davis s
3. Generating Facilities operating in parallel with SCE s Distribution system shall be equipped with the following Protective Functions to sense abnormal conditions on SCE s Distribution System and cause the Generating Facility to be automatically disconnected from SCE s Distribution System or to prevent the Generating Facility from being connected to SCE s Distribution System inappropriately Over and under voltage trip functions and over and under frequency trip functions Avoltage and frequency sensing and time delay function to prevent the Generating Facility from energizing a de energized Distribution System circuit and to prevent the Generating Facility from R 850 V5 0414 2 1 Appendix B 21 NEM Interconnection Handbook February 2014 v 5 0 reconnecting with SCE s Distribution System unless SCE s Distribution System service voltage and frequency are within normal operating limits and are stable for at least 60 seconds A function to prevent the Generating Facility from contributing to the formation of an Unintended Island and cease to energize SCE s Distribution System within two seconds of the formation of an Unintended Island Island Islanding A condition on SCE s Distribution System in which one or more Generating Facilities deliver power to customers using a portion of SCE s Distribution System that is electrically isolated from the remainder of SCE s Distribution System Generating Facility sha
4. s testimony incorrectly presumes the full DC output generated by the 60 panels is processed by the inverter It is not The Testimony of Edward Soler Jr attached a PV Inverter Sunny Boy Installation Manual which Mr Soler asserts is the manufacturer s data sheets for the SMA SB5000 US inverter 23 If it is assumed that this is the user manual for Mr Davis s 5 kW inverter then the Technical Data sheet within that manual states that the maximum DC power processed by Mr Davis s inverter is 5300 W 24 Accordingly any additional watts beyond the 5300 W is not processed by the inverter in order to manage the AC output to its targeted 5000 W The inverter efficiency is not reduced in the manner Daniel Davis describes Daniel Davis s formula is also flawed because it relies on the PTC rating for the wrong solar panel It assumes the use of Schott 230 solar modules 25 However David Davis s interconnected generating facilities utilize Schott Poly 225 solar modules In addition both the David Davis and Daniel Davis testimonies fail to address the applicability of the NEM Handbook Formula No 2 or the appropriate input for the Inverter Efficiency under that formula which takes into account more specialized consideration of the location and configuration of the proposed facility 26 4 Davis Is Seeking a Policy Change The David Davis and Daniel Davis testimonies do not demonstrate that SCE has incorrectly applied the Inv
5. 6 65911 Twentynine Palms Hwy 7 gt SCE s Tariff Rule 1 Definitions at Sheet 3 34 Mr Davis is also the customer on the NEM Interconnection Agreements for these locations that were entered into with SCE 18 20 21 22 23 e 65911 TwentyNine Palms Hwy 8 e 6804 Park Blvd e 6804 Park Blvd 1 e 6804 Park Blvd 2 e 6804 Park Blvd 3 e 6804 Park Blvd 4 6807 Park Blvd e 6815 Park Blvd 61736 Onaga Trail Pursuant to Rule 1 regardless of the actual user of the service the load registered on the applicable meters is considered Mr Davis s responsibility since service is rendered in his name Therefore SCE believes that it appropriately allowed Mr Davis to use the load registered on the meters that are in his name for which he is financially responsible as his own electrical requirements for the purposes of participating in the NEM program which is consistent with how SCE applies these requirements to its other customers 35 SCE s Tariff Rule 18 Supply to Separate Premises and Use By Others governs how Mr Davis is to charge his tenants for the electricity that is registered on meters that are in his name Specifically Rule 18 Section E 2 states in part that A customer shall not charge for electricity received from SCE and used by another person except Where the charge to domestic or nondomestic tenants is absorbed in the rental for the Premises or space occupied is not separ
6. All Eligible Customer Generators seeking to interconnect a Renewable Electrical Generating facility to SCE s electric system must first complete an application for interconnection SCE s Form 14 753 Application for Net Energy Metering of a New Solar Wind or Fuel Cell Generating Facility of Not More Than 10kW Under NEM Rate Schedule is the applicable interconnection application for most generating facilities sized 10 kW and smaller which necessarily encompasses systems that are sized smaller than 5 kW The Applicability section of this application informs Eligible Customer Generators that their generating facilities must operate in parallel with SCE s electric system for the purpose of offsetting part or all of the eligible customer generator s own electrical requirements The last section of this application captioned Qualified NEM Generating Facility requires all Eligible Customer Generators to provide information so that SCE can calculate the estimated monthly kWh production of the generating facility Nowhere in the NEM Application is there a differentiation or distinction made in regards to the NEM sizing requirements based on whether a system is sized smaller or larger than 5 kW SCE NEM Handbook Further SCE publishes the NEM Handbook included herein as Appendix B to specify the minimum requirements necessary to interconnect a generating facility to SCE s electrical system SCE first published the Handbook in Octobe
7. February 2014 v 5 0 SOUTHERN CALIFORNIA Appendix E Supply Side Line Side connections EDISON To SCE Project SCE has received the application fora ___ solar generating facility located at The single line for the proposed project indicates that the proposed method of interconnection to the SCE system is to connect the generating facility to the source side of the existing customer s main breaker Line Side Tap This proposed method of interconnection requires the existing interconnecting switchgear equipment busses connectors termination points etc to be modified in order to connect the generation on the source side of customer s main circuit breaker Such modifications could compromise the UL certification of the existing switchgear and could compromise the ratings and withstand capabilities that the switchgear was originally designed for SCE strongly encourages the customer to modify its proposed method of interconnection and interconnect the generating facility to the load side of the main circuit breaker in accordance with the original intent of the existing switchgear SCE considers the project s proposed method of interconnection to be a potential safety issue because of the modification of the switchgear To ensure that the project s interconnection facilities meet SCE s safety requirements SCE must receive verification of UL compliance for the modifications to the existing switchgear This can be accomplished
8. L of Rule 21 PDF as tested by a nationally recognized testing laboratory NRTL acceptable to SCE with the test reports acceptable to IEEE 1547 Rule 21 PDF and SCE additional protection requirements and testing may be required Inverters listed in the following lists have met UL 1741 and IEEE 1547 standards Underwriters Laboratories Standard UL 1741 certification or Section L of Rule 21 PDF as tested by a nationally recognized testing laboratory acceptable to SCE and the test reports must have been approved by SCE The California Energy Commission maintains a certified list of approved inverters at www consumerenergycenter org erprebate inverter php If one of these inverters is used the application process is greatly simplified and expedited If not the customer may be required to provide additional details and the utility may need to perform additional studies to determine how the proposed system will perform under fault conditions and prevent islanding Note SCE may require additional testing for a single installation of multiple CEC approved inverter units To be eligible for CSI credits the inverter must be listed at http www csi epbb com R 850 V5 0414 1 1 Appendix B 11 NEM Interconnection Handbook February 2014 v 5 0 Separate single unit or multiple unit inverters that do not meet UL 1741 certification or have not been adequately tested will not be granted commercial operation status a
9. One of the requirements for all Eligible Customer Generators is that the customer s Renewable Electrical Generating Facility be intended primarily to offset part or all of the Customer s own electrical requirements 22 Further Special Condition 6 f of Schedule NEM which addresses generator size states that Nothing in this Special Condition alters the existing NEM system sizing requirements and limitations To be eligible for NSC a system must meet the definition of an eligible customer generator within Section 2827 b 4 including that it be intended primarily to offset part or all of the customer s own electrical requirements Systems that are sized larger than the customer s electrical requirements are not eligible for NEM and therefore are not eligible for NSC 32 Nowhere in the NEM tariff is there a differentiation or distinction made in regards to the NEM sizing requirements based on whether a system is sized smaller or larger than 5 kW Because all proposed NEM generating facilities must be sized to offset the customer s own electrical requirements SCE believes that it is allowed to request information from any Eligible Customer N 29 SCE s Tariff Schedule NEM at Sheet 13 30 14 at Sheet 14 15 20 21 22 23 24 Generator regardless of the size of the proposed generating facility to help ensure compliance with its CPUC approved tariffs and statutory requirements SCE NEM Application
10. PROPOSED NEM GENERATING FACILITY EVEN IF THE SYSTEM IS SIZED SMALLER THAN 5 15 Pulgar IF DAVIS INSTALLS SOLAR PANELS PROPERTIES HE RENTS TO TENANTS RESULTING IN ELECTRICITY USED NOT BY DAVIS BUT BY HIS TENANTS THE INSTALLATION MAY STILL OFFSET CUSTOMER S OWN ELECTRICAL REQUIREMENTS SUCH THAT THE PROJECT CAN QUALIFY FOR NEM UNDER 2827 B 4 c cccsssssssessseessecesssssseesssseeesueesseess 18 VI IF DAVIS INSTALLS A SOLAR PV SYSTEM AT HIS HOME AND ALLOWS NON RESIDENTS TO USE THE ELECTRICITY GENERATED BY THIS PV SYSTEM THAT USE MAY COUNT AS PART OF CUSTOMER S OWN ELECTRICAL REQUIREMENTS FOR PURPOSES OF NEM ELIGIBILITY 21 SCE 01 REPLY TESTIMONY ON PHASE I ISSUES Table Of Contents Continued OTHER SAFETY CONSIDERATIONS RAISED THESE CONSOLIDATED 5 2 2 25 Patel Appendix Witness Qualifications Appendix B Net Energy Metering Interconnection Handbook Version 5 0 Effective Date February 2014 4 5 1 INTRODUCTION This reply testimony responds to the issues presented in testimony by Edward Soler Jr David Davis Daniel Davis as well as issues identified in the May 28 2014 Assigned Commissioner s and Administrative Law Judge s Scoping Memo and Ruling Scoping Ruling Specifically this reply testimony addresses the following Phase 1 issues
11. attachments up to 7 if the total size of attached files exceeds 7 MB please submit them in multiple emails adding the following to the subject lines part 1 of 2 part 2 of 2 etc Signed Interconnection Agreements can be submitted digitally for Form 14 933 and 16 344 However originals of customer signed Agreements for Schedules FC NEM PDF NEM V PDF and MASH VNM PDF must be submitted via mail to Southern California Edison Attention NEM Program P O Box 800 Rosemead CA 91770 2 2 Reference Information Certified Equipment Listings For CEC certified equipment list the manufacturer model number rating voltage and other required information on the Application and Single Line Diagram exactly as shown at the following on line resources Table 2 2 1 CEC Certified Equipment Listings Equipment Certified Listings Inverters Solar http www csi epbb com default aspx Wind Fuel Cell http www consumerenergycenter org erprebate inverter php Solar PV Modules http www csi epbb com default aspx Wind Turbines http www consumerenergycenter org cgi bin eligible_smallwind cgi Fuel Cells http www consumerenergycenter org erprebate eligibile_fuelcells html R 850 V5 0414 6 Appendix B 6 NEM Interconnection Handbook February 2014 v 5 0 NOTE The certification listings above identify some of the electrical components generating facility These components must be incorp
