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hello everyone and thank you for attending today's webinar confused by rule 21 demystifying the new smart grid requirements I'm Kelsey miss Grenier editor with solar power world before we begin we wanted to let you know about our application widgets at the bottom of our screen you can move and resize them however you'd like slides are available to view at any time via the resource widget submit any questions related to today's webinar via the Q&A widget presenters will answer them after the presentation we encourage you to tweet with us simply sign in through the Twitter box today's hashtag is automatically added to your tweets and finally if you're watching this on demand you can still use all the features I went over let's get started with today's webinar confused by rule 21 demystifying the new smart grid requirements today's speakers are Jon Drummond and Mesa Chef John is an applications engineer at CPS America he's responsible for addressing technical questions related to CPS products ensuring optimized code compliant designs and installations and providing technical training for CPS string inverter products Mesa sharp is a director of global solutions for also energy he coordinates hardware software and service offerings across all regions and now I'll turn it over to John and Mesa Thank You Kelsey hello everyone and thanks for joining today as Kelsey mentioned this presentation will cover and address a face to blue 21 clarification of the obligation and deadlines will cover current state of negotiations by driving policy decisions the forecasted grid requirements and other US markets and the status that be for rule 21 face you compliance solutions from Chen Power Systems and also energy we'll start with some quick introductions before we get into presentation as Kelsey mentioned I'm Jon Drummond application engineer with Chen Power Systems had been involved in the solar PV industry for almost 20 years prior to joining CPS and 2015 my career included roles with other inverter manufacturers hardware design new product development and sustaining engineering activities my role of GPS includes ensuring optimized code compliant designs and installation as well providing technical training for CPS training of our products I also assist our Asia team with the certification process for our ul listed string inverters by staying abreast of the relevant standards and updates and other requirements I attended and participated in many of the swig and council meetings that have led to the Felton a rule 21 update for smart inverters and make sure I'll turn it over to you thanks John yeah so my name is Mesa I've been with also energy for about three years and been in the industry for about 15 years before that I worked in fuel cell so I've been in renewables essentially my whole career excited to be here to chat with you guys about rule 21 at before also energy I worked at advanced energy and PV power where we did provided solar inverters for the industry from residential all the way up through utility scale I was the engineer and then marketing person suppose associated with the communications and telemetry associated with inverters so I'm no stranger to smart grid around distributed energy resources and I look forward to chatting with you today about rule 21 thanks Mason we're happy to have you on before we jump into the details of demystifying the new smartly requirements for the next days a little 21 first like to introduce you to ten power systems GPS is a worldwide inverter manufacturer we do business in several countries around the world for CBS America here in North America we're focused on three face during inverters in the commercial and industrial small utility skate utility scale space we have a market-leading number one share position for CMI applications and we've shipped over three gigawatt of inverters to the US CBS is just a small division of a larger diverse energy company called Ghent group group as a global company it's about eight billion in revenue publicly traded and has been in operation for over 30 years so if you're a customer of ours in this webinar we sure appreciate your business and thanks for attending today if you're new to Chen power systems I would invite you to consider using CPS string inverters for your next project Mesa yeah so also energy also energy has been around since 2007 so a little over ten years we've emerged as the north america leader for CNI monitoring and controls but world we're a global player now with over 30 gigawatts of monitored power worldwide in over 40 countries we have over 200,000 sites spread across residential commercial industrial and utility a number of those sites have controls telemetry and various functions that start to spread into that world of smart grid where you have to wait blow information and energy so with that I think we should get started I want to chat just briefly about the history of also energy and shant working together you know as John mentioned Qin is also a leader in North America around CNI deployments and to that end we have a long working history and we have over almost 20,000 Qin inverters in operation within our platform a number of those installations also are more than just monitoring they have controls ranging from zero net export to maximum export control fault power plant control reactive power control and a host of other applications part of that marriage we have in long working history provides value to the customer both in terms of meeting you know difficult interconnect requirements and meeting technical requirements as well as the value propositions that bull chin and also energy offer independently but it also provides access to chintz engineering organization to access to access their inverters for anything from for more updates diagnostics or to dealing with challenging interconnects so that relationship working together enabled us to provide you with better you through the lifecycle of your project and John yeah if you had another comment yeah thanks me I was going to say that this collaboration in history between also energy and CPS literally spreads over multiple sites and thousands of an cps converters deployed on the also energy platform and as you mentioned the platform enables CPS engineers remote access to many of their assets having a remote access equates to more efficient troubleshooting and a quicker time to issue resolution this collaboration also includes cross-training as