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On March 16, 2012, fourteen parties to the Distribution System Interconnection Settlement Process filed a settlement in CPUC Rulemaking (R.)11-09-011.
The settling parties represent a wide range of interests, including the state’s three Investor-Owned Utilities, IREC and various other renewable energy advocacy groups and organizations, farm associations, environmental groups and others. Considering this diversity of interests, this settlement is a considerable achievement for all those involved.
The centerpiece of the settlement is a significantly reformed CPUC-jurisdictional Rule 21 interconnection tariff. Upon launching the settlement process for Rule 21 in August 2011, the CPUC’s goal was to craft transparent rules that provide a clear, predictable path to interconnection for distributed generation while maintaining the safety and reliability of the electric grid. Following are key provisions highlighting how the proposed reforms seek to accomplish that goal:
A “Fast Track” process is introduced and designed to build on Rule 21’s successful screening process for non-export and net energy metering customers, expanding Fast Track eligibility to exporting generating facilities up to certain size limits.
A national best practice for distributed generation penetration levels is introduced, under which aggregate interconnected generating capacity can be equal to 100% of minimum load on a distribution line section. This provision is the first of its kind in the U.S.
Specific, transparent time frames for each analysis track are proposed, ranging from simplified Fast Track review to the detailed Independent Study Process.
New rules under which distributed generation developers obtain and retain queue position are set out, including publication of an integrated queue by each investor-owned utility for exporting generating facility applicants at the distribution level.
A “Pre-Application Report” is proposed as a first look at a potential point of interconnection, to assist distributed generation developers with early identification of potential technical benefits or challenges of siting decisions.
New dispute resolution mechanisms are introduced that are designed to respond to developers’ needs, including a utility ombudsman authorized to address certain interconnection-related disputes, and expedited handling of timeline-related disputes by the CPUC’s Alternative Dispute Resolution Program.
The settlement is now undergoing Commission consideration within R. 11-09-011. The full settlement is available here: Motion for Approval of Settlement Agreement Revising Distribution Level Interconnection Rules and Regulations, and includes the proposed reforms to Rule 21.

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