12. 1 Must a generating facility be sized greater than its associated premises annual load to receive CSI incentives Can the annual estimated generation for purposes of NEM generating facility size requirements be calculated using the manufacturer s inverter efficiency rate for situations involving high panel to inverter ratios Can a load justification be required for a proposed NEM generating facility if the system is smaller than 5 kW If Davis installs solar panels at properties he rents to tenants resulting in electricity used not by Davis but by his tenants does the installation still offset customer s own electrical requirements such that the project can qualify for NEM under 2827 b 4 If Davis installs a solar PV system at his home and allows non residents to use the electricity generated by this PV system does that use count as part of customer s own electrical requirements for purposes of NEM eligibility See Scoping Ruling at pp 12 13 July 1 2014 ALJ Email Ruling Parties are instructed to include evidence related to Issue Nos 1 2 and 3 in their written testimony In their testimony parties should clearly explain the facts of the case necessary to support the arguments they intend to make in their briefs Parties are not required to file additional legal briefs on the 3 legal issues but parties may elect to address the legal issues again in briefs filed after the evidentiary hearin
13. 1 MW To deliver incidental power to the grid a customer s generating system must be located on the customer s premises and be interconnected to SCE s electrical system i e permanently connected to allow parallel operation with the utility grid Note for standby and back up generators not permanently connected to SCE s electrical system please refer to the notice requirements defined in Section 5 8 R 850 V5 0414 5 Appendix B 5 NEM Interconnection Handbook February 2014 v 5 0 2 Reference Information Please visit http www sce com nem e For more information about the NEM Program NEM Rate Schedules and review process e download checklists applications sample Single Line Diagrams and Plot Plan NEM Interconnection Agreements e Technical requirements for interconnection under Rule 21 PDF e read Frequently Asked Questions and Tips to Speed through Interconnection 2 1 Document Requirements At http www sce com nem SCE provides checklists listing all the required documents for NEM Interconnection as well as all the required forms along with mark ups and sample Single Line Diagram and Plot Plan for download The NEM Interconnection review process is entirely paperless for solar and wind projects NEM Interconnection application documents should be submitted to the NEM Interconnection team via email to customer generation sce com or via fax to 626 571 4272 Note SCE can accept email
14. 23 77 5 2 23 Appendix A Sample Single Line 25 B Sample 26 Appendix Inverter Settings 27 Appendix D Maximum Borderline of Irritation 001 28 Appendix Supply Side Line Side 928 29 Appendix Vendor Decal instructlons 31 R 850 V5 0414 Appendix B 4 NEM Interconnection Handbook February 2014 v 5 0 1 Overview A generating facility may not be operated in parallel with SCE s Distribution facilities UNTIL PERMISSION TO OPERATE IS GRANTED BY SCE as required in Electric Rule 21 PDF Unauthorized operation may result in personal injury equipment damage and or property damage for which the customer may be liable This NEM Interconnection Handbook specifies the typical minimum technical requirements to interconnect generating facilities with SCE s electric system under the Net Energy Metering NEM program These requirements are necessary to ensure safe and reliable operation of SCE s electric system These requirements apply to interconnection of a generating facility to SCE s electrical distribution system through the NEM program under the following SCE rate schedules Schedule NEM PDF Net Energy
15. 3 Appendix Shift decal and picture requirement to beginning of the interconnection application process to reduce technical review time frame Section 5 5 Clarify wiring instructions for Net Generator Output Meter NGOM R 850 V5 0414 Appendix B 2 NEM Interconnection Handbook February 2014 v 5 0 Contents 1 OVERNMVIEW titrant ivi rasta 2 1 Document israse ei enaa inaen i 2 2 Reference INFOMATION Table 2 2 1 CEC Certified Equipment 2 a Table 2 2 2 CEC AC Nameplate Calculation for Inverter based Generation Table 2 2 4 Estimated Monthly kWh Calculation 2 Interconnection REVIEW PROCESS 3 1 DOCUMENT REVIEW 3 2 COMMISSIONING Aes ead SAG RRM UR Re 3 3 Interconnection 5 1 4 3 4 6 tay exces A Operating 4 1 Normal Voltage Operating 4 1 1 Limits Specific
16. Appendix 3 22 Commissioning Test SCE intends to conduct a commissioning test and onsite inspection for as many sites as possible Currently all projects greater than 10 kW are subject to a commissioning test while projects less than 10 kW are evaluated on a case by case basis When a commissioning test is required a representative of the installer qualified to operate the equipment must be present Before a commissioning test will be scheduled SCE requires a copy of an Electrical Inspection Release from the appropriate Authority Having Jurisdiction e g final inspection job card from the local building and safety department to ensure that the work on the customer s side of the meter has been permitted meets the requirements of the National Electric Code applicable local codes and ordinances and is therefore safe to energize The onsite inspection will ensure that the installation reflects what is shown on the single line diagram and documents provided by the applicant on the generating facility Rule 21 Section H voltage and frequency requirements will be tested and verified during the commissioning test Regardless of the results of the onsite inspection and commissioning test the customer may not energize the system until SCE issues a Permission to Operate PTO letter 3 3 Interconnection Study If during the course of the initial and supplemental reviews it is determined that an interconnection study is required SCE will det
17. CB in the metering enclosure b Generating facilities that are proposing to connect to the source side of the CB when allowed When customers do not agree on facility outage when required to disconnect the generator from the distribution system Reference SCE s Electrical Service Requirements for information on Self Contained Meter R 850 V5 0414 1 4 Appendix B 14 NEM Interconnection Handbook February 2014 v 5 0 Step 2 SCE to remove the Meter for isolation MainCB gt Step 1 Customer Open Main CB 3 SCE Secondary Service cable Generating Facility Typical self contained meter per SCE s Electrical Service Requirements Figure 1 Typical self contained meter system 5 2 4 Non Self Contained Meter Secondary Voltage Connection These generation facilities cannot be disconnected by simply removing the revenue meter as the metering is achieved by current transformers CTs Refer to figure 1 2 for typical installation These types of installations are typically utilized for medium sized commercial or industrial customers For these types of systems the following are the disconnect device requirements 1 Must comply with Rule 21section H 1 d Visible Open Disconnect Requirement and SCE s Interconnection Handbook section 5 11 1 Manual disconnect 2 One single disconnect is to be used to disconnect all generation at a facil
18. Metering Schedule FC NEM PDF Fuel Cell Net Energy Metering Schedule NEM V PDF Virtual Net Metering Schedule MASH VNM PDF Multi family Affordable Solar Housing Schedule BG NEM PDF Biogas Net Energy Metering Note per CPUC 2827 9 biogas digester generators must have commenced operation by December 31 2009 to be eligible for the program This handbook does not address other types of generator interconnections under Rule 21 PDF or the Wholesale Distribution Access Tariff WDAT PDF Note Schedule RES BCT PDF Renewable Energy Self Generation Bill Credit Transfer is addressed under Rule 21 For technical requirements for interconnection under Rule 21 PDF or WDAT please refer to SCE s Interconnection Handbook PDF Under the Net Energy Metering program CPUC 2827 customers installing generating facilities are eligible to interconnect if the generating facility is located on the customer s premises generates electricity from a renewable source pursuant to paragraph 1 of subdivision a of Section 25742 of the Public Resources Code i e biomass solar thermal photovoltaic wind geothermal fuel cells using renewable fuels small hydroelectric generation digester gas municipal solid waste conversion landfill gas ocean wave ocean thermal or tidal current fuel cells or biogas or a hybrid of these technologies and is sized to offset all or part of the customer s electrical requirements to
19. PG amp E uses a similar formula CEC AC rating x 8 760 hrs yr x 19 See AGREEMENT AND CUSTOMER AUTHORIZATION Net Energy Metering Interconnection For Solar And Or Wind Electric Generating Facilities Of 30 Kilowatts Or Less Form 79 1151A Advice 4369 E PG amp E s formula calculates the number of hours in a year as opposed to the number of hours in a month PTC is an acronym for PVUSA Test Conditions This is a standardized set of testing conditions that are used to evaluate the performance of a particular model of solar panel 10 This published data can be found at the Go Solar California website at http www gosolarcalifornia ca gov equipment pv_modules php last visited August 1 2014 The modules are also required to have an ANSI UL1703 safety certification issued by a Nationally Recognized Testing Laboratory NRTL 20 21 equipment an applicant must list inverter technical information consistent with the test data maintained and published by the CEC This CEC data reflects a weighted average of the inverter efficiency for a particular model of inverter This weighted average reflects a particular model s performance during different standardized measurements tested by a Nationally Recognized Testing Laboratory NRTL Such measurements include testing at different input voltage input current input power output voltage output power ambient temperature and inverter temperature at heat s
20. enclosures and raceways on the line side unmetered or housing metering equipment shall be sealable Meter seals shall not be broken by anyone except an authorized SCE employee Per ESR 6 Section 1 0 pp 6 5 conductors shall not be rerouted through any metering compartment Fused and unfused conductors shall not occupy the same raceway unless they are completely barriered from each other in a manner acceptable to SCE Per ESR 6 Section 5 0 Figure 6 8 pp 6 20 except for conductors supplying the instrument transformer compartment and the ground bus no other conductors or devices shall be installed in or routed through the compartment or the sealed area above the compartment The ground bus shall not infringe on utility compartment space or reduce any clearances Customer connections to the ground bus shall be allowed in the instrument transformer compartment 5 2 1 Visible Open AC Disconnect Switch requirements for generation interconnection to distribution voltages 34 5KV or below3 Per SCE guidelines a visible open lockable AC Disconnect is required for all of the following aggregate generating facilities All Commercial All Residential Non Self Contained Meters All Line Side Taps additional overcurrent protection required Refer to Rule 21 Section H 1 d and SCE s Interconnection Handbook PDF for Visible open Disconnect requirements 5 2 2 Disconnects must be reviewed and approved by Field Engineering Locatio
21. in the following ways 1 of the attached verification signed by the inspecting authority acknowledging the following 1 that the existing customer switchgear has been altered to allow the interconnection of the generating facility to the source side of the customer s main breaker and 2 that the altered customer switchgear continues to meet UL certification requirements or that the modified equipment has been recertified for its new configuration 2 A document from the manufacturer of the existing panel indicating that the proposed modification or connection to the source side of that panel does not compromise the UL rating of the panel 3 AULcertification of the proposed modification or connection to the source side of the main circuit breaker of the existing panel SCE must receive one of these verifications before it will approve the generating facility for interconnection to SCE s distribution system via the source side of the existing customer s main breaker Line Side Tap It should be noted that in addition to the requirements above the customer must comply with existing requirements including a P E stamped Single Line plot plan equipment requirement etc Southern California Edison Friendly Field Engineer 909 555 5555 Friendly engineer sce com R 850 V5 0414 2 9 Appendix B 29 NEM Interconnection Handbook February 2014 v 5 0 Return to Southern California Edison Friendly Field Engineer 909 555
22. intent is to have the ability to remove the generation from SCE s distribution system so that SCE personnel may work on the distribution system safely To this extent SCE and the customer can agree to use the customer s main rackable breaker to provide the disconnecting means when it is necessary to remove the generation from the SCE s distribution system The following are the requirements 1 Facility must have a main breaker that can be opened and racked out by the customer a SCE s clearance policies can take a clearance to a customer CB when SCE can take control over the CB This would be accomplished by witnessing that the CB was racked out and by applying SCE s lock and tagging procedures 2 Customer must agree that when necessary to disconnect the generating facility by opening and racking out the CB the customer will also experience an outage to the customer s facility a Customer must provide a letter on their company letterhead stating agreement with this concept Restrictions For the facilities or the conditions below the option of using the main breaker for purposes of disconnecting the generation facility is not available and the customer must install a visible open and lockable disconnect as required by Rule 21 and SCE s Interconnection Handbook near the PCC and ona single disconnecting device a Facilities that do not have a main CB that is capable of being racked out R 850 V5 0414 1 6 Appendix B 16 NEM I
23. registered on those accounts is appropriately considered the customer of record s i e Mr Davis own electrical requirements for the purposes of participating in NEM 37 SCE notes that Schedule D does not contain Demand Charges Under Schedule D customers responsible for kWh energy charges based on a tiered rate structure and a Basic or Minimum Charge For instance the Basic Charge for a Multifamily Accommodation is 0 024 meter day or 0 72 meter month based on a 30 day billing period 20 20 21 22 23 VI IF DAVIS INSTALLS A SOLAR PV SYSTEM AT HIS HOME AND ALLOWS NON RESIDENTS TO USE THE ELECTRICITY GENERATED BY THIS PV SYSTEM THAT USE MAY COUNT AS PART OF CUSTOMER S OWN ELECTRICAL REQUIREMENTS FOR PURPOSES OF NEM ELIGIBILITY For the purpose of this response SCE answers assuming that Mr Davis intends to allow non residential third party electric vehicle EV charging usage to register on his home s Domestic Service meter to which a Renewable Electrical Generating Facility would be installed under Schedule NEM to help offset the costs of EV charging 28 As a threshold matter Mr Davis can power his EV charger in a variety of ways For example he can supply power to it from an isolated generating facility 1 neither the generating facility nor the fast charger will operate in parallel with SCE s distribution system Alternatively Mr Davis can elect to utilize the fast charger by receiving ser
24. system is extremely inefficient Even assuming his testimony is correct Mr Davis concedes that the overall efficiency of the system he proposes would only output 40 9 percent of the DC power produced by the solar panels If Mr Davis did not overload the inverters with such a large number of panels the proposed facility would not waste as much energy However Mr Davis s proposed overloading of the Sunny Boy inverters located at the properties described in Section IV A 2 remains hypothetical 14 16 17 18 19 20 21 22 23 24 25 IV SCE MAY REQUIRE LOAD JUSTIFICATION FOR A PROPOSED NEM GENERATING FACILITY EVEN IF THE SYSTEM IS SIZED SMALLER THAN 5 KW SCE may require load justification for a proposed NEM generating facility even if the system is sized smaller than 5 kW be eligible for NEM a proposed generation facility must be intended primarily to offset part of all of the customer s own electrical requirements SCE understands that it is obligated to ensure that NEM customers satisfy the sizing requirements applicable to all eligible customer generators regardless of system size as set forth in SCE s NEM Tariff SCE s NEM Application and SCE s NEM Handbook SCE NEM Tariff SCE s NEM tariff is only applicable to Eligible Customer Generators as the term is defined in both Public Utilities Code Section 2827 b 4 A and Special Condition of SCE s Tariff Schedule NEM Schedule NEM
25. the customer side of the main circuit breaker does not require a Net Generation Output meter and is the sole generator onsite no backup systems no battery backup systems etc Unintended Island The creation of an Island usually following a loss of a portion of SCE s Distribution System without the approval of SCE Visible Open Visible means visible break when the disconnect is in the open position there is a visible separation between the contacts and the separation may be observed without disassembling the device Typically this switch contains visible blades inside an enclosure an external lever and a positive indication that the switch is in the off position see Section 5 3 Manual Visibly Open and Lockable AC Disconnect Switch R 850 V5 0414 2 4 Appendix B 24 62 8 xIpueddy lt 098 4 5539049 IWIN 2237099 __ l 140530 WIS WYSOVId INIT ONIMVAC a ar ams os E E S3LON GO 333 ONLLVS 232 X 537000 waaa un NOILVWAOANI WSLSAS WAN 8 O S A 4 WIN 9 9 xIpueddy 9 lt 098 4 1227 221 475 325 5529009 IWYN LOW ead 0 002 1 TWIS 2574 FOVTEYIA LNINIIV Td JIVNIIS 210 SNOTLVIGT 2207 INVII 707 325 1517 SNOILLVLIWIT 552229 1517
26. to Single Phase Generating 4 1 2 Limits Specific to Three Phase Generating 5 sees 5 1 WAVE OT 5 2 SINGS WINE 5 2 1 Visible Open AC Disconnect Switch requirements for generation interconnection to distribution voltages 34 5KV DelOW 5 2 2 Disconnects must be reviewed and approved by Field Engineering Location of AC 915 sia 5 2 3 Self Contained Meter with one main switch Figure 1 Typical self contained Meter 5 2 4 Non Self Contained Meter Secondary Voltage Figure 2 Typical non self contained meter switchgear 5 2 5 Primary Service Voltage Figure 3 Typical high voltage service 5 2 6 PlOt Pla 5 2 7 Circumstances when AC Disconnect be Opened by 5 R 850 V5 0414 Appendix B 3 NEM Inte
27. 5555 Friendly engineer sce com City Authority Having Jurisdiction SCE Project I hereby certify that 1 The existing customer switchgear has been altered to allow the interconnection of the generating facility to the source side of the customer s main breaker and 2 The altered customer switchgear continues to meet UL certification requirements or that the modified equipment has been recertified for its new configuration Name amp Title Signature Date R 850 V5 0414 3 0 Appendix B 30 NEM Interconnection Handbook February 2014 v 5 0 Appendix F Vendor Decal instructions Once you have identified a vendor to make each type of decal Send this template to have a vendor make the decals to be installed on your generation project This is the actual size of the decals For decals that have to be placed on the customer s panel Generation This Panel has a Customer Owned Generator Connected to the Load Side of the Main Breaker SOUTHERN CALIFORNIA EDISON An EDISON INTERNATIONAL Company 3 Small Generator Labels 3 x 4 Forms 15 40 A Specs 3 x 4 yellow green red and black on 3M premium vinyl with 3M 3980 clear coat and scored backing For decals that have to be placed on AC Disconnects This AC Disconnect Isolates the Customers Generator From the Edison System EDISON An EDISON INTERNATIONAL Company Generation Small Generat
28. Application No 12 08 015 13 11 002 Exhibit No SCE 01 Witnesses Jennifer Kamphuis Vishal Patel Erin Pulgar SOUTHERN CALIFORNIA EDISON An EDISON INTERNATIONAL Company U 338 E REPL Y TESTIMONY ON PHASE I ISSUES Before the Public Utilities Commission of the State of California Rosemead California August 4 2014 SCE 01 REPLY TESTIMONY ON PHASE I ISSUES Table Of Contents 1 1 E Pulgar A GENERATING FACILITY CANNOT SIZED GREATER THAN ITS ASSOCIATED PREMISES ANNUAL LOAD TO RECEIVE CSI INCENTIVES 3 J Kamphuis ANNUAL ESTIMATED GENERATION MUST CALCULATED USING STANDARDIZED INVERTER EFFICIENCY RATES PUBLISHED BY THE 5 V Patel A SCE Has Properly Applied Its NEM Estimation FOUN AS ie 5 1 NEM Handbook Formulas 20 0ccc ccessersetcevsacsctsanccesesancosteeseeees 6 a Formula ING piece feos 7 b Formula Nos as 8 2 Mr Davis s Currently Interconnected Generating 9 J Kamphuis 3 Flaws Relating to Daniel Davis Analysis of ETH CIENCY 11 Patel 4 Davis Is Seeking a Policy Change 12 IV SCE MAY REQUIRE LOAD JUSTIFICATION FOR A
29. allation National Electric Code and All applicable local codes and ordinances If the components change from design to installation submit revised documents with Failure to comply with these requirements will result subject line EQUIP CHANGE prior to in potential delay and any corrections required to scheduling the final inspection bring the project into compliance with these requirements will be at the customer s expense and must be completed before SCE will issue written authorization to interconnect in the form of a Permission to Operate PTO letter The purpose of the technical review is to facilitate the safe interconnection of eligible NEM generators to the SCE electrical distribution system To ensure the generator interconnection is in compliance with SCE interconnection requirements the customer s generating facility will at a minimum be reviewed to ensure that the generator facility will not unintentionally operate islanded mode with SCE s electrical system as required by IEEE 1547 and UL 1741 havea visible open lockable disconnect switch and or rackable breaker for isolation purposes comply with SCE s Electric Service Requirements ESR If the generating facility exceeds the operating capabilities of the distribution system relative to voltage control system overload system operating flexibility or other system condition it will be required to mitigate such condition prior to F
30. ately identified and does not vary with electrical usage Emphasis added 3 customers to whom this requirement is applicable including Mr Davis are required under SCE s tariffs to comply with this provision 35 Mr Davis also entered into the NEM Interconnection Agreement with SCE for the Renewable Electrical Generating Facilities associated with these accounts and is therefore considered the NEM Eligible Customer Generator for these accounts 36 SCE s Tariff Rule 18 Supply to Separate Premises and Use By Others at Sheet 1 19 However this assumes that the load registered on the meters to which the Renewable Electrical Generating Facilities are interconnected meet the applicability requirements for the rate under which those services are billed The accounts listed above are all served under SCE s Schedule Domestic Service Schedule is applicable to domestic service including lighting heating cooking and power or combination thereof in a Single Family Accommodation or an individually metered Single Family Dwelling in a Multifamily Accommodation Based on SCE s understanding of the characteristics of the accounts listed above the usage on those meters meet the applicability requirements for receiving Domestic Service and are appropriately served under Schedule D 32 Schedule NEM can then be applied as a rider to the accounts otherwise applicable rate schedules i e Schedule D and the load
31. ble Energy operated by the Alliance for Sustainable Energy LLC 20 21 22 N 4 a user inputs data specific to the proposed system and proposed location e g zip code model of solar panel number of solar panels tilt of the solar panels azimuth of the solar panels etc Thus as described in this section SCE s NEM Handbook establishes that two formulas can be used to determine estimated kWh generation of a proposed photovoltaic generating facility Both provide a uniform nondiscriminatory way to efficiently process thousands of NEM applications 2 Mr Davis s Currently Interconnected Generating Facilities Mr Davis s Second Amended Complaint requests that the Commission provide the following e with respect to 61736 Onaga allow me NEM interconnection for an additional 30 horizontal panels on each of the two existing already interconnected non CSI 6kW inverters and an additional 30 horizontal and 30 vertical panels on the existing 6kW CSI inverter additionally to the extent that any estimate of anticipated production might be required that that estimate be adjusted for reduced inverter efficiency caused by the high panel to inverter ratio total three 6kw inverters with 60 horizontal panels each and an additional 30 vertical panels on one e with respect to 65911 29 Palms Hwy apartments 1 8 allow me NEM interconnection for an additional 30 panels on each of the existing 5kW already interconnected CSI in
32. d generation of the proposed facility must be calculated To do so SCE must evaluate certain features of the proposed facility including the number of solar panels the model of the solar panels and the model of the inverter SCE utilizes one of two formulas to calculate the estimated monthly kilowatt hour kWh output Both formulas applied by SCE rely upon among other variables an Inverter Efficiency variable which reflects the anticipated DC to AC losses of the particular model of inverter chosen by the applicant For California Energy Commission CEC certified inverters such as the inverters IN Other key components include among others cables disconnects and connectors 95 The amount of export to SCE would depend on the specifics of the situation taking into account load behind the meter on an NEM type service SCE s Tariff Schedule NEM at Sheet 13 14 serving Mr Davis s currently interconnected generating facilities SCE determines the Inverter Efficiency variable based upon manufacturer data published by the CEC The opening testimonies of David Davis and Daniel Davis request that the Commission prospectively adopt a new formula for estimating the future kWh generation of a photovoltaic generating facility 1 NEM Handbook Formulas To determine whether a customer s Renewable Electrical Generating Facility is intended primarily to offset part or all of the Customer s
33. e Electrical Service Requirements section 1 12 and Figure 5 for wiring instructions of the NGO socket 5 5 1 AC Disconnect requirement for NGO meter sockets When a NGO customer meter socket is installed a line side and a load side ganged operated visible open lockable AC Disconnect shall be installed See Figure 4 For NGO meter socket rated at greater than 600 the AC Disconnects shall be installed directly adjacent to the NGO meter socket For NGO meter sockets rated at 600 V or below the AC Disconnects shall be installed in line of sight of the NGO meter socket These AC Disconnects may be in addition to the singular AC Disconnect to isolate the entire generation facility R 850 V5 0414 1 9 Appendix B 19 NEM Interconnection Handbook February 2014 v 5 0 Note 1 For metering purposes the generator shall be connected to the line side of the NGO socket SCE Secondary Service cable PCC Load Side Visible amp Lockable AC Main CB Disconnect Net Generation Note 2 picas reference the ESR section 5 for Socket Meter socket 5 requirements Typical self contained meter per SCE s Electrical Service Requirements Line Side Visible amp Lockable AC Disconnect p 4 Generating Facility Figure 4 Typical self contained meter
34. e Mr Davis s own electrical requirements for the NEM generating facility interconnected to the Domestic Service meter Any non residential EV charging load appropriately served on the applicable General Service rate schedule would also be considered Mr Davis s electrical requirements for the NEM generating facility interconnected to the 41 This requirement is found in SCE s Tariff Rule 1 Definitions which defines Domestic Service as follows Service for residential use at a Single Family Dwelling premises Any service for other than residential use at a Single Family Dwelling premises may be served through the domestic service meter only where such nondomestic connected load does not exceed 300 watts for lighting or 2 hp for power emphasis added 23 1 2 General Service meter 42 But non residential EV charging load registered on a Domestic Service meter would be out of compliance with SCE s rate schedules 43 42 Effective July 21 2014 SCE s NEM tariff now allows Eligible Customer Generators with additional metered service accounts located on the property where the Renewable Electrical Generating Facility is located and or on property adjacent or contiguous to that property if those properties are all solely owned leased or rented by the same Eligible Customer Generator to have the load of all the meters aggregated for the purposes of participating in NEM referred to as NEM Aggregat
35. eferenced by Mr Davis on pages 41 and 42 of the Second Amended Complaint have not been submitted to SCE in an appropriate application and thus SCE has not reviewed the system configurations for safety and reliability 25 Appendix A Witness Qualifications 20 21 22 23 24 SOUTHERN CALIFORNIA EDISON COMPANY QUALIFICATIONS AND PREPARED TESTIMONY OF JENNIFER KAMPHUIS Please state your name and business address for the record My name is Jennifer Kamphuis and my business address is 2244 Walnut Grove Avenue Rosemead California 91770 Briefly describe your present responsibilities at the Southern California Edison Company I am the Program Manager for the Distributed Generation department in Customer Service Organization at Southern California Edison For the past 3 years I have been the Program Manager PM responsible for administrating the California Solar Initiative CSD Residential and Non Residential programs and ensuring compliance in application processing As the CSI PM I am the subject matter expert on CSI Program rules and requirements set forth by the California Public Utility Commission Briefly describe your educational and professional background I have a Bachelor s Degree in Liberal Studies for the California State University of San Bernardino I have been an employee of SCE for three years in the Manager of Programs and Contracts role for Distributed Generation working directly on the CSI Progra
36. ermine the study timetable on a case by case basis The interconnection study will detail any additional interconnection facilities or distribution system modifications that will be needed to accommodate the applicant s generating facility If the generating facility exceeds the operating capabilities of the distribution system relative to voltage control system overload system operating flexibility or other system condition it will be required to mitigate such conditions prior to Field Engineering providing technical approval R 850 V5 0414 9 Appendix B 9 NEM Interconnection Handbook February 2014 v 5 0 3 4 Review Fees There are no application and review fees for NEM interconnection requests Please refer to Rule 21 Section E 2 c 4 Operating Evaluations The generator shall not energize or export power to the SCE system during any interruption to the supply that serves the Point of Common Coupling The applicant s generation may be operated during such interruptions only with an open tie to SCE Islanding with SCE systems will not be permitted under any circumstance Technical Approval is based on the following criteria 15 Rule the applicant s generating system combined with existing generation does not exceed 15 of the maximum loading of line section For more information please refer to Rule 21 G 1 m Overloading all distribution equipment must not be overloaded by the applicant s generating system Volta
37. erter Efficiency variable in the two NEM Handbook formulas Rather their testimony asks that the Commission adopt new alternative 23 Soler testimony at p 1 24 Soler testimony at Attachment 91 25 Daniel Davis testimony at p 11 26 SCE acknowledges that the NEM Formula No 2 is likely to return an error message for Daniel Davis s hypothetical system because it is configured to cause the CEC AC System Rating to exceed the inverter s rating by greater than 125 percent 12 20 21 formulas methodologies Both David Davis and Daniel Davis propose to use the inverter manufacturer s SMA America Sunny Design tool This Sunny Design tool is web based software published on the inverter manufacturer s website SCE believes it is inappropriate to rely upon individual inverter manufacturer software SCE relies upon standardized formulas using inputs set by the CEC that can be used to efficiently process thousands of NEM applications in a uniform and nondiscriminatory way Daniel Davis also proposes to use the NREL System Advisor Model 5 27 While the NREL SAM may be a reasonable methodology to use to estimate generation in developing policies and procedures for processing NEM applications SCE elected to use the above described two NEM Handbook Formulas These formulas are published in the NEM Handbook which has been used to process thousands of NEM interconnections since 2011 as discussed in Section IV of
38. f NEM facilities onto SCE s secondary network distribution system is permitted However due to the complexity of secondary networks additional requirements must be met to ensure continued reliable operation of the network In addition to standard NEM requirements NEM interconnections must use one of the following to ensure non export to the SCE secondary network Preferred An under power relay minimum import relay should be installed to monitor power flow at the PCC The relay should be set to disconnect the NEM generator from the SCE system when input power at the PCC falls below Rule 21 G 1 i requirements 5 of the Generating Facility s total Gross Nameplate Rating with a maximum 2 0 second delay A reverse power relay should be installed to monitor power flow at the PCC The relay should be set to disconnect the NEM generator from the SCE system when reverse power flow at the PCC falls exceeds Rule 21 G 1 i requirements 0 1 of the service transformer s rating with a maximum 2 0 second delay Install dynamically controlled inverters DCI that monitor power flow at the PCC and will initiate a reduction of power output from the NEM to maintain a minimum import level 6 Protection Requirements The interconnection of a new NEM generation facility to the SCE distribution system must not degrade any of the existing SCE protection and control schemes nor lower the existing levels of safety and reliability to other customers
39. f Verification tests and maintenance of its protective devices generator owner s system interferes with SCE equipment or equipment belonging to other SCE customers generator owner s system is found to affect quality of service of adjoining customers R 850 V5 0414 1 7 Appendix B 17 NEM Interconnection Handbook February 2014 v 5 0 5 3 Signage Requirements SCE requires decals or permanent signage to be installed on generation facilities in order to identify customers that have generation onsite A photograph with the installed decals must be submitted to the NEM Interconnection team with the final Permit Inspection see section 2 1 SCE will verify the decal installation during the final technical approval by local Field Engineering or Service Planning Decals that will be installed on the customer s main service panel Decals that will be installed on the AC Disconnect to be used for utility isolation of the generator Generation This Panel has a Customer Owned Generator Connected to the Load Side of the Main Breaker SOUTHERN CALIFORNIA EDISON This AC Disconnect Isolates the Customers Generator From the Edison System SOUTHERN CALIFORNIA EDISON You have the option to receive the decals by the following method 1 You may elect to have up to 20 sets of decals sent to you Please send a self addressed stamped envelope with sufficient postage to mail a total weight of 3 4 ounces
40. g 6 Are any safety considerations raised by determination of whether a proposed solar PV system qualifies under NEM CSI or NSC Are there any other safety considerations raised by these consolidated proceedings 20 21 22 23 24 25 26 27 28 29 GENERATING FACILITY CANNOT SIZED GREATER THAN ITS ASSOCIATED PREMISES ANNUAL LOAD TO RECEIVE CSI INCENTIVES Through 2006 the California Public Utilities Commission s the CPUC or the Commission Self Generation Incentive Program SGIP provided incentive payments to customers who installed distributed generation systems including solar facilities In Rulemaking R 04 03 017 the Commission stated its intent to fund a new distributed generation program specific to solar namely the California Solar Initiative and in Decision D 06 01 024 the Commission committed 2 5 billion to CSI over 10 years The CSI program is overseen by the CPUC and administered by investor owned utilities SCE has been a Program Administrator for the CSI program since the beginning of the program in 2007 SCE is responsible for processing applications and understands applications must be processed in accordance with the requirements set forth in the relevant statutes CPUC decisions and the CSI Handbook SCE is also obligated to administer the CSI program in a fair non discriminatory manner Under Section 25782 of the California Public Resources Code a s
41. ge Operating Levels the applicant s generating system must not create a voltage drop or rise that is outside the allowable operating voltage bandwidth specified in Rule 21 and Rule 2 PDF System Upgrades upon review by SCE Distribution Engineering system upgrades may be required to allow the system to accommodate the interconnection of the generating facility NOTE For technical analysis defined in this Handbook SCE Engineering will use the Aggregate Inverter Capacity Please refer to Section 3 above for the delineation of cost responsibilities for distribution modifications versus interconnection facilities Following a generation facility disconnect as a result of a voltage or frequency excursion parameters are described in Rule 21 Section H 1 a 2 the generation facility shall remain disconnected until the service voltage and frequency has recovered to SCE s acceptable voltage and frequency limits for a minimum of sixty 60 seconds 41 Normal Voltage Operating Range To minimize the adverse voltage effects experienced by other customers on SCE s electric system any voltage flicker at the point of common coupling PCC caused by the generating facility must not exceed the limits defined by the Maximum Borderline of Irritation Curve shown in the Institute of Electrical Engineers IEEE 519 Rule 2 PDF and Rule 21 PDF Rule 21 Section C Definitions R 850 V5 0414 1 0 Appendix B 10 NEM Interc
42. generators consist of 60 Schott 230 Poly solar modules which have a PTC rating of 207 7 connected to an SB5000 US inverter which can convert a maximum of 5 1kW from DC to AC First we calculate the Inverter Efficiency using formula 11 Inverter Efficiency 5100 60 x 207 7 100 40 924 22 Daniel Davis is stating that Inverter Efficiency is calculated based upon 1 a presumed maximum AC output for an inverter i e 5100 W which is then 2 divided by the maximum DC output of an attached set of solar panels number of panels times the PTC rating of those panels i e 60 panels 207 7 W 12 462 W This is not inverter efficiency Rather Daniel Davis is describing system efficiency Specifically he is describing the system efficiency of the total generating facility for a single hypothetical configuration Assuming the AC output and DC output values used by Daniel Davis are correct the hypothetical system efficiency described by Daniel Davis is approximately 40 9 percent But this is not the inverter efficiency ratio which is a different variable that N 20 The n a reflects that this meter has not yet completed a full Relevant Period N 21 n a reflects that this meter has not yet completed a full Relevant Period N 22 Daniel Davis testimony at 11 11 20 21 considers only the amount of power due to the conversion of power from DC power to AC power Daniel Davis
43. gs Settings lt 120 48004 208 Maximum Timing of Nominal Base Base Base Cycles Seconds 27 Extreme Under Voltage 50 240 104 10 0 167 27 Extreme Under Voltage 50 60 240 104 10 0167 Element Element Name Tar Tundersvorage _________ 16 aza 1 ow _ 1 _ Extreme Over 120 576 249 6 10 0 167 Note Producer can set relays more stringent than required by Rule 21 Such is the case in inverter systems R 850 V5 0414 2 2 Appendix 22 NEM Interconnection Handbook February 2014 v 5 0 Table 7 1 2 Frequency Relay Trip Settings Maximum Timing Element Element Name Settings Cycles Seconds 810 Over Frequency gt 60 5 HZ 10 0 167 81U Under Frequency 59193157 10 0 167 Unless otherwise required by SCE a trip frequency of 59 3 Hz maximum trip time of 10 cycles shall be used 6 1 1 Ground Fault Sensing and Stabilization When required by SCE s Interconnection Handbook PDF a ground fault sensing scheme detects SCE s ground faults and trips the generator breaker or the generator s main circuit breaker preventing the generator from continuously contributing to the ground fault Ground fault sensing scheme will consist of either a ground detector or ground bank depending on the configuration of SCE s power system 7 Definitions Accessible A device that is accessible to SCE
44. icable rate schedule that contains Demand Charges Currently EV fast chargers that are both a installed at residential Single Family Accommodation locations and b used for residential purposes are 39 Schedule NEM does not allow for the netting of demand kW charges only energy kWh charges and credits are netted A customer that installs a generating facility may see a reduction in Demand Charges because of the coincidence of the electricity generated by the generating facility and the customer s peak demand load but that is a function of installing a generating facility it is not a function of being served on Schedule NEM since NEM does not net Demand Charges 40 See e g Complaint C 12 08 015 at p 3 22 eligible for SCE s Domestic Service EV tariffs including Schedules TOU D TEV and TOU EV 1 These Domestic Service EV tariffs do not contain Demand Charges If Mr Davis chooses to make the EV fast charger available to non residential third parties then SCE understands that it must separately meter that load from the Domestic Service load and serve the non residential load on the applicable General Service rate schedule such as TOU GS 2 or TOU EV 4 4 Both of these General Service rate schedules contain Demand Charges and these Demand Charges are applicable to all customers who are appropriately served on these rate schedules In sum for NEM purposes SCE considers the usage served on the Domestic Service meter to b
45. ield Engineering providing technical approval An NEM customer must bear the cost of the Interconnection facilities Please refer to Decision 02 03 057 Rule 21 Section E 4 and Public Utilities Code Section 2827 g for the delineation of cost responsibilities for distribution modifications versus interconnection facilities 3 1 Document Review The following documents are required before SCE will begin the technical review of a proposed generating facility R 850 V5 0414 8 Appendix B 8 NEM Interconnection Handbook February 2014 v 5 0 Completed Application Form see NEM Interconnection Checklists at www sce com nem for information about which application form is required based on the project size and configuration Single Line Diagram see Section 5 2 for detailed requirements and Appendix A for a sample The following additional information may also be required based on the size configuration of the proposed system Photos of the manual visibly open and lockable open AC Disconnect Switch showing visible contact separation see Section 5 3 for manual visibly open and lockable open AC Disconnect Switch requirements Plot Plan see Section 5 3 6 for circumstances when a Plot Plan is required and Appendix for a sample Inverter Specifications see Section 5 1 for more information Photos of installed SCE provided decals when applicable see Section 5 3 for more information Line side supply side taps Please see
46. ink The published CEC data identifies a specific Inverter Efficiency for each model of inverter that is approved by the 12 b Formula No 2 For Formula No 2 the CSI EPBB calculator estimated generation is determined by multiplying the System Rating by the Design Factor The System Rating variable is the same as the CEC AC Nameplate Quantity of Modules x PTC Rating x Inverter Efficiency 1000 kW This variable is calculated using the same methodology discussed above As above SCE relies on CEC data to determine the inverter efficiency variable The Design Factor determines the estimated performance of a proposed system when taking into account the proposed physical location and the specific configuration of the generating facility The Design Factor is calculated by the National Renewable Energy Laboratory s NREL PV Watts version 2 PV Watts software program which is run after 1l See Performance Test Protocol for Evaluating Inverters Used Grid Connected Photovoltaic Systems Section 5 4 1 at p 14 available at http www gosolarcalifornia ca gov equipment inverters php last visited Aug 1 2014 This published data can be found at http www gosolarcalifornia ca gov equipment inverters php last visited Aug 1 2014 13 NREL is a national laboratory of the U S Department of Energy Office of Energy Efficiency and Renewa
47. ion This means that Mr Davis could install one Renewable Electrical Generating Facility on either the Domestic Service meter or the General Service meter assuming he qualifies for this additional meter that is sized to offset the electrical requirements of the aggregated load from both meters The load from both meters is considered the customer s own electrical requirements for the purposes of participating in NEM Aggregation See SCE s Tariff Rule 11 Section G Noncompliance Except as otherwise specifically provided in this Rule 11 where SCE determines that a customer is in noncompliance with any tariff schedule SCE at its option may 1 Transfer the customer to another tariff for which the customer can qualify or 2 Withhold payment of any credits or discounts applicable to the customer s existing tariff schedule or 3 Discontinue service to the customer 24 OTHER SAFETY CONSIDERATIONS RAISED BY THESE CONSOLIDATED PROCEEDINGS Safety and reliability considerations are raised every time an interconnection applicant submits a request to interconnect a new generating facility or to increase the capacity of or make a material modification to the operating characteristics of an existing generating facility that is interconnected with SCE s Distribution or Transmission system These safety and reliability concerns must be evaluated on a case by case basis SCE notes that the hypothetical system configurations r
48. ity a When adding additional generation to a facility that currently has generation at the facility the added generation must be connected to the existing disconnecting device 3 The visible open disconnect must be adjacent to the Point of Common Coupling PCC or approved location that should be in line of sight with approved signage and must comply with access requirements per Rule 21section H 1 d a Inside the same electrical metering room b Immediately outside the electrical metering room 4 Location of visible open disconnect must be approved by SCE prior to installation a Plot plan outlining the locations of the visible open disconnect must be provided in the interconnection request R 850 V5 0414 1 5 Appendix B 15 NEM Interconnection Handbook February 2014 v 5 0 Visible amp Lockable Generating Facility Typical non self contained meter switchboard per SCE s Electrical Service Requirements Figure 2 Typical non self contained meter switchgear 5 2 5 Primary Service Voltage Connections These types of installations are typically utilized by large customers or by customers that have a campus style electrical system For these types of installations the generation is typically installed on a panel fed by the customer s transformers see figure 3 For these types of installations it becomes extremely difficult to comply with the one single disconnect at the PCC requirement SCE s main