you mentioned to both CPS and also energy service and support teams for both inverters and the monitoring solutions so first before we dive in what is rule 21 I'd like to frame the discussion and give you a bit of history in context before we begin the electric rule 21 is not new in California if you interconnect to the grid you're likely already working under the rule 21 interconnect tariff today the rule 21 tariff document issued by the California io u--'s basically describes the interconnection operation and medium requirements for generating facilities that are connected to the distribution and transmission systems of which the California Public Utility Commission for the CPUC has jurisdiction now to back up a bit more there was a committee established in early 2013 called the smart inverter working group or swig that was made up of industry experts including equipment manufacturers and utility engineers that put together over a number of years a set of recommendations to the CPUC to enable grid support features for advanced inverters the sway grew at a collaboration between the CPUC and the CEC California Energy Commission and identified the development of advanced inverter functionality as an important strategy to mitigate the impact of high penetrations of distribution energy resources on the grid those recommendations have now been rolled into rule 21 and we're introduced in phases phase 1 phase 2 and 3 each with separate requirements and mandates deadlines rule 21 today under Section H H for advanced or smart inverters now allows an expansion of the allowable grid-connected conditions that traditionally under the older UL 70 41 and I Triple E 1547 standards were only allowed to operate under a fairly narrow range of voltage and frequency requirements under those older standards all the capability of a grid connected inverter wasn't fully utilized with the introduction of UL 70 41 sa an addendum to the UL 741 safety standard inverters are now listed and certified as grid support utility interactive or smart inverters using the rule 21s Argy requirements rule 21 phase 2 mandate will be a set of communication protocol requirements that essentially enables remote adjustments to the capability to find for the phase 1 autonomous functions for smarter burgers and has been mandated as of September 2017 these new communication requirements will rest on the backbone of this ship and I Triple E 2035 protocol the C sip or the common smart converter profile for California was developed as an outgrowth of the electric rule check ramon smart inverter process to create a common communication profile for inverter communications that could be ride relied upon by all parties and foster essentially a plug-and-play communications as per the recently published resolution a 5000 formal CPC response the council petition for clarification on the rule 21 phase 2 requirements these communication capabilities will soon be required as of January 22nd 2020 by the CPC and enforced by the investor-owned utilities here in California utilities like PG&E SCE San Diego Gas and Electric this communication piece would enhance the level of interoperability between the California utilities and the third-party operated smarter inverters for systems and service providers managing those or East versus the overall intent here is to improve on grid stability and enable better control of energy production assets yes okay so much think about on the fourth bullet thank you so no problem so when you think about it you know utilities have had visibility and ability to manage solar resources and power plants for many years now but we have an increasing amount of distributed generation resources on the grid that are feeding our distribution networks which weren't designed for power plants to be sitting on the distribution network and as we continue to get higher and higher penetration of de our meaning residential and commercial installations primarily they're sitting on rooftops etc utilities have a increasing amount of generation that they have no visibility to and no ability to control rule 21 really filled that gap and provides utilities both visibility and control ability to those resources and while it may seem like a lot of red tape and complication it ultimately is going to be good for the solar industry because it provides an ability to enable a higher level of penetration of the e.r resources on the grid and could have been previously possible without telemetry and communications and you know ultimately oversight to these PV plants on the grid so really rule 21 is focused on the distribution side distribution assets most utility scale power plants data oriented plants have effectively a rule 21 compliant implementation today through large generator interconnect procedures and the requirements that go along with that so I just wanted to briefly talk a little bit about what's affected there so really this is the distribution connected assets John you want to take it from there on the next slide yeah thanks Mesa so again why are we talking about this topic and what are the drivers behind it first when you think of distributed energy resources out on the grid solar system for example when PV systems are connected to the grid an inverter is injecting current against the impedance of the grid and that can sometimes cause issues like voltage rise the brand was not designed to easily accommodate intermittent and by direction energy flows so without proper management distributed resources community can create grid congestion sometimes voltage instability outages and even damage to transmission equipment very congestion can be a significant issue a system operators focus on moving power from areas of Greater supply to those a greater demand those situations can occur for numerous reasons including transmission or generator outages this often needs to be mitigated and managed by the utilities and in fact advanced or smart inverters can be the least costly solution to help solve some of those issues another reason why this is important as potential cascading effects of PV inverters disconnecting from the grid in August of 2016 there was an event called the bloom cut fire that happened in Southern California that was in the SPT se excuse me at te territory where multiple faults happened on a transmission line due to a wildfire this cause of simultaneous disconnect of about 1.2 gigawatts of inverter connected generation as noted by the big dip in the production shown on the graph