New National Best Practices Set by California’s Rule 21 Revisions

September 20, 2012.  The California Public Utilities Commission (CPUC) last week adopted a substantial revision to Rule 21 (9.13.12), the state interconnection procedures, which establishes several new national best practices, and removes barriers to continued growth of the state’s renewable energy market.

The product of a year-long process, the commission unanimously approved a settlement between the three major investor-owned utilities and 11 other stakeholders, including the Interstate Renewable Energy Council, Inc. (IREC). The settlement puts in place new procedures through changes to Rule 21.

The new Rule 21 adopts a modified screening mechanism that more effectively sorts applicants into a study path that corresponds to the level of review necessary for the project.  The new multi-tiered study process will allow the state to safely and reliably move toward higher penetrations of renewables while still processing applications efficiently.

“This ruling is of national interest,” explains IREC Executive Director Jane Weissman. “Regulatory successes like this in one state provide replicable examples for other states, providing the foundation for a robust clean energy industry in the public’s best interest.”

IREC provided concrete proposals for improvements that were ultimately adopted by the settling parties, as well as insight into best practices across the country. IREC’s attorneys, Kevin Fox and Sky Stanfield, drafted significant portions of the revised tariff language and facilitated communications between the various stakeholder groups, playing a critical role in the settlement’s results.

Specifically, the revised procedures drastically improve the clarity of the Supplemental Review process, by adding precise screens and including concrete timelines for review completion.  The procedures retain the 15 percent of peak load penetration screen in the initial Fast Track review process, but under Supplemental Review the utilities will apply an improved 100 percent of minimum load threshold.  The adoption of this improved penetration based screen is a significant achievement for solar projects because it is more relevant and less conservative than the 15 percent of peak load screen.

The Supplemental Review screen looks at minimum load measured during the daytime when solar systems are actually generating power.  As Sky Stanfield of Keyes, Fox & Wiedman explains, “application of the minimum load screen in Supplemental Review enables the state to continue to process applications quickly, while still providing the utilities with sufficient time to review any safety, reliability and power quality issues that may occur at higher penetrations.”

Responding to applicant concerns about the lack of transparency in the process, the revised rules add clearer timelines, more explanation of the technical standards, and offer a pre-application report that can help applicants screen possible project locations prior to submitting an interconnection request.

The revisions to Rule 21 are also significant for transmission dependent projects that need to be studied in conjunction with projects proceeding under the federally regulated tariffs of the utilities and the California Independent System Operator.  Numerous wholesale distributed generation projects in Southern California Edison’s territory had been stuck in a seemingly never-ending study cycle due to these dependencies. The improved procedures should provide those projects a path forward and reduce the extensive study queues found in some areas.

The modified process adopted in Rule 21 shows a positive evolution in interconnection standards that is responsive to the increased levels of penetration being seen in California, adds Weissman.  “This change builds on enhancements IREC helped to bring forward in Hawaii last year, and IREC hopes to see other high penetration states consider similar improvements in the coming year.”

Source: The Interstate Renewable Energy Council, Inc.

About IREC
The Interstate Renewable Energy Council (IREC) is a non-profit organization accelerating the use of renewable energy since 1982. IREC’s programs and policies lead to easier, more affordable connection to the utility grid; fair credit for renewable energy produced; best practices for states, municipalities, utilities and industry; and quality assessment for the growing clean energy workforce through the credentialing of trainers and training programs.





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