Technical Workshop on Energy Storage Systems Operation and Maintenance Standards

To: Energy Storage Systems Owners (ESSOs), Generating Asset Owners (GAOs) and Rulemaking (R.) 23‑10‑011 and R.20‑05‑003 Service Lists:

The Electric Safety and Reliability Branch (ESRB) of the Safety and Enforcement Division (SED) of the California Public Utilities Commission (CPUC) is planning to hold a technical workshop on Tuesday, March 26, 2024 to discuss the implementation of standards for the maintenance and operation of Energy Storage Systems (ESS), pursuant to Senate Bill (SB) 1383 (Hueso, 2022). 

Instructions on how to attend the workshop virtually are included below:

 

Workshop Details:

Date:

Tuesday, March 26, 2024

Time:

9:30 a.m.

Webex Link:

https://cpuc.webex.com/cpuc/j.php?MTID=m33fb0c573aee109070f3f0fa30c7a426

Webinar Number:

2481 223 8144

Webinar Password:

032024 (032024 from phones and video systems)

Join by Phone:

1-855-282-6330 United States Toll Free

+1-415-655-0002 United States Toll

Access Code:

248 122 38144
        

Workshop Overview 

ESRB is holding a technical workshop to present a walkthrough of the proposed revisions to General Order (GO) 167-B to implement operation and maintenance standards for energy storage systems are required by SB 1383 and answer questions from workshop participants. We ask that participants read through the Staff Proposal beforehand and limit questions during the workshop to clarifying questions in order to allow for sufficient time to present all parts of the proposal. We will post the workshop presentation and materials in advance of the workshop on the Electric Generation Safety and Reliability webpage. 

Workshop Comments 

ESRB invites parties to submit comments on its proposed changes to GO 167-B. Parties’ comments will be posted to the webpage: Electric Generation Safety and Reliability (ca.gov).

In written comments, please provide your suggested edits to staff’s proposed changes to GO 167-B and address the following guiding questions in your response. Any recommended edits or changes to the proposal must be submitted in redline format or track changes. Comments should be emailed to the GO 167 inbox: GO167@cpuc.ca.gov with the subject title “SB 1383 ESS Operation and Maintenance Standards” no later than close of business Tuesday, April 9, 2024.     

Guiding Questions 

The following guiding questions have been developed for your consideration. 

  1. How can the proposed changes to GO 167-B be improved to promote the safety and reliability of Energy Storage Systems (ESSs)?  Are there other rules, codes, standards, and regulations that should be added to SED’s proposed changes to GO 167-B in implementing the requirements of SB 1383? 
  2. Is the term “ESS” sufficiently defined and broad enough to capture all applicable utility-scale energy storage systems including current and emerging technologies? 
    1. What could be added to the proposed definition to make it more consistent with SB 1383? 
    2. Are the megawatt thresholds assigned in the proposed changes to GO 167-B (Large, medium, small) appropriately scaled for ES systems? 
  3. What are the recommended timelines—which can include phased approaches or transition periods—to allow stakeholders sufficient time to comply with the new proposed regulatory requirements of GO 167-B? Please comment on the transition time period needed to implement the proposed Logbook Standards, Operation Standards, Maintenance Standards, Operation and Maintenance Compliance filings, Incident Reporting, and Outage Reporting requirements.
  4. As ESS technology quickly changes and evolves, how can the proposed changes to GO 167-B ensure that ESSs use the best available technologies and controls and that the GO sufficiently accounts for these changes and updates? Is a Best Available Technology standard appropriate to capture future modifications and changes to ESSs’ operations?
  5. What metrics or parameters should be used to monitor and evaluate the performance of ESSs deployed to ensure compliance with proposed changes to GO 167-B? (e.g. Roundtrip efficiency, C-rate, State of Charge or State of Health metrics, charging and discharging status, etc.).  How does the ESSO ensure situational awareness, control, and operational coordination between ESSO and ESS operations, (as well as coordinating with the off-taker)? 

Relevant Links