at about 12 p.m. a nerd field report on this event concluded that loss of inverter power injection was primarily due to a perceived low frequency condition and low voltage blocking and being burgers that's a negative thing that can potentially cause more harm than good and that's exactly the type of thing that the smart inverter working group and rule 21 tried to anticipate with the inclusion of the advanced inverter functions frequency ride-through would have certainly helped in this situation so is in California reaching here with complex regulations I mean California is known to lead the charge with regulations California is also leading the charge with the amount of renewables on the grid today in North America so is this additional red tape and complication or is this going to really turn into something you know I think something to look at when you think about that is what's going on in other markets where there's a high penetration of PV or distributed energy resources and the two markets that come to mind or German in Hawaii there's certainly others Germany has a large amount of PV and in some cases more than 50% of their generation comes from PV on the grid and they run into a number of challenges associated with dealing with the PV on the grid because when you want to turn your lights on the PV you know the Sun may not be shining it's the fundamental issue with intermittent generation and so Germany has developed a number of requirements around managing PPE on the grid to ensure that they can support that large amount of PV and even down to smaller projects like we're talking about here with rule 21 the German grid directive or council requires a level of management of those resources and that's required through various platforms and is in in they have a fair amount of legislation associated with that to ensure that they can manage the PV on the grid Hawaii similarly has a situation where the penetration is high and the grid is small and why he also has been leading the charge with a significant amount of relatively complex requirements to driving PV to be effectively a good steward to the grid so really you know I think rule 21 may make some parts of rule 21 may not be realized it may take longer than we expect for it to become realized but it's coming because renewable portfolio standards and generation that's going in today is primarily renewable so it's not really a question of if it's a question of when and exactly how it's how it gets implemented so we have a fair amount of steam going with rule 21 and we expect that at least some portion of that will get rolled out and utilized on the California grid and likely that will serve as a seed to move across other states in the nation as you start to see pockets of high penetration in other regions this is also part of the larger trend towards the smart grid with 2035 communications I Triple E based on that I Triple E standard 2035 governing other resources on the grid and really tying in to other components like electric vehicles that can provide a huge demand but you can in some cases decide when that demand comes in with 2035 and rule 21 that you're starting to build a platform and framework to enable smarter decisions for when pv runs and when vehicles get charged and how energy flows based on information versus based on when you say plug your vehicle in or or just when the Sun shines so we do see this as an exciting trend towards the smarter grid John do you want to kind of take it from here yeah yeah thanks Mesa has mentioned the rule 21 Shay's won't autonomous functions and even the two additional advanced functions 5 and 6 under phase 3 these are mandatory for smart inverters in California today however Spartan virtus and their capabilities are now or have been required for interconnections and other utility jurisdictions and staged like like Mesa mention Hawaii even Illinois Arizona Oregon and Texas just named a few other states will likely follow suit with smart inverter requirements in the near future does it make sense to do this in foster growth for the smart grid using reliable and sustainable distributed energy resources so how does the smart inverter functions help the grid we mentioned previously at the rule 21 requirements are introduced in phases phases one two and three each with their separate requirement mandate requirements phase one autonomous functions have been a requirement for interconnections with smart Brewers as of September 7 to 20 17 these are set of a automatic functions within D inverter controls like voltage and frequency ride through soft start reconnect ram three fixed or static power factor even dynamic both are volt watt and frequency watt are the to control advanced functions under that I mentioned that are included under the phase three it announced also required as of February this year 2019 each of these functions has a different way to help the grid a connected network of smart inverter serves to support the grid rather than further destabilize it in times of need each of the individual functions provides benefits for different situations as higher penetrations but DRA our systems increasingly impacts traditional distribution operations so these to bring then utility oversight in phase one it's about autonomous controls and capability in Phase two we bring in oversight by bringing communication communications interface between the DTRS to the investor owned utilities that interface for those that want the details runs using I Triple E 2035 protocol with the sun's back common smart inverter profile in terms of the the bits and bytes that are flowing between the utility and the de our resources as John I think mentioned already interconnect applications after the deadline currently set at January 22nd 2020 must note that it that a rule 21 and must know a rule 21 approved inverter at the point of application for interconnection the testing in phase 2 is currently in process so during with phase 2 inverter manufacturers aggregators etc are in process to ensure that they have a rule 21 communications compliant solution and that solution brings a number of functions I'm going to talk about that here on the next slide brings a number of functions to the table that this utility can use and it's important to note that you know if you think about it in January when assuming the date doesn't slip in January excuse me in January is when we will see the requirement for the capability but sites won't go online until sometime after that and