CPUC E-5000 Brings Major Changes to Rule 21

On Thursday, July 11, the CPUC approved Resolution E-5000 regarding modifications to CA Rule 21 and the IOU Advice Letters. This order contains five major changes that impact our IEEE 2030.5 CSIP customers:

1. E-5000 extends the date by which inverter-based DER IEEE 2030.5 CSIP (Phase 2 Communications) is required to be certified to be interconnected in the CA IOUs. The date is now March 22, 2020 (UPDATE: The date has now been changed to June 22, 2020).
2. It introduces a new mechanism for listing non-CSIP certified inverters to allow them to be interconnected in the CA IOUs.
3. Provides guidance for the adoption of IEEE 1547.1 certification testing when available.
4. E-5000 changes the dates that Phase 3 functions must be included and certified for interconnection in the CA IOUs.
5. It adds an order to consider Phase 2 Cybersecurity issues.

While the order addresses some realities of the Rule 21 challenges, it is just the next step in an evolutionary process. There are as many unanswered questions as answered ones in the new ruling. QualityLogic’s comments on the E-5000 Resolution were instrumental in shaping the outcome. Here is our analysis as to the meaning of this new order and our recommendations.

August 22 is now January 22*. Will it be delayed again?

The new date is a compromise between the requests by certain parties for a 12-18 month delay (premised on IEEE 1547.1 certification solving all interoperability and functionality issues) and arguments to stay the course with the August 22 deadline.

We are aware of six or more gateway and inverter vendors who are in the process of certification testing with the SunSpec approved labs. However, none have so far completed the process, been awarded a SunSpec certificate, been listed by the CEC, and implemented the PKI infrastructure SunSpec has established. The reality is that at most a handful of vendors would have achieved complete certification and listing by August 22.

The five-month delay is a needed period to bring a critical mass of vendors through the SunSpec CSIP certification process in time for its requirement for interconnection. The initial certification efforts by the labs have provided the required experience to update the test specification, test tools and certification process to address the inevitable growing pains in such a complex process. We are working through these with SunSpec. We expect the process for the balance of the year will provide a more mature IEEE 2030.5 development and SunSpec certification testing process.

One of the key lessons in the experience to date is that adding an IEEE 2030.5 interface to an inverter, gateway, aggregator, DERMS or other product is not trivial and the overall development, testing and certification timeline is months, not days. For those intending to become certified for CA Rule 21 by March 22 (UPDATE: The date has now been changed to June 22, 2020), if you haven’t started the process by now, you may well miss the deadline.

Will the date be delayed a third time? No doubt there will continue to be calls for delay based on the readiness of the IOUs to start using the communications infrastructure being put in place. But the more experience we as an industry have with the CSIP program, the more efficient it will become and the greater the investment will be made. With a growing vested interest in deploying certified products in CA, there will be a point at which the vested interests in getting certified products installed will outweigh the interests in further delays.

We predict that this tipping point will occur during the balance of this year, and we will have achieved a critical mass of certified vendors eager to install advanced, communicating DER systems in CA and elsewhere.

*As we have expected, on December 24, 2019, the California Public Utilities Commission extended the deadline for complying with the CSIP certification requirements to March 22, 2020. This is not a change in policy (products still need to be certified). Rather it is a recognition of the time to complete the complex process of development, testing, certification and CEC listing. (UPDATE: The date has now been changed to June 22, 2020).

What About Non-CSIP Certified Inverters?

One of the compromises in defining the CSIP requirements was that communication from an aggregator or building EMS was out-of-scope and therefore undefined. The CPUC is labeling these two entities as “gateways” even though that is not really a correct term. But we will use the “gateway” term in this discussion.

The revised, final E-5000 order includes a “testing pathway” for non-CSIP inverters proposed by CALSSA. Essentially, the new testing pathway would rely on

“…type testing to allow inverter manufacturers to demonstrate that their products meet the Phase 2 communications requirements via Nationally Recognized Testing Lab (NRTL) testing only…the NRTL would test each model with each compatible gateway and then produce two types of reports: one test report stating that the gateway meets CSIP requirements and one letter that states which inverter models successfully connected to the gateway during testing.”

