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Utilities debate redaction approach for substation reverse‑flow limits; stakeholders ask for uniform guidance
Summary
At the CPUC ICA workshop utilities described divergent treatments of substation reverse‑flow ("safety bank") redaction. PG&E said it redacts when a substation fails the '1515 rule' and safety bank is the most limiting hourly constraint; other utilities described different approaches. Stakeholders asked the CPUC to require harmonized documentation and a cross‑utility discussion.
A focal point of the CPUC quarterly ICA workshop was how investor‑owned utilities handle limits tied to substation reverse flow — sometimes called the 'safety bank' constraint — and whether ICA values on public maps should be redacted to prevent disclosure of potentially sensitive customer information.
PG&E told the workshop it redacts ICA static‑grid values when a substation fails the 1515 rule and the safety bank (reverse flow limit) is the most limiting constraint for the hour. "If the bank fails 1515 rule, we would redact ICA safety bank for both feeders," the PG&E presenter said, explaining the utility’s conservative approach to avoid any possibility of reverse engineering customer data.
CE (SCE) and SDG&E described different practices. CE said it does not redact the static‑grid ICA value in the example PG&E showed and that it treats substation reverse‑flow limits as part of thermal evaluations; SDG&E said it redacts differently and offered to follow up by email with precise SME details.
Stakeholders including representatives from the California Public Advocates Office and clean‑energy groups urged the utilities to align methods. "We'd like to have a discussion about what is the way that this should be done ... and then how it's redacted," a stakeholder said, asking the CPUC to schedule a focused cross‑utility session.
Why it matters: Different redaction approaches produce different public map behavior and developer expectations. Over‑redaction reduces ICA usefulness; under‑redaction risks exposing information that could identify customers or reveal sensitive operational constraints.
Requested action and next steps: Utilities agreed to prepare comparative materials showing whether and how they evaluate substation reverse flow, where the calculation appears in technical criteria, how it interacts with the 1515 redaction rule and, if applicable, why a utility does not redact. Stakeholders asked that the discussion be a focused agenda item at the next quarterly workshop and that utilities include written explanations in bianual reports.
Ending: The utilities and stakeholders agreed to follow up. The CPUC workshop record will include a request that each IOU document whether it computes substation reverse flow for ICA, how it models and redacts the results, and how the approach meets privacy and operational requirements.