really we're talking about future proofing and providing an ability for the utilities to later call on these kinds of functions so how this actually plays out and when actual implementation occurs is still somewhat TBD and we'll have some more details on that later so but fundamentally what the rule 21 phase 2 requires as of the January 22nd 2020 date from a communications and control perspective our functions one through three and function eight a couple of the functions noticed here frequency wat in volt watt are already native within the inverters and then a couple of other functions are on the roadmap but not yet required as a rule 21 deadline so just I want to talk through the functions briefly step one when you start thinking about oversight and managing resources is you need visibility to those resources so function one is just about bringing black box visibility to the e of the de our resources to the utility that might be power production status of the inverters and online or offline and a few other data points like that the second function is around disconnect effectively enabler enabling or disabling the plant again this gives the utility a high you know granular a bit of granularity an ability to enable or disable a plant or a host of plants based on some need we've got an example later in the presentation but that might be you know an emergency type situation it could be a maintenance type situation or other situation that could drive them to want to do that in the third function here with limiting maximum active power that effective effectively allows them to give sort of a soft nameplate or expected maximum power output for an inverter or a group of inverters or sites across say a given region which just provides better determinism in terms of what they can expect from a given resource and so if you expect and say kind of a partly cloudy day and you need to firm that resource up a bit so that you can fill in the gaps more cleanly in energy with other resources you can essentially set a maximum power limit for an inverter or a group of sites the aid function there around setting power modes and values gives the utility and ability to reach in and affect the phase one functions remotely so it can enable or disable various modes and functions as well as effect you know look-up tables around volt watt etc functions like that so that's really what phase two is about and what we're driving towards and John's going to provide a brief overview of phase three which is coming at a later date thanks Misa yeah so under the rule 21 phase 3 requirements they typically function eight utilities may begin issuing scheduling events for active and reactive power values as well as power modes and other system settings like Lisa mentioned functions like limit active power enables an upper limit on active power that an inverter or system of distributed resources can produce or use are limiting the active power this function helps prevent adverse voltage conditions on the distribution grid especially in areas with higher penetration the distributed resources must also report system data to the utility and we know that during operation and inverter for example of many measurements as it converts say DC to AC power inverter or the aggregator in this case and communicates and send us information data such as voltage active and reactive power values back to the utility they are also responsible for daily subscriptions to all clickable utility channels to receive schedules and convinced one thing to notice the 15 minute response time may be required for emergency situations should they arise well with rule 21 what will this mean well with the implementation rule 21 phase 2 what will this mean for assets owners and investors well there's some challenges here yet there's also some positive on the horizon for one there's a possibility to diminish to reduce energy yields as we saw on the previous slides the utility will have the ability to limit the maximum active power that the system can produce and business practices will need to evolve and need to address the situation additionally there may be some higher costs and goals and meeting the communication functionality depending on the equipment and method use on the upside however we know that phase 2 smart grid or communication requirements ultimately drives to allow greater grid penetration for distributed resources it also provides future-proof technology for coming smart grid developments and most importantly though it gives data-driven insights for grid operators to provide proactive grid support you give some greater ability to mitigate and deal with grid congestion by focusing on key areas that might be at higher risk so you know I just wanted to expand briefly on the business practices comment John made you know when you start to think about this again we're talking about future proofing so these things aren't going to happen overnight but as a owner O&M provider installer etc depending on which part of the value chain you're in there's definitely considerations that will need to go into the impacts here because the utility has an ability to affect real power output which is how we all essentially make our money right so some of the considerations that we need to start thinking about it and that others are already thinking about is how does that affect our site Hardware what additional potential costs or challenges what I have in terms of what I put on site to ensure that I'm rule 21 compliant how does that affect my PTA contract and my production guarantee if I'm intelligent provider and I provide some kind of a production guarantee and the iou curtails a given site for a number of days how does that affect my production care guarantee and how do I keep track of that how does that affect terms of service with utility legal responsibilities for utility ours and aggregators and then how does that also eventually affect net metering and insurance terms these are all things that we need to think about as rule 21 begins to gain steam and we start to see actual usage of the control functions thanks Nisa well after you can some of the comic here in these last couple of slides you may be asking yourself why are we doing this and why our rule 21 phase 2 communication requirements important to the solar industry well first this communication education is a next logical step to enable intended functionality for smarten readers with the grid we know that it'll ultimately enhance the grid voltage stability