Rule 21 Enhances Renewable Energy Distribution in California
By Marsha W. Johnston
September 21, 2012 |
New Hampshire, USA — The California Public Utilities Commission (CPUC) last week handed developers of mid-sized, wholesale renewable energy systems, primarily solar, an important revision to its interconnection procedures, known as Rule 21.
The unanimously approved revision, say stakeholder participants in the year-long process, establishes several new national best practices, and removes barriers to continued growth of the state’s renewable energy market.
The new Rule 21 is, in effect, a settlement between California’s three major investor-owned utilities — Pacific Gas & Electric, Southern California Edison and San Diego Gas & Electric Company — and 11 other stakeholders, including the Clean Coalition and Interstate Renewable Energy Council, Inc. (IREC).
“It is, by far and hands down, the best interconnection tariff in the country,” says IREC attorney Sky Stanfield of Keyes, Fox & Wiedman, who helped draft portions of the revised tariff language with her colleague Kevin Fox. “We made it clearer in almost every way, adding timeframes and explanations of what’s happening. We came to fast track screens, made a more robust Supplemental Review, and it is the first tariff where utilities have accepted 100% minimum load as the standard for determining whether a full study is required.”
Under the previous Rule 21 procedures, Stanfield explains, the utilities made all renewable energy projects that represented 30 percent of the minimum load (or 15% of peak load) in their geographic area go through a full approval process.
Now, she says, projects with a 30% minimum/15% peak load can get Fast Track approval through a quick, initial review. “If they fail the 15 percent screen, they will go to Supplemental Review, which used to be totally unclear,” she continues. “It didn’t explain what it would study or what it would cost. Previously, not a lot of projects could get through that process and there was no pressure on the utility to get projects through Supplemental Review.”
In the new Supplemental Review, projects that are below 100% of minimum load and pass two screens on safety and reliability can still get Fast Track approval, she said. The adoption of the higher penetration screen is significant for solar projects because it is more relevant than the 15 percent of peak load screen. “We were getting more and more systems in California, and many systems were failing the 15% screen, so we had to move the bar up,” she says.
Ted Ko, associate director of stakeholder Clean Coalition, says critically important issