workshops and the annual symposium or ad hoc communications). The IOUs may not conduct all projects that are described in the Investment Plans, so the Annual Reports are the best sources for determining which projects are being implemented. Though the IOUs comply with EPIC program requirements, Evergreen identifies the need for more timely reporting on projects after the Investment Plans are approved to increase transparency and ensure more effective CPUC oversight. In its post-workshop comments, the CEC agrees that increased transparency on active utility projects and outcomes will be helpful in ensuring that the projects of all EPIC administrators are coordinated to avoid duplication and ensure that the research is helpful and used. The CEC adds that it would also be helpful if the utilities also shared project information from related programs such as pilots on energy efficiency, demand response, energy storage, electric vehicles, and the Emerging Technologies program. The CEC suggests that this will lead to greater visibility and more commercialization and deployment by utility incentive programs, customers and others. The utility administrators offered only limited responses to Evergreen’s observations and recommendations. PG&E and SCE were silent on two-thirds of the 32 recommendations made by Evergreen; SDG&E was slightly more responsive, responding to approximately half of the recommendations. In some instances, Evergreen singled out specific utilities, but that utility did not respond to Evergreen. The utilities’ limited engagement with this central aspect of this proceeding has had the effect of slowing our review of the Evaluation. As explained below, we add an additional filing requirement for the utility administrators so that they can address Evergreen’s findings and recommendations in sufficient detail.
have a competitive advantage, and thus no longer have the impetus for developing new technology. However, IP rights must also allow the sharing of new scientific knowledge which fosters further advances and prevents duplication of efforts by others, which in turn preserves RD&D funds for new efforts. Currently, the CEC’s “EPIC Standard Grant Terms and Conditions” allows the CEC and the CPUC to grant IP licenses to LSEs, including the IOUs, that provide electricity to EPIC ratepayers. The licenses allow LSEs to utilize EPICfunded IP “to enhance the entities’ service to EPIC ratepayers.” The CEC requested that the scope of this proceeding include clarification or modification of D.13-11-025, as necessary, regarding the circumstances under which the CEC may grant licenses to LSEs for EPIC-created IP. Specifically, the CEC seeks Commission support for the CEC’s interpretation of D.13-11-025: the CEC may grant LSEs a free license to use models and analytical tools that can inform distribution planning and decision-making that benefits electric ratepayers, but no licenses are to be granted by the CEC for any other type of developed technology. The CEC explains in its application that its request is based on input it received when it conducted a public workshop in September 2016, in order to better understand potential barriers that may deter private sector companies from applying for EPIC funding opportunities. The CEC reports that workshop participants, including entrepreneurs and private investors, raised concerns that the EPIC Standard Grant Terms and Conditions provision that allows the CEC and the CPUC to grant IP licenses to LSEs deters EPIC applicants. More specifically, “[i]nvestors are hesitant to fund companies with pre-exiting IP commitments, which prevents companies, especially entrepreneurs and
look forward to additional dialog on this matter in the future rulemaking contemplated in this decision. Flexibility The fifth and final section of Evergreen’s review of the project selection process addressed issues regarding whether the administrators currently have sufficient flexibility to change projects. Currently, the administrators are permitted to add, modify or cancel a project by filing a Tier 3 Advice Letter with the CPUC. This issue was also included within the scope of this proceeding at the request of PG&E, which requested that the Commission consider whether to provide a more streamlined, expedited Tier 2 advice letter approval process for new projects initiated between EPIC plan approvals: As a modification to D.15-09-005, PG&E requests that the Commission re-assess the level of approval process required when proposing project additions to an approved portfolio. PG&E proposes the CPUC revise the requirements to a Tier 2, instead of Tier 3, advice letter, which will still allow adequate time for evaluation of a proposed project based on that project’s merits, while also making the approval process more nimble. This approach helps PG&E and the other IOUs stay current with new RD&D developments and propose projects that meet evolving customer needs and California’s aggressive energy policy goals. SCE joins PG&E in asserting that the current Tier 3 advice letter process for initiating new projects does not provide the utility administrators the flexibility needed to react to new technology, energy policy goals, Commission proceedings, and outside funding opportunities. Like PG&E, SCE recommends the Commission lower the threshold from a Tier 3 to a Tier 2 approval.