49. ll cease to energize SCE s Distribution System for faults on SCE s Distribution System circuit to which it is connected IEEE 1547 4 2 1 The Generating Facility shall cease to energize SCE s Distribution circuit prior to re closure by SCE s Distribution System equipment IEEE 1547 4 2 2 Please reference SCE s Interconnection Handbook for additional information The customer s system protection facilities are at the customer s expense and must be installed operated and maintained in accordance with all the applicable regulatory requirements and in accordance with the design and application requirements of this Handbook 61 Inverter Protection Settings Approved voltage and frequency setting per SCE s Rule 21 below If inverter is 30KW or below protection settings approved if inverter is UL listed all CEC approved inverters meet this guideline If inverter is larger than 30kW protection settings are field adjustable o Verify that it is UL listed o Verify settings on each inverter during commissioning test by installer displaying settings on connected computer or on inverter panel If settings cannot be verified during a commissioning test obtain a letter from the inverter manufacturer providing the inverter settings and their respective serial number Distribution Engineering will verify the proposed settings to ensure that they meet Rule 21 Section H requirements see Appendix C Table 7 1 1 Voltage Relay Settin
50. m Prior to coming to SCE I worked as an Account Manager in the wholesale mortgage lending industry for 4 years I have not previously testified before the California Public Utilities Commission What is the purpose of your testimony in this proceeding The purpose of my testimony in this proceeding is to sponsor portions Exhibit SCE 01 as identified in the Table of Contents thereto Was this material prepared by you or under your supervision Yes it was Insofar as this material is factual in nature do you believe it to be correct Yes I do Insofar as this material is in the nature of opinion or judgment does it represent your best judgment Yes it does Does this conclude your qualifications and prepared testimony Yes it does A 2 20 21 22 23 24 SOUTHERN CALIFORNIA EDISON COMPANY QUALIFICATIONS AND PREPARED TESTIMONY OF VISHAL PATEL Please state your name and business address for the record My name is Vishal Patel and my business address is 3 Innovation Way Pomona California 91768 Briefly describe your present responsibilities at the Southern California Edison Company I am currently a Senior Power Systems Planner fulfilling the role of Manager of Generation Interconnections in the Distribution Engineering department Distribution Engineering is a group within the Electric System Planning ESP department under the Transmission and Distribution operating unit I am responsible for overseei
51. maintenance personal consistent with Rule 21 PDF requirements Anti Islanding A control scheme installed as part of the Generating or Interconnection Facility that senses and prevents the formation of an Unintended Island Island Islanding A condition on SCE s Distribution System in which one or more Generating Facilities deliver power to customers using a portion of SCE s Distribution System that is electrically isolated from the remainder of SCE s Distribution System Line Side Tap A point of interconnection on the utility or line side of the main breaker Load Side Tap A point of interconnection on the customer or load side of the main breaker Lockable The disconnect must have provisions for a common 3 8 padlock used as part of normal SCE maintenance lockout procedure see Section 5 3 Manual Visibly Open and Lockable AC Disconnect Switch Non Islanding Designed to detect and disconnect from a stable Unintended Island with matched load and generation Reliance solely on under over voltage and frequency trip is not considered sufficient to qualify as Non Self Contained Meter An SCE revenue grade meter at a customer panel that uses external current transformers to measure the flow of current R 850 V5 0414 2 3 Appendix B 23 NEM Interconnection Handbook February 2014 v 5 0 Standard Located on the customer s premise must use UL listed inverter s with a point of interconnection on
52. n of AC Disconnect In order for SCE to operate and maintain the distribution system safely and reliably it is mandatory that all electrical sources to the SCE s distribution system have the ability to If you come across a be disconnected from the system with a single visible open and broken meter seal lockable switching device Having the ability to disconnect and to report it immediately secure the disconnection of the various electrical sources will allow to 800 655 4555 SCE s workers to safely perform the required maintenance to the 3 SCE s Interconnection Handbook provides the requirements for voltage greater than 34 5KV R 850 V5 0414 1 3 Appendix B 13 NEM Interconnection Handbook February 2014 v 5 0 distribution system by removing tagging and taking the required clearances to the system where maintenance is to be performed SCE s distribution system is designed with switches and other devices that can be used to disconnect the SCE source to any section of the distribution system However in order to achieve the required complete isolation from all the sources the generation facility sources that are connected to the distribution system must also have the capability of being securely disconnected with a single visible open and lockable switching device While SCE acknowledges that in some cases installing the required disconnecting device may significantly increase the cost of the interconnection SCE must ensure
53. nd the customer will not be permitted to interconnect to SCE s electrical distribution system SCE reserves the right to disconnect previously certified interconnected units when Underwriters Laboratories decertifies the units SCE may implement an acceptable mitigation procedure for recertification at the customer s expense 5 2 Single Line Diagram See Appendix A for a sample Single Line Diagram The Single Line Diagram shows the path and graphic symbols of the entire electrical system for the site to provide a good understanding of the connections and component use Best single lines provide on one side of the page a sequence of events such as what happens during an SCE interruption and which devices close and or open to return the generation system to normal status Any and all additional information necessary to demonstrate compliance with Rule 21 and SCE s Electrical Service Requirements ESR should be provided Depending on the system the following should be included on the Single Line Diagram Site location service address must match address SCE account and NEM Interconnection Application Detail view of the point of connection to the power grid specifically showing whether it is on the utility or customer side of the main breaker see below for additional requirements that apply when the point of interconnection is on the utility side of the main breaker line side tap Appendix Service Panels Pro
54. ng a group of engineers and technical specialists that perform technical studies and other related tasks necessary to interconnect generation to SCE s distribution systems via the Rule 21 and WDAT FERC jurisdictional tariffs Prior to this I was a Senior Power Systems Planner in various Transmission Planning organizations within ESP I have performed transmission planning studies on different portions of the SCE transmission system which have evaluated system reliability generation interconnection and inter utility transfer capability issues in addition to sponsoring capital projects to maintain system reliability Briefly describe your educational and professional background I obtained a Bachelor of Science degree in Electrical Engineering from California State Polytechnic University Pomona Additionally I am a Registered Professional Engineer in Electrical Engineering in the State of California and a member of the Institute of Electrical and Electronics Engineers IEEE I have worked at SCE since 2006 What is the purpose of your testimony in this proceeding gt gt Q The purpose of my testimony in this proceeding is to sponsor portions Exhibit SCE 01 as identified in the Table of Contents thereto Was this material prepared by you or under your supervision Yes it was Insofar as this material is factual in nature do you believe it to be correct Yes I do Insofar as this material is in the nature of opini
55. nterconnection Handbook February 2014 v 5 0 e Customer may replace the CB section with a rackable CB in order to meet the requirement b When customer does not agree on facility outage when isolating the generator from the distribution system 1 SCE to De Energize Customer service by opening source switch Generating Facility 2 Customer to Open and Rock out CB and SCE to verify and lockout the D CB with SCE Locks SCE takes control of the CB Circuit Coninues Figure 3 Typical high voltage service interconnection 5 2 6 Plot Plan Requirement See Appendix B for a sample Plot Plan If the manual visibly open and lockable AC disconnect is required a Plot Plan must be provided to SCE Distribution Engineering for review showing the location of the manual visibly open and lockable open AC disconnect switch with reference to the utility meter 5 2 7 Circumstances when AC Disconnect May be Opened by SCE The manual visibly open and lockable open AC Disconnect Switch or rackable circuit breaker may be operated by SCE under the following circumstances Pre emergency or emergency conditions on the SCE system hazardous condition is revealed by an SCE inspection To eliminate a condition that constitutes a potential hazard to SCE personnel or the general public When protective device tampering is discovered generator owner has failed to make available records o
56. o 1 For Formula No 1 CEC AC Nameplate 720 x 0 2 SCE must calculate the Nameplate 8 The CEC AC Nameplate represents the anticipated amount of AC power that the proposed generating facility can contribute to the distribution system when taking into account the number of solar panels the particular model of solar panel and the particular model of inverter Under the NEM Handbook variable CEC AC Nameplate is determined pursuant to the following calculation Quantity of Modules x PTC Rating x Inverter Efficiency 1000 kW The Quantity of Modules refers to the proposed generating facility s number of PV solar panels PTC Rating represents the estimated power output in Watts for a particular model of solar panel under specific test conditions It 15 a standardized estimate calculated by the CEC using laboratory tested parameter values 12 The Inverter Efficiency reflects anticipated power losses that occur when an inverter converts DC to AC During the course of converting DC power to AC power some power is lost due to heat and other factors An inverter s efficiency reflects how much DC power is actually converted to AC power Section 2 2 of the NEM Handbook states that for CEC certified 8 720 represents the number of hours in a month 2 represents the average number of full sun hours in a 24 hour period in Southern California SCE notes that Pacific Gas and Electric Company
57. oad to 100 of annual historical usage based on the previous 12 months customer usage SCE has applied the system sizing requirement using the methodology described above to approximately 57 000 applications including Mr Davis s applications 20 21 22 ANNUAL ESTIMATED GENERATION MUST BE CALCULATED USING STANDARDIZED INVERTER EFFICIENCY RATES PUBLISHED BY THE CEC A SCE Has Properly Applied Its NEM Estimation Formulas A photovoltaic generating facility includes among other key components an array of solar panels and an inverter 2 The solar panels convert solar energy into to Direct Current electrical energy The inverter converts the DC electrical energy to Alternating Current electrical energy which can then be exported to SCE s AC electrical energy distribution system 3 During the course of converting DC power to AC power some power is lost For example in this conversion some energy 15 lost to heat and some energy is lost because it is used to power the inverter An inverter s efficiency reflects how much DC power is actually converted to AC power taking into account these losses To be eligible for SCE s NEM tariff a customer s Renewable Electrical Generating Facility must be intended primarily to offset part or all of the Customer s own electrical requirements 4 In order to determine whether a proposed facility offsets the Customer s electrical requirements the estimate
