CA Rule 21 – Comments on Petition of the CALSSA for Modification of Resolution E-4832 and Resolution E-4898 and Subsequent Responses to Petition – SunSpec Alliance

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Text of Letter:

April 29, 2019

Subject: Comments on Petition of the California Solar & Storage Association for Modification of Resolution E-4832 and Resolution E-4898 and Subsequent Responses to Petition.

With this letter and the attached comments, the SunSpec Alliance (SunSpec) hereby submits its comments regarding the California Solar and Storage Association (CALSSA) petition to the California Public Utilities Commission (Commission) to modify Resolution E-4832 and Resolution E-4898 (Resolutions) and the subsequent responses to the CALSSA petition from others.

Resolution E-4832 approved Advice Letter 3023-E from San Diego Gas & Electric (SDG&E), Advice Letter 3532-E from Southern California Edison (SCE), and Advice Letter 4982-E from Pacific Gas and Electric (PG&E), implementing Phase II smart inverter requirements (Phase II Advice Letters). Resolution E-4898 approved SDG&E Advice Letter 3106-E, SCE Advice Letter 3647-E, and PG&E Advice Letter 5129-E, implementing Phase III smart inverter requirements (Phase III Advice Letters).

Rather than responding on a point-by-point basis to the CALSSA petition and responses from others, SunSpec has taken the opportunity to address the issues raised in the petition by reiterating some of the key details contained in the technical documents governing CA Rule 21, in particular the Common Smart Inverter Profile (“CSIP”) and the IEEE 2030.5 standard.

Respectfully,
Thomas Tansy
Chairman