and enable California utilities to continue allowing interconnection for new solar PV development it will also establish communication and control models now for the future in emerging markets across the u.s. we know that this collaborative process of utilities davell and other stakeholders is complicated but it's also necessary to deliver a model that will work for everyone really the bottom line is it might look messy but we as an industry need to go through this process develop a workable template for other industries and future smart career developments so we're gonna spend a few minutes now that just kind of looking at and talking about how do you achieve rule 21 phase 2 compliance and what does that actually look like hopefully through the next series of slides you'll get an idea of what an actual implementation look would look like and it will go from hopefully less move from less move from more abstract to less abstract in terms of what is real 21 phase 2 communications compliant to look like because ultimately it's a fairly complex system and I think there's often a fair amount of mystery around what is compliant system look like and how would that be implemented so to start with oops I grew one too many so to start with there's three basic architectures for rule 21 phase 2 compliance ranging from what I would call sort of the more simplest to the most complex in some ways and of course you know with simplest comes you know trade-offs and most complex comes trade-off so I'm just going to walk through each of all each of them but effectively in the first architecture you have a direct connection between the IOU and a given inverter to this compute single commercial and urban rooftop for instance and the second you have a utility connection to the site and in the third you have a utility connection to an aggregator platform of some kind who operates essentially as a broker to a series or range of sites so I'm going to go into each of those in a little bit of detail here so here in this first slide we're looking at the first two architectures there's a little bit of nuance on the first architect so you can see on the left of the utility communications gateway that might be as the e via their network operations center they've got a communications gateway of some kind that's communicating I Triple E 23.5 with that Sun SPECT common smart inverter profile to the this field and in the first architecture it's communicating directly with the actual de our meeting it's connect it's communicating directly with an inverter this could be the most cost-effective approach for a single inverter system maybe it's a 20 kW commercial rooftop with a single 20 kW string inverter that that utility communications goes directly to that inverter that inverter has certified functionality inside of it in the next case with the SMC you we have a a smart gateway that sits ahead of that inverter and it provides the I Triple E 2035 communications interface to the utility whereas it can be communicating over a unspecified protocol to the actual inverter and provided the inverter meets the functional requirements and can provide all the functions the Gateway needs to be rule 21 certified and the inverter just needs to be rule 21 compliant there's a little bit of nuance there but effectively you have a rule 21 compliance system even though the communications isn't correct with the inverter or de are in the second architecture we have a generating facility EMS you can think of that as an R to you or maybe a power plant controller or some kind of an on-site gateway that's communicating with a host of inverters and providing that rule 21 a triply twenty-thirty top five communications to the utility and translating that back to a host of inverters on a site maybe that's a you know multi-page commercial rooftop or a larger site with may inverters in the third architecture we have the utility communicating with an aggregator platform that could be that could be a platform like also Energy's power track platform or a variety of other platforms there's a number of players in the industry who are developing an aggregator platform in this case the utility communicates over 2035 to the platform and that platform operates as a broker to a host of sites which may have one or more the ER per site so that the er aggregator platform is performing a number of functions and providing utility an aggregate look at a number of sites which in some ways is nice for the utility because they're used to dealing with small numbers of large mega watt sites as opposed to large numbers of small kilowatt sites and so this provides you know almost sort of a virtual power plant view on the assets so just a little bit more on that the aggregator has a number of responsibilities as an aggregator it needs to develop it needs to continuously discover all of the assets working underneath it and needs to obviously fetch relevant info around information about the de our nameplate etc what it needs to activate control within 15 minutes if there's a control command sit down from the utility it needs to report system data needs to redo subscriptions and ensure that its database of compliance sites is current at all times needs to handle error reporting and ensure that it handles any kind of exception clearly and communicate that backup to the utility it also can provide the information to other stakeholders so just diving a little bit more into the aggregator model that aggregator model as I mentioned provides an ability to manage multiple sites simultaneous simultaneously so the utility can interact with a single aggregator and deal with the large number of sites it also provides a flexible option to accommodate a diverse portfolio of hardware assets that may be from various vendors maybe various sizes shapes forms etc maybe small sized large sites etc also provides an ability to group assets and to oversee assets in a wider group and then as standards change and evolve and other requirements evolved you have a central platform that's providing the rule 21 functionality so that central platform can also be updated with relative ease compared to updating a number of field dr assets so just gone just a little bit deeper into the e aggregator model you can see just a little more detail from the earlier slide you can see that utility if say there's a command to disconnect a site the utility communications gateway call it as BG&E or sve would would sent the command over I Triple E 2035 to the aggregator