58. olar energy system must be intended primarily to offset part of or all of the consumer s own electricity demand to be eligible for CSI incentives Since the inception of the CSI program the Commission has addressed system sizing multiple times Section 2 2 4 of the CSI Program Handbook states To be eligible for CSI Incentives the system must be sized so that the amount of electricity produced by the system primarily offsets part or all of the Host Customer s electrical needs at the Project Site Unless additional load substantiation documentation is submitted the estimated annual kWh production of the proposed system as shown on the EPBB calculator may not be higher than the previous 12 month energy usage Additionally section 2 2 5 of the CSI Program Handbook states In accordance with Senate Bill 1 2006 no solar energy systems that exceed a customer s onsite load will receive a CSI incentive SCE understands that the CSI Program Handbook is consistent with Commission Decision 06 07 028 where the Commission expressly held that the maximum solar system size eligible for incentives under the California Solar Initiative CSI is 100 of historical annual usage based on customer usage data from the previous 12 months D 06 07 028 at Ordering Paragraph No 1 see also id at Conclusions of Law Paragraph No 2 System size eligibility requirements for solar facilities should be modified from 100 of peak l
59. on or judgment does it represent your best judgment Yes it does Does this conclude your qualifications and prepared testimony Yes it does A 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN CALIFORNIA EDISON COMPANY QUALIFICATIONS AND PREPARED TESTIMONY OF ERIN PULGAR Please state your name and business address for the record My name is Erin Pulgar and my business address is 8631 Rush Street Rosemead California 91770 Briefly describe your present responsibilities at the Southern California Edison Company I am currently a Manager of Programs and Contracts in SCE s Regulatory Operations Department As such I am responsible for providing tariff related subject matter expertise on existing CPUC tariffs and for implementing new statutes and CPUC decisions into SCE s CPUC tariff book I also provide tariff expertise in the resolution of informal and formal complaints with the CPUC Briefly describe your educational and professional background I hold a Bachelor s degree in Public Relations and Political Science from the University of Southern California I have over three and a half years of experience working at SCE Prior to my current position I was a project manager in the Revenue Service Organization where I was responsible for operational compliance with SCE s billing related tariffs Before joining SCE I worked six years for AeroVironment Inc as a
60. onnection Handbook February 2014 v 5 0 4 1 1 Limits Specific to Single Phase Generating Facilities When connected to a single phase transformer the generator must be installed such that the aggregated gross output is balanced between the two phases of the single phase voltage and the maximum aggregated Gross Ratings for all the Generating Facilities shall not exceed the transformer rating 4 1 2 Limits Specific to Three Phase Generating Facilities The applicant must balance the demand load and generation as nearly as practical between the two sides of a three wire single phase service and between all phases of a three phase service The difference in amperes between any two phases at the customer s peak load should not be greater than 10 percent or 50 amperes at the service delivery voltage whichever is greater except that the difference between the load on the lighting phase of a four wire delta service and the load on the power phase may be more that these limits It will be the responsibility of the customer to keep the demand load balanced within these limits 5 Miscellaneous Requirements 5 11 Inverter An inverter based generating facility must meet all required criteria specified in the CPUC s Rule 21 Generating Facility Interconnections IEEE 1547 UL 1741 and SCE s Interconnection Handbook PDF If the inverter does not meet Underwriters Laboratories Standard UL 1741 certification CSA OR specifically meets Section
61. or Labels 3 x 4 Forms 15 43 A Specs 3 x 4 yellow green red and black on 3M premium vinyl with 3M 3980 clear coat and scored backing R 850 V5 0414 Appendix B 31 31 NEM Interconnection Handbook February 2014 v 5 0 Once the decals are made please send a sample set to Attn SCE Field Engineering Support 2885 West Foothill Blvd Rialto CA 92376 Please also provide your contact information and your vendor information Once the decals are approved by SCE please install them as per the diagrams below for each project as part of your application package Example of Labeling Practice for AC Isolation Disconnect with Generation The AC Dicoaseri the Cestomers Geosersior From the Edison Generation This Panel haan Customer Owned Generates Commected ta the Loud Side uf the Main Breaker NOTE examples above are intended to portray typical customer equipment If you have questions or concerns about signage placement contact the Field Engineer directly R 850 V5 0414 3 2 Appendix B 32
62. or NEM purposes SCE considers any load that registers on the meter to which the Renewable Electrical Generating Facility is interconnected to be the customer s own electrical requirements Because Mr Davis is the customer of record for the Service Account associated with the meter located at his residence at 62736 Onaga SCE would consider the load registered on Mr Davis s meter as Mr Davis s own electrical requirements regardless of whether he allows non residents to use the electricity generated by his facility But this assumes that the registered load meets the applicability requirements for the otherwise applicable rate schedule e g Schedule D under which service is rendered Schedule NEM is not a standalone tariff SCE applies Schedule NEM as a rider tariff to the customer s otherwise applicable rate schedule to allow for the monthly netting of energy consumed with energy exported to the grid over 12 month Relevant 38 Schedule NEM does not alter the underlying applicability requirements for the otherwise applicable rate schedule under which a customer is appropriately served Mr Davis has represented to SCE that he desires to oversize his NEM generating facility ies to avoid paying Demand Charges that may be caused by the installation and use of a 50 kW EV fast charger However Mr Davis would only be responsible for Demand Charges to the extent that his EV charging load must be served on an otherwise appl
63. orated in the generating electrical design to ensure that the generating facility as whole is compliant with the NEM tariff requirements Solely having individual components in generating facilities that are in the listing does not automatically deem a generating facility eligible for NEM For example a certified inverter used to interconnect a storage device may deem the generating facility ineligible for NEM even when the generating facility uses the equipment that is on the CEC certified equipment listings For non CEC certified equipment refer to the information provided by the manufacturer NOTE The NEM tariff is applicable for Eligible Customer Generators intended primarily to offset part or all of the customer s own electrical usage where the total Renewable Electrical Generating Facility capacity does not exceed 1 MW CEC AC Nameplate rating and 1 MW aggregate inverter capacity and must be located on customer s Premise Calculations For the purposes of the NEM Interconnection Application the following are formulas used to calculate CEC AC nameplate system size kW and estimated monthly kWh output Table 2 2 2 CEC AC Nameplate Calculation for Inverter based Generation Facilities Technology CEC AC Nameplate Calculation Solar PV Qty of Modules x PTC Rating x Inverter Efficiency 1000 kW Wind Qty of Turbines x Power Output x Inverter Efficiency 1000 kW Fuel Cell Qty of Cells x Rated Ou
64. own electrical requirements SCE understands that the estimated future generation of the proposed generating facility should be determined SCE s NEM Interconnection Handbook Handbook specifies the typical minimum technical requirements to interconnect generating facilities with SCE s electric system under the Net Energy Metering NEM program to process NEM applications Under procedures established in the NEM Handbook estimated monthly kWh output is calculated by using either one of two formulas 2 a Formula No 1 CEC AC Nameplate x 720x0 2 kWh or b Formula No 2 The CSI EPBB calculator located at www csi epbb com Both of these formulas in turn rely in part on an inverter efficiency variable In SCE does not address analysis relating to the actual or reasonably anticipated annual load calculation in this testimony because it is beyond the scope of the Phase issues In addition SCE acknowledges that pursuant to the Scoping Ruling the scope of Phase of these consolidated proceedings will not address whether electrical requirements under Section 2827 b 4 should be interpreted to limit size based on customer peak demand or annual load IN See NEM Handbook Version 5 0 at p 5 Please see Section IV for additional testimony relating to the NEM Handbook The NEM Handbook is also attached to this testimony as Appendix B See NEM Handbook Version 5 0 at p 7 IN Formula N
65. program manager responsible for implementing engineering projects related to electric vehicle charging and other energy related areas I have not previously testified before the California Public Utilities Commission What is the purpose of your testimony in this proceeding The purpose of my testimony in this proceeding is to sponsor portions Exhibit SCE 01 as identified in the Table of Contents thereto Was this material prepared by you or under your supervision Yes it was Q Insofar as this material is factual in nature do you believe it to be correct A Yes I do Q Insofar as this material is in the nature of opinion or judgment does it represent your best judgment A Yes it does Q Does this conclude your qualifications and prepared testimony A Yes it does Appendix Net Energy Metering Interconnection Handbook Version 5 0 Effective Date February 2014 Leading the Way in Electricity Net Energy Metering INTERCONNECTION HANDBOOK SOUTHERN CALIFORNIA An EDISON INTERNATIONAL Company Version 5 0 Effective Date February 2014 R 850 V5 0414 Appendix B 1 Leading the Wav in Electricity What s New This handbook has been updated from the previous version to reflect the following Section 2 2 Provide further clarification the applicability of the NEM tariff in reference to the 1 MW maximum system size for Eligible Customer Generators Section 5
66. r 2011 to help answer technical questions from customers and contractors in regards to interconnecting generating facilities pursuant to the NEM tariff Over 60 000 NEM interconnections have been completed since SCE first began referring customers to the NEM Handbook Although not officially filed with the Commission SCE makes the NEM Handbook publically available on the internet at https www sce com NR sc3 tm2 pdf ce158 12 pdf SCE applies the requirements 31 Generating facilities that include paired energy storage systems for example must complete the longer interconnection application Form 14 732 regardless of system size 16 of the NEM Handbook to all NEM Eligible Customer Generators to help ensure fair non discriminatory and equal access to the NEM program Tables 2 2 2 and 2 2 4 of the NEM Handbook outline the standard formulas used to calculate the CEC AC nameplate system size kW and estimated monthly kWh output for solar PV generating facilities applying under the NEM 32 This information is used by SCE to help ensure that the proposed generating facility is sized to offset the customer s own electrical requirements Nowhere in the NEM Handbook is there a differentiation or distinction made in regards to the NEM sizing requirements based on whether a system is sized smaller or larger than 5 kW Because all Eligible Customer Generators must comply with the requirement that their proposed generating facilities be
67. rconnection Handbook February 2014 v 5 0 5 3 Slg Mage 18 5 4 19 5 5 Net Generation Output Meter NGOM cccccccccsssscceesssseeecsssseceesesseeecseseeeessseeseseaseeeseseeaeens 19 5 5 1 AC Disconnect requirement for NGO meter 19 Figure 4 Typical self contained meter system with NGO metering and AC Disconnects 20 Figure 5 Wiring of a NGO meter socket for Virtual Net Metering 20 5 6 Generating Systems with Battery 21 5 7 Secondary Network 21 6 echt 21 6 1 Inverter Protection Setting Ss iiai 22 Table 7 1 1 Voltage Relay 22 Table 7 1 2 Frequency Relay Trip 5 23 611 Ground Fault Sensing and
