Anticipated Ruling Presents Critical Opportunity to Improve California Grid Data. Will Regulators Seize It

California is looked to as a leader in clean energy, and rightly so. It is one of the nation's leading producers of renewable energy and has pioneered groundbreaking clean energy and transportation policies. But this leadership is threatened by inaccuracies in key electric grid data published by the state's utilities, which have been ongoing for multiple years.

The California Public Utilities Commission is expected to soon release a Proposed Decision that could remedy these issues, and pave the way for more efficient and affordable clean energy and electric vehicle adoption in the state. If the decision fails to address these issues, it could significantly undercut the feasibility of California's decarbonization goals.

In this article, we explore the nature and history of these grid data issues in California, why they matter, and what can be done to solve the problem.

What's Wrong with California's Public Grid Data?

Thanks in part to over a decade of work by public interest advocates, California utilities have been required to develop some of the nation's best electric grid data transparency tools, called "Integration Capacity Analyses" or ICAs.

An ICA is a model of the electric grid in map form that shows how much electricity generation or demand ("load") can be added in different areas without costly upgrades.

Unfortunately, since they were first published in 2019, numerous issues with the accuracy, completeness, and recency of ICA data published by California's investor-owned utilities (PG&E, SCE, and SDG&E) have been identified. These issues limit the ability of clean energy developers and other stakeholders to use the tool as it is intended.

Why Do ICAs Matter for Clean Energy?

ICAs offer important benefits for the development and siting of clean energy, including:

• Helping developers choose optimal locations for clean energy and EV charging projects where they are less likely to require expensive grid upgrades. (These upgrades can cost tens or hundreds of thousands of dollars and add months or years to the timeline of a project.)
• Providing utilities with valuable data to inform and prioritize infrastructure investments on the electric grid.
• Improving the efficiency of decisions about whether clean energy projects can be approved to connect to the electric grid. (Since 2022, the CPUC has required the utilities to use ICA data in interconnection review processes for certain DERs, taking the place of more time-consuming reviews.)
• Enabling DERs to operate based on an export schedule that supports grid needs and reduces costs. California made clean energy history in March by becoming the first state to enable clean energy systems to propose an operating schedule when applying to connect to the grid. Under this approach, approved projects can connect without requiring grid upgrades that might otherwise be needed, because they restrict power output at times when the grid is constrained in its ability to accept additional electric generation. This saves time and money and allows more clean energy on the grid.

All of these applications are only possible, however, if the data in the ICA is accurate and kept up to date.

What's the History of ICA Data Issues in California?

The Commission first required utilities to develop ICAs in 2015 under a pilot program; it required their full publication in 2019. When the first full ICA maps were released in 2019, IREC discovered serious inaccuracies in the data.

For example, PG&E's map was so inaccurate it indicated that its entire grid was unable to accept any new electricity generation (e.g., solar, etc.) and 30% of its system was not even displayed. SDG&E and SCE's map also had issues. The maps also had questionable data on capacity for new load (such as that needed for electric vehicle charging). Initially, all three utility maps showed zero capacity for new load across the vast majority of their systems, defying common sense.

Since then, numerous other issues have arisen:

• SCE continues to make significant errors that result in delayed or erroneous data;
• SDG&E has repeatedly violated Commission orders by not displaying required data;
• SCE and PG&E continue to not update their maps at the required frequency: when an ICA is out of date, the accuracy of the data it shows cannot be trusted.

While the Commission has slowly required fixes to some of these problems, five years after the ICAs were first released, many of these issues are still ongoing. ICA development is not simple, and a learning curve is expected. But after nearly a decade of work by the utilities and millions of ratepayer dollars spent, it is reasonable to expect that these potentially game-changing tools should be fully functional.

A Critical Moment for Regulatory Enforcement

The Commission is currently working on a draft decision that could require utilities to fix these issues and demonstrate the Commission's commitment to enforcing the ICA requirements it has previously established.

While the exact date this document will released is not yet confirmed, IREC's latest information indicates that it may come as soon as next month. After the release of the Proposed Decision, there will be an opportunity for stakeholder comments before it is voted on by the Commission. It usually takes about two months between a Proposed Decision and a vote, though this timeline could be extended if an alternate Proposed Decision is issued, requiring further comments.

IREC urges the Commission to recognize the seriousness of continued non-compliance by utilities with ICA requirements and commit to resolving them once and for all.

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Delays connecting clean energy to the grid are a leading barrier to clean energy growth. Delays connecting the new loads needed for transportation and building electrification are perhaps even more dire, seriously threatening the state's ability to meet electric vehicle mandates.

Accurate ICAs can accelerate clean energy and EV charger deployment while reducing the need for costly grid upgrades. Without them, California will be hard pressed to meet its clean energy and electrification mandates.