platform that aggregator platform would register that command and determine which site you know decode which site applies etc and it would translate that to whatever native protocol our language is needed to send it on to the site and it would dispatch that command receive status etc format back into the 2035 communications protocol and syntax and status and information back to the utility communications gateway and that all happens automatically and effectively in real time oops three slides so that gives you sort of a better feel for the various models and a little more detail on the aggregator model next we're going to go into a few examples to give you an idea of how the utilities may use rule 21 and what the impact may be and some of the benefits and challenges associated with it yeah thanks me so thanks for the detail on the various models and diving into the aggregator solution yeah let's look at some use case examples here we're faced to communication requirement but not only apply but you'd also see some some effect on they may be something like grid resiliency and support we know that resiliency events can happen as reactions to weather or equipment failures or even even like fires as in the case of a blue cup fire example that we shared earlier for minor voltage and frequency events traditional grid interactive inverters must shut down immediately to prevent an island of power on the grid that could be a safety issue smart and murders of grid support utility rack converters on the other hand can stay active and ride through and actually provide good support to allow false to clear during many voltage and frequency events by providing utility control via the aggregator model solution the supports enables a more efficient communication among regional inverter groups to proactively support the grid in the case of a resiliency event yeah so the classic case when you think about the minimum ante for a site with some level of smart grid communications beyond seeing status the first control thing that comes to mind is the ability to turn a system on or off and what we call that in in this language is a de our distributed energy resource connect or disconnect this has been used routinely and the utility scales data space and then traditional power plants for years this brings that capability down to the distributed resource and when a disconnect is requested by the utility to a site or a host of sites that command would trickle through the system and cause the site or series of sites to be disconnected or turned off this case would typically be used for you know if you have a massive honor over generation situation you may want to send a command to disconnect a host of inverters in a given control area but also more typically it's going to be used for emergency system emergency situations so you have potential runaway situation where you could see a blackout coming the utility has an opportunity to control a large number of resources quickly and immediately turn them off if you have a function your equipment that's communicating but malfunctioning utility can disable that equipment it also you know if you have a fire or another type of an emergency type scenario the utility has yet one more opportunity to disable that inverter and provide cease energy flow and potentially feeding the fire without having to climb up on the roof or wherever you may need to go to disconnect the inverter manually another benefit when you think about this especially in the aggregator model is that this the aggregator platform can provide visibility back to you as a stakeholder maybe you're an owner or a no-name provider can provide visibility back to you if your site was disabled you're wondering why is why is my site not running well it may be a rule 21 event and the aggregator model provides a platform and visibility for you to see whether whether and why your site or sites were disabled due to a rule 21 and another case here which I talked about briefly earlier is the ability to limit maximum active power again this provides establishment of an upper limit on the active power for the inverter so you may have a 30 kW inverter on a rooftop and utility may send a 50% active power limits command say the morning of before sunrise and that inverter would be limited to 15 kilowatts for the rest of the day or until another command is set that gives the the utility both the ability to have more distributed energy resources on the grid as well as provide a deterministic or more deterministic mechanism to manage the de AR resources so because the ER is intermittent and load is not completely predictable you can as you can essentially allow for a much more de R on the grid through a series of management capability that rule 21 unlocks there's there's some flexibility in the implementation of this in terms of percentage based or absolute value based I use the percentage base in that case and it can be used for a wide array of reasons but fundamentally it's really about providing better management of real power on the grid and ability to support a larger percentage of distributed energy resources on the grid if we want a hundred percent renewable penetration in a given area we have to have an ability we have to have more than the area requires and we have to have an ability to manage those resources to effectively provide firm power or power that meets the need of the utility or effectively the load I think John's got one or two more examples here yeah thanks mesa for this next use case let's look at an example for grinch stability we understand that PV and girder current injection can cause voltage rise to the feeder inductance and because renewable energy distributed resources are intermittent power sources we need smart inverter functions to help maintain and provide grid voltage stability if var support is needed smarten birders can provide reactive power support in response to dynamic variations in the grid voltage we know that smart and birders can control both is at the point of interconnection and this is more efficient and cost-effective method than using safety ger plants cap changers or even a capacitor bank for example among a smart intruder functions for grid voltage stability the dynamic volt our function were an inverter would either inject or absorbed VARs in response to grid voltage this function is often a better solution than using say a static power factor or fixed power factor mode this can avoid setpoint mistakes and reduces the need for