68. sized to offset part or all of their own electrical requirements SCE understands that it may request load justification from any Eligible Customer Generator to help ensure compliance with this requirement regardless of the size of the proposed generating facility 32 NEM Handbook Version 5 0 7 17 20 21 22 23 IF DAVIS INSTALLS SOLAR PANELS AT PROPERTIES RENTS TO TENANTS RESULTING IN ELECTRICITY USED NOT BY DAVIS BUT BY HIS TENANTS THE INSTALLATION MAY STILL OFFSET CUSTOMER S OWN ELECTRICAL REQUIREMENTS SUCH THAT THE PROJECT CAN QUALIFY FOR NEM UNDER 2827 B 4 SCE s Tariff Rule 1 defines Customer as the person in whose name service is rendered as evidenced by the signature on the application contract or agreement for that service or in the absence of a signed instrument by the receipt and payment of bills or Summary Bills regularly issued in his name regardless of the identity of the actual user of the service 33 Mr Davis is the customer of record for the Service Accounts associated with each of the locations identified in the March 24 2014 revised Joint Prehearing Conference Statement 34 60215 Alta Loma Apt A 60215 Alta Loma Apt B 60219 Alta Loma Apt A 60219 Alta Loma Apt B 65911 Twentynine Palms Hwy Apt 1 65911 Twentynine Palms Hwy 2 65911 Twentynine Palms Hwy 3 65911 Twentynine Palms Hwy 4 65911 Twentynine Palms Hwy 5 65911 Twentynine Palms Hwy
69. system with NGO metering and AC Disconnects Line Side Visible amp Lockable AC Disconnect Note 1 For metering purposes the generator shall be connected to the LOAD SIDE of the NGO socket SCE Load Side Visible amp Lockable AC Disconnect Net Generation Output Meter Socket 7 GF Generating Facility gt Note 2 Please reference the ESR section 5 for Meter socket requirements Figure 5 Wiring of a NGO meter socket for Virtual Net Metering projects R 850 V5 0414 Appendix B 20 20 NEM Interconnection Handbook February 2014 v 5 0 5 6 Generating Systems with Battery Back Up Back up generators are typically used to provide electrical power to the facility during electrical outages of SCE s electrical grid There are several forms of back up generation including battery back up diesel generators fly wheels etc Battery back up systems when used in conjunction with an NEM project must be designed to be in an isolated mode and not parallel with SCE system under any condition Typically this isolation mode can be accomplished via use of an open transition transfer switch but other means can be used to accomplish the isolation requirements These types of system will require SCE approval and may also require a separate Rule 21 interconnection request 5 7 Secondary Network Interconnection Interconnection o
70. tective devices Circuit Breakers Fuses CT and PT ratings if applicable Utility meter Generation Output Meter s of applicant including built in within component Generator s make and model e Detailed component information characteristics is included for each component Voltage and phase of inverters transformers etc e Inverter setting for Under Voltage Extreme Under Voltage Overvoltage Extreme Voltage Over frequency Under frequency Other Generation type and system size such as emergency battery backup diesel generator permanently connected generators etc including their related interconnection equipment such as open transition transfer switches relays and control systems Manual visibly open and lockable open AC disconnect switch including make and model all info outlined in proposed SLD see Section 5 3 for Manual Visibly Open and Lockable AC Disconnect requirements Code and version to be used for construction and repair inspection and testing R 850 V5 0414 1 2 Appendix B 12 NEM Interconnection Handbook February 2014 v 5 0 Additional Requirements for Line Side Taps When the point of connection to the power grid is on the utility side of the main breaker the Single Line Diagram must also include Protective device information Signed Stamp For Physical connections please refer to Appendix E CAUTION ABOUT BROKEN METER SEALS Per ESR 5 Section 1 0 pp 5 7 all
71. that the system is safe to operate and maintain and thus must require the appropriate disconnecting device SCE will accept the following alternatives to installation of a visible open and lockable disconnect in order to maintain the ability to disconnect the generating facilities from the distribution system 5 2 3 Self Contained Meter with one main switch For these facilities SCE can utilize the SCE revenue meter to disconnect the generation and load from the SCE distribution system See figure 1 for typical system configuration In order to use this option the following requirements must be met 1 Facility must have a main breaker that can be operated by the customer on the same metering switchboard meter panel as the revenue meter 2 Customer must agree that when it is necessary to disconnect the generating facility by opening the main CB and then removing the revenue meter the customer will also experience an outage to the customer s facility until the meter is re installed Restrictions For the facilities or the conditions below the option of removing the revenue meter for disconnection purposes is not available and the customer must install a visible open and lockable disconnect adjacent to the PCC or an approved location that should be on line of sight with approved signage and ona single disconnecting switching device as required by Rule 21 and SCE s Interconnection Handbook a Facilities which do not have a main
72. this testimony Daniel Davis is asking to permit Mr Davis to rely upon an alternative methodology that is different from the standard processes that SCE has applied to thousands of other NEM applicants Mr Davis s hypothetical system configuration i e 60 solar panels per 5 kW or 6 kW inverter is unusual The vast majority of applications processed by SCE do not contain this type of high panel to inverter ratio In fact the NEM Formula No 2 i e the CSI EPBB calculator would return an error message for the hypothetical system proposed by Mr Davis 28 Although the NEM Formula No 1 does not have a built in error message that prevents calculation of such overloading it is not designed to address such substantial overloading beyond the rating of an inverter 27 Daniel Davis testimony at 14 28 The CSI Calculator User Guide version 5 CSI Calculator User Guide which outlines NEM Handbook Formula No 2 states if the CEC AC rating of the proposed system is greater than 125 percent of the inverter rating an error is flagged which must be corrected by reducing the number of panels choosing a lower PTC rated panel increasing the number of inverters or choosing a larger capacity inverter before being allowed to proceed to the results page See CSI Calculator User Guide at 5 available at http www csi epbb com CSICalculator V4UserGuide pdf 13 Indeed according to Mr Davis himself his hypothetical
73. to the following address Attn SCE Field Engineering Support 2885 West Foothill Blvd Rialto CA 92376 2 You may contact the Field Engineer assigned to your project to coordinate decal pick up at the local service center Once you have identified a vendor to make each type of decal please send a sample set with vendor and contact information for approval You can have an approved vendor make SCE decals in bulk at your convenience Please see Appendix F for instructions SCE decal placement does not authorize the generation facility to operate in parallel You may only turn on your system once you have received official notification from SCE R 850 V5 0414 1 8 Appendix B 18 NEM Interconnection Handbook February 2014 v 5 0 54 Telemetering Please refer to section 7 of SCE s Interconnection Handbook for information about telemetry requirements 5 5 Net Generation Output Meter NGOM A Net Generation Output Meter NGOM may be required as indicated in the applicable Rate Schedule see section 1 for a list of Rate Schedules Please see Figure 4 for additional requirements For Virtual Net Energy Metering projects either Schedule NEM V or Schedule MASH VNM a NGO meter will be required and paid for by the customer also the customer will provide and install the NGO meter socket per the ESR The point of interconnection must be made in parallel to other SCE revenue meters and not in SCE sealed sections Refer to th
74. tput x Inverter Efficiency 1000 kW Table 2 2 4 Estimated Monthly kWh Calculation Technology Estimated Monthly kWh Solar PV Use the CSI EPBB calculator at www csi epbb com or CEC AC Nameplate 720 x 0 20 ____ kWh Wind CEC AC Nameplate x 720 0 10 ____ kWh Fuel Cell CEC AC Nameplate x 720 x 0 80 ____ For Non Inverter based generation facilities SCE will use the inverter aggregate capacity R 850 V5 0414 7 Appendix B 7 NEM Interconnection Handbook February 2014 v 5 0 3 Interconnection Review Process After an initial review to confirm the Application and Single Line Diagram are complete and consistent the NEM Interconnection team refers the project to SCE Distribution Engineering for technical review and approval Upon referral the installer is provided notice and contact information for the Distribution Engineer assigned to the project At SCE Distribution Engineering s discretion an onsite inspection and commissioning test may be required as part of the technical review see Section 3 2 for more information SCE strongly encourages the submission of The design must be in accordance with 5 the Application and Single Line Diagram as Rule 21 PDF early as possible so that any changes SCE s Electric Service Requirements PDF required as a result of SCE s technical review SCE s Interconnection Handbook PDF can be incorporated prior to inst
75. verters additionally to the extent that any estimate of anticipated production might be required that that estimate be adjusted for reduced inverter efficiency caused by the high panel to inverter ratio total 1 5k W inverter with 60 panels per apartment 4 Each of the interconnected generating facilities at the nine referenced locations is currently producing sufficient electricity to offset the load of the location 14 Second Amended Complaint at pp 41 42 Table 1 Permission to Operate Previous Previous Current Current Locati f PTO Date Relevant Relevant Relevant Period Relevant ETE Period 5 Period Net Period Net E Facility Energy Energy Usage Usage kWh kWh 61736 Onaga Trail a 12 28 2011 for 12 24 2012 1413 12 23 2013 to 7584 5 996 kW NEM to 12 23 07 25 2014 Generating Facility 2013 b 04 18 2013 for expanded 17 3 kW Generating Facility 65911 08 28 2012 08 28 2012 9599 09 18 2013 7601 TwentyNine Palms to to Hwy 5 09 18 2013 07 22 2014 65911 08 28 2012 08 28 2012 7926 09 18 2013 6073 TwentyNine Palms to to Hwy 6 09 18 2013 07 22 2014 65911 05 20 2013 05 20 2013 1345 05 21 2014 1230 TwentyNine Palms to to Hwy 1 05 19 2014 07 22 2014 65911 08 01 2013 08 01 2013 4785 0 TwentyNine Palms to Hwy 4 7 22 2014 65911 08 01 2013 08 01 2013 4740 18 0 TwentyNine Palms to Hwy 8 7 22 2014 65911 12 11 2013 19 12 11 2013 3888 TwentyNine Palms to
76. vice from SCE s distribution system under an appropriate electric vehicle tariff If Mr Davis elects to receive service from SCE s distribution system he can then elect to offset that electric vehicle load via a generating facility in one of two ways First he can supply power to the EV charger from an isolated generating facility and install an Automatic Transfer Switch that would allow him to power his EV charger with electricity from the grid when his generating facility is unavailable for use Alternatively he could also apply to interconnect that generating facility to SCE s distribution system If Mr Davis interconnects his proposed facility to SCE s distribution system he can then enroll in the NEM program provided his interconnection meets all requirements of the NEM tariff As outlined in the response to Question VI above SCE understands that any load that 38 Davis has submitted one 21 Application to install a 95 kW solar generating facility at 61736 Onaga Joshua Tree CA 92252 which Complainant represented was intended to serve an electric vehicle charger SCE has no record regarding any additional applications for interconnection of NEM eligible generating facilities by Mr Davis to serve load of other unspecified EVchargers 21 20 21 registers on a specific meter is considered the responsibility of the customer in whose name service is rendered regardless of the actual user of the electricity F

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