The plan does not require the lab to verify that the inverter actually performed the required functions but allows the vendor to “attest” to conformance with the functional requirements. But the plan also leaves a number of unanswered questions, including when compliance is required for non-CSIP inverters. It could be argued that the intent is to have non-CSIP inverters tested and listed by the June 22, 2020 date since the description of the testing pathway is to allow “…inverter manufacturers to demonstrate that their products meet the Phase 2 communications…” And the Phase 2 communications requirements are effective on June 22.

But since it is not explicitly stated in the order anywhere, we would expect the date to be clarified in the order for the IOUs to start work with SIWG within 20 days of the order date. The first meeting is already set for August 1 with the agenda to establish:

• the implementation pathway for Phase 3 Functions 2 (DER Disconnect and Reconnect) and 3 (Limit Maximum Active Power);
• the requirements for and identification of a program owner and/or certifying body, unless it is determined that such an entity is unnecessary;
• the division of roles and responsibilities in the execution of the testing pathway;
• outreach to industry;
• development of lists of approved inverters and gateways;
• interconnection portal preparation (as necessary);
• other testing pathway clarifications, as identified throughout the process.

What are the implications of this new “testing pathway”? Based on an assumption that the details will get ironed out and some organization (probably SunSpec) will own this program, our initial conclusions are:

1. For inverter vendors who have decided not to get a SunSpec CSIP IEEE 2030.5 certification, getting listed so that the CA IOUs can interconnect with your inverters should still be a priority. Teaming up with an aggregator or building EMS and going to a lab (either your partner’s certification test lab or yours) and conducting the CALSSA test path would be the most efficient process.
2. For inverter vendors that have achieved SunSpec certification through an adapter device (protocol converter) or by implementing your own cloud-based DER control system for your inverters, no further action seems required. Unless, of course, you also want your inverters separately listed as integrated with other aggregation/EMS platforms.
3. For aggregators, EMS and DER Control systems (microgrid controllers or integrated with an EMS), you may want to consider offering to do the CALSSA testing with one or more of your inverter partners. If they are already integrated and support the Phase 1 and Phase 3 functions, the testing should be minimal (but still requires an NRTL).
4. For test labs, if you are already doing inverter and/or “gateway” certification testing, adding the CALSSA testing pathway should be straightforward.

One concern with the program is what happens when there is actually a need to manage a specific end device? If an inverter is on the list because it demonstrated it can communicate with a specific gateway platform, it is not required to do so when interconnected. It could be one or two years before the IOUs are ready. By then, not only has the firmware probably changed and not been re-tested, the chances that the same gateway platform would be the interface to the grid seems remote. We can envision some sort of IOU communications commissioning process to address this issue.

The adoption of the CALSSA testing pathway is definitely a step forward that provides a mechanism to determine which inverters can be interconnected with the CA IOUs. However, it clearly leaves a number of questions to be answered which the SIWG and IOUs will start tackling August 1.

The Start of an IEEE 1547.1 Mandate

The order starts the process of mandating conformance to IEEE 1547.1/UL 1741 when they are approved and certification is available.

“Following the publication of the IEEE 1547.1 test procedures, PG&E, SCE, and SDG&E are ordered to work with the Smart Inverter Working Group to incorporate the new procedures, as appropriate, into the testing regime for the Phase 2 and 3 requirements. Within 9 months of the publication of IEEE 1547.1, PG&E, SCE, and SDG&E must submit separate Tier 2 Advice Letters (ALs) proposing the new testing regime…”

We’ve highlighted the term “publication” since in IEEE this can be six months or longer after formal approval of the IEEE 1547.1 standard. The current educated guess is that 1547.1 will be approved in early Q1 2020. But actual publication could take until Q2 or even Q3. The good news is that UL plans to start work on an update to UL 1741 as soon as 1547.1 is approved. This means that the testing specification for the IEEE 1547.1. requirements will be completed in parallel with the publication of the standard and testing could theoretically start at that point.