active monitoring and power factor adjustment over time one thing I do want to emphasize is that for some smart inverter functions this may lead to an active power loss for CTF string inverters are 50 60 or 100 and are 125 kilowatt models have what we refer to as Kea Headroom each of these models have an apparent power rating that's 10 percent higher than their active power this allows these inverter models to provide reactive power or var support up to 0.9 leading or lagging power factor without any reduction in active power output so now that we've explored some of these use cases let's let's transition and look at the CPS also energy solution for rule 21 compliance including the phase 3 advanced functions power systems and also energy are working collaboratively solution for delivering rule 21 phase 2 compliance for our customers and clients think of this is like the list of Breed companies coming together to provide a benefit from our combined IP staff expertise and engineering experience to you the end customer as discussed in the presentation the CES also energy solution will follow the dirt aggregator model as a vehicle for rule 21 phase 2 compliance we are actively working on will 21 phase 2 compliance now and we'll be ready for market and time for the January 22nd 2020 deadline so rest assured if any of your projects will be using TPS Martin burgers will be ready and you'll be able to proceed yes but just one last point here on the previous slide we're working hard to be an agnostic aggregator we're working hard with chance to get this dialed in but obviously we need to work with a variety of dr and approved devices across our platform so we'll continue to provide and build out capability within our platform to provide you to visibility you need to understand the impact once will provide both the solution together with chant forward rule 21 compliance will also provide a range of capabilities and visibility for you to what's occurring once the asset has been deployed to understand the impacts on your production and ultimately your return on your investment so some of the things in power track power track for those who don't know is our flagship monitoring platform pretty you know well is used and been around a long time within North America but also worldwide power track provides you the visibility for sort of analytics portfolio monitoring etc for your assets and with rule 21 with the aggregator functionality we'll bring that ability in for you to tag power losses and various rule 21 related events within the platform you build or receive alert notifications associated with rule 21 events now probably early on you want to subscribe to those alerts but after there's a level of comfort and deployment with rule 21 you probably won't want those nuisance alerts so we'll also be cataloging in our database all of the different events associated with rule 21 so that you can use that to manage performance guarantees and other obligations as well as just in general understand the impact and conduct you know develop and provide reports of rule 20 event impact or tie those into other reports for production or invoicing or any other kinds of business activities and flows that you may have going so John just kind of a quick summary slide here and I think we'll have a few minutes to go into Lucy tonight yeah yeah thanks Mesa well I hate I want to thank everyone again for listening on the webinar niche and I hope that we've kind of painted a clearer picture of you for you by clarifying the new mandates and upcoming deadlines and sharing what's driving the policy decisions and also providing a bit of forecast for smart and Grid requirements across the u.s. we know that the rule 21 phase 2 and phase 3 advanced function mandate deadline is coming we cps together with also energy we're prepared we know if it's not when they stress not if then it's when this requirement will be mandated for all interconnected distributed resources in California starting January 22nd 2020 and it eventually won't just be California but could effectively be required in other states and jurisdictions in the very near future this requirement won't just be for DVRs pvp and PVE inverters if you will it will be for a huge range of smart devices and smart infrastructure once the phase 2 January 2020 deadline hits installers and integrators must choose and select a ceaseth certified smart inverter the CDC or the California energy energy commission will be updating their eligible equipment list on the go solar California site by noting which inverter models meet the phase 2 requirements the io u--'s will then be looking at that list to ensure compliance of the equipment so you want to take a last bullet yeah so just just a reminder that you know this is a evolution here and we're talking about future proofing the assets that are going onto the grid but with that we need to start thinking about the business practices as well that will need to evolve to these changing requirements that could affect overall return on investment and potentially cause some unexpected consequences if we don't have a good understanding of the impact and this ranges from short term sort of the hardware hopper associated with compliance and in longer term that the thinking process associated with the impact of these rule 21 functions begin to actually be utilized raining for PPE contracts production guarantees and all the other things that we've talked about the day so with that I think that's it I'd love to turn it over to Kelsey to walk us through some of the q8 and then I think we'll wrap up okay all right so the first question does my project need to comply with phase 2 requirements if the interconnection application has already been submitted great question maybe I'll take that one the simple answer is no so phase 3 requirements are only coming to effect for submitting applications and for interconnect after the deadline not before the deadline so if you are applying now before the January 22nd deadline you need not have to apply for meet these phase 2 requirements it's only after will will that mandate happen and you're required to use a certified inverter okay so next question how will I know of my system falls under rule 21 Said's two requirements yeah so I can take that there's a number of avenues for those of you that are developing and it has been building projects in California and the various iou territories I know that SD and others are providing they have a mailing list they've got