Commission how the completed projects will benefit ratepayers. The Scoping Memo determined that the issues raised by ORA should remain in the scope of this proceeding because the planned workshops would provide an opportunity for all stakeholders to resolve their differences on the adequacy of the administrators’ showings. ORA also makes several specific recommendations based on its review of each utility’s plan, stating that the Commission should: Reduce SCE’s 2018-2020 budget because SCE funded a previously authorized EPIC project with GRC funds; Deny SCE’s request to re-litigate the funding of research institutes; Require program administrators to file more detailed plans for Cyber Security for Industrial Control Systems; and Deny the utility administrators' second-life EV batteries program, and require future RD&D applications to be coordinated among the IOUs to sufficiently demonstrate that no duplication of efforts is made. We review each of ORA’s recommendations, and the utilities’ replies, as we consider each utility administrator’s investment plan below. At the outset of our review, we also refer back to the EPIC Evaluation findings and recommendations addressed previously in this decision: the Evaluation found that the utilities, while technically compliant with the letter of program requirements, could better fulfill the spirit of many of those requirements, and should improve several aspects of their program administration practices. Areas needing improvement include metrics tracking and reporting to quantify project benefits, as well as improving stakeholder engagement and transparency throughout the entire investment planning and implementation process. This is why we directed the utilities file a joint
4h) The administrators jointly develop a single EPIC website and listserv to post and distribute project information YES NO YES YES 11.4.4 Project Networks (No Recommendations) II.5 Project Impacts and Policy Alignment 5a) The CPUC consider using our characterization of the EPIC portfolio in terms of the types of technologies and studies and their commercialization status as baselines against which to compare future iterations of EPIC. YES NO NO YES 5b) The CPUC regularly evaluate EPIC to confirm that the CEC is ensuring the Market Facilitation projects are effectively connected to and serving the needs of the Applied R&D and TD&D projects. YES NO NO YES 5c) EPIC administrators establish a process to ensure that once Applied R&D projects are completed by the CEC, the results are considered and potential TD&D projects are identified. YES YES NO YES II.6 Overarching Coordination and Collaboration 6a) The CPUC and/or the administrators fund and convene an independent body to coordinate, facilitate and lend technical expertise. YES NO YES NO 11.7 On-Going Program Evaluation
PG&E 3.31 Real Time DER Rates This project should consider how the results from this project can inform how value is expressed in LNBA -- e.g., can we move to a new modeling platform (beyond a spreadsheet) where locational value is determined way more frequently than annually (near real-time perhaps, and outside of the distribution planning process?) -- as well as exploring how real-time value calculations can translate into DER rates/tariffs under development in IDER PG&E 3.42 (Revised from Project 2.32): Electric Load Management for Ridesharing Electrification This project should also consider how forecasts of DC fast charging EVSE installations can quickly/efficiently get baked into distribution load forecasts, inform the distribution planning process, and drive distribution deferral opportunities through the Distribution Investment Deferral Framework SCE 14 Beyond the Meter Phase 2 According to a data response by SCE, Phase 1 of this project is currently being re-scoped. Due to the additional time needed to complete Phase 1, SCE has stated that it may cancel Beyond the Meter Phase II (on its own). SCE should not continue this project without successfully completing Phase 1. SCE 17 Distributed Plug-in Electric Vehicle Charging Resources SCE should directly coordinate the technical scoping of this project with the other administrators to avoid overlap with their related EV projects. SCE 23 Power System Voltage and Var Control Under High Renewables Penetration ED Staff requests more information on this project before initiation, to provide a better understanding of the specific technologies/use cases to be tested. SCE shall coordinate with ED staff leads for grid integration and modernization to share project scoping information before the project is initiated, as well as after the project is launched.