There are two issues to be aware of regarding IEEE 1547.1 in CA. First, the advanced inverter functions in IEEE 1547-2018 do not clearly map to the SIWG Phase 3 functions. This means that the SIWG and CPUC will need to revisit the advanced Phase 3 functions to synchronize them with IEEE 1547. That work has not started.

Secondly, the Phase 3 functions are mandated at different times and in different ways until IEEE 1547.1/UL 1741 are mandated for testing. So some functions in 1547 will already be mandated by the time a formal adoption of IEEE 1547.1 is completed by the CA IOUs. It’s pretty confusing to us and we attempt to sort it out in the next section.

Phase 3 Functions? Which and When

The Resolution addresses two issues: 1) testing of Phase 3 Functions 1 and 8, and 2) testing any other Phase 3 functions.

“The Petition’s request that manufacturer attestations be accepted as sufficient evidence of compliance with Phase 3 Function 1 (Monitor Key Data) is granted. PG&E, SCE, and SDG&E must, until 18 months after the publication of a nationally recognized test procedure containing Phase 3 Function 1, accept manufacturer attestations as sufficient evidence of compliance with Function 1…”

Phase 3, Function 8 (Scheduling) is treated in a similar fashion but the timeline is until “…twelve months after the publication of a nationally recognized test procedure containing Phase 3 Function 8…” The logic in the different timeframes is that Function 1 is included in IEEE 1547 while Function 8 is not. To our knowledge, there is not currently any effort underway to establish a “…nationally recognized test procedure…” for Function 8. So attestation for Function 8 may be operable for some years.

Appendix D in E-5000 includes the following summary table for Phase 3 mandated functions. We’ve added a column in an attempt to map Phase 3 functions to IEEE 1547.1-2018.

Phase 3 Mandated Functions

#	SIWG Function Name (1547 function name)	IEEE 1547.1-2018	UL 1741 SA	E-5000 Order
1	Monitor Key DER Data	6.6 Interop Test	Not included	Jan 22, 2020 (Attest until Nat Std + 18 months)
2	DER Disconnect and Reconnect Command (DER Cease to Energize and Return to Service Command)	Mapping not clear	HECO specific	Jan 22, 2018
3	Limit Maximum Active Power Mode	5.13 (Limit Active Power)	Not included	Jan 22, 2018
4	Set Active Power Mode	5.13 (Limit Active Power)	Not included	12 mos after national test std
5	Frequency-Watt Mode (Frequency Droop)	5.5.1.4 (over voltage trip) and 5.5.2.4 (under voltage trip)	SA14: Defined – Optional	Jan 22, 2020
6	Volt-Watt Mode (Voltage-active Power)	5.14.9 (volt-watt)	SA 15: Defined – Optional	Jan 22, 2020
7	Dynamic Reactive Current Support	Mapping not clear	Not included	12 mos after national test std
8	Schedule power values and modes	Not included	Not included	Jan 22, 2020 (Attest until Nat Std + 12 months)

UL 1741 SA currently provides a test procedure for the Freq-Watt and Volt-Watt functions along with a Hawaiian Electric Disconnect/Connect test included.

It is apparent that some re-thinking of Phase 3 functions will be on the agenda in the next year.

Cybersecurity is a Hot Topic

Interestingly, the draft E-5000 had one mention of cybersecurity while the final order has nine instances and a totally new order:

“PG&E, SCE, and SDG&E shall, within 90 days of the publication of IEEE 1547.1, begin meeting with the SIWG and other interested parties, in order to address cybersecurity concerns raised by the Phase 2 communications requirements and develop a pathway forward.“

The final order does not detail the cybersecurity concerns other than those raised by the IOUs and in comments on the original petition – e.g., QualityLogic pointed out that IEEE 1547.1 testing does not include any cybersecurity testing. In addition, the CALSSA testing pathway does not include cybersecurity testing.

The concerns are 1) how secure is the IEEE 2030.5 protocol used between IOU DERMS and gateways, and 2) how secure are the out-of-scope communications from the gateways to the end devices. This will become an issue in 2020 per the order. So stay tuned.