On June 20, a California Public Utilities Commissioner issued a scoping memo and ruling setting forth a tentative timeframe for additional steps in a rulemaking to reform CPUC Interconnection Rule 21. Rule 21 governs interconnection by generating facilities to the distribution systems of the three investor-owned utilities in the state. The presently effective Rule 21 was adopted by the Commission approximately 12 years ago and it successfully facilitated the interconnection of tens of thousands of net energy metered and non- exporting generation facilities. The CPUC adopted an Order Instituting Rulemaking for this proceeding on September 22, 2011.
The scoping memo notes that when a generator seeks to primarily offset on-site load, interconnection under the existing Rule 21 generally occurs efficiently. In contrast, generators seeking to export a portion or all of their generation to the utility’s distribution system lack a straightforward means of interconnecting under the presently effective Rule 21. Exporting generators eligible to use Rule 21 as the interconnection tariff include those participating in a number of procurement programs administered by the Commission, including the renewable feed-in tariff, the efficient combined heat and power feed-in tariff, and Qualifying Facilities up to 20 megawatts.
On March 16, 2012, a collaboration of stakeholders sought approval of a settlement by a Motion for Approval of Settlement Agreement Revising Distribution Level Interconnection Rules and Regulations. As described by the motion, the Proposed Settlement represents a major review of Rule 21 and is the result of compromise and agreement among a wide range of industry representatives.
This scoping memo sets forth the timeframe and a number of issues that the Commission needs to consider. The CPUC would like to:
(1) Define the appropriate interconnection study process for all types of generation resources seeking interconnection to the distribution system.
(2) Create distribution-level interconnection procedures for storage technologies.
(3) Evaluate and determine appropriate processes for establishing distribution-level interconnection queues (serial or cluster).
(4) Establish data and reporting requirements.
(5) Evaluate the need to revise technical operating standards due to advances in technology, communications, and the potential need for the system operator to control these systems.
(6) Define distinct engineering methodologies based on the characteristics of the resource, such as the resource’s impact on the transmission system.
(7) Establish a path to resource adequacy qualification for resources that have certain characteristics.
(8) Review and modify, if necessary, the screening mechanism that limits an expedited interconnection to fifteen percent of a line section’s peak load.
The CPUC expects to issue a proposed decision in the third quarter of 2012 and has allowed 24 months for the entire proceeding.