enough wealth of information on their website and they're providing frequent updates I would recommend you get it stay tuned to those services also when you think about the interconnect application many of these you know in this size range will have quick interconnect application processes through the iOS you the only of you is going to walk you through that and alert you through their website of the new and changing requirements associated with rule 21 compliance that January 2020 date may shift slightly and so I would recommend you know one you stay tuned with your the IOUs that you're interacting with and you can also subscribe to the various world rule 21 working groups if you want a deeper level of information about how that how its evolving and certainly also energy enchant will also be staying tuned to that so you can feel free to contact your salesperson or our support team and we can provide up-to-the-minute updates on how the rule 21 process is evolving all right the next question will the utility companies compensate system owners for supplying reactive power and is there any way to compensate for diminished active power generation another good question no there there actually is no plan to provide net metering credits in cases where inverters orders or supplying reactive power we know that increasing reactive power in this case can reduce the maximum output available from the solar inverters utilities generally only pay for real power produce so there again as we mentioned earlier in the webinar there can be revenue losses for PV system owners using inverters that don't have this higher apparent power capability so yeah it's unfortunately not the answer you probably wanted to hear but that's the way it's going to fall all right next question deadlines for rule 21 phase 2 have repeatedly been pushed back there a chance of full implementation may never happen yes so I could take that I think we answered that reasonably well pretty early in the presentation but the chances of no implementation happening I think it's like saying that Solar is going to stop being installed in California to continue to bring solar to California and able more distributed resources on our grid we will need a solution like rule 21 will it be reinvented a few times and change somewhat yeah I think that's possible will it take longer than anybody expects I think most regulatory things do so I think this will be an evolution but we're seeing it already in Germany in Hawaii in a big way and I expect it to also occur in California and to some degree in other states and hopefully California leads the charge in a way that we don't have a unique set of regulations and requirements in each state as they come online so that's part of the beauty of incubating this in California is hopefully other states will follow suit over time all right next question what hardware will be needed on-site in order for a system to meet rule 21 compliance yeah so the answer is a little bit depends based on the architecture whether you choose for the number 1 2 or 3 architecture for your site in the number 1 architecture you may have an inverter that's fully rule 21 phase 2 compliant and they've gone through all the testing process etc and the inverter communicates rule 21 directly that means no additional hardware is required that probably won't work for a site that has many inverters in that case you would have an additional G generating facility ems or r2 you or power plant controller depending on the device that's certified or you would have an aggregator communicating with a gateway of some kind on the site so in general we would expect at least a rule 21 compliant inverter or a rule 21 compliant system via a rule 21 gateway or a general-purpose gateway and a rule 21 aggregator solution which would not be Hardware on site so there's a number of sites in California for instance with also Energy's power track platform where we have compliant Hardware on-site it would be a matter of just providing the aggregator capability so you know we're looking at future-proofing as early as possible as we work through this process thank you and this will probably be our last question can you give a little more explanation for direct inverter communications models allowed under rule 21 what would be the use cases for those models and would developers and owners have any reason to choose those models over the aggregator model sure I can take that so I think direct and vertical when you think about residential which again we may not see application in the residential space immediately but when you think about residential or smaller plants it may be that the most cost-effective solution there is to use a direct inverter communication model and so you'll see that case often it's it's essentially the simplest but it also requires a fair investment to get that capability built right into the inverter and may add to a slight increase in the cost of that inverter system for you know for that type of a model so I would see that most likely used and like I said in small commercial and in residential I think developers and owners are going to need to look at the overall you know what what's the overall makeup of their fleet and do they want to have various models or do they want to see everything feeding into a single platform or do they you know what what are their business needs and then are there any commercial implications associated with the three models I expected over time most larger developers om providers etc are going to end up with a host or a variety of all three models and we'll need to think about interoperability of those models when it comes to monitoring platform reporting looking at events and understanding the impact because there's no standard really that describes how you as a system owner or a O&M provider get visibility to what's happening on the assets and I think there's some opportunity potentially there for innovation but also potentially blind spots thank you that's all the questions we have time for today if you have additional questions or we didn't get to yours please feel free to contact our presenters on your own again this webinar will be shared with all registrants you may view it again at your convenience I'd like to thank John and Mesa again for being here and cps america and also energy for sponsoring today's webinar thank you to everyone in our audience for participating I hope you can we invite you to join us for more solar power world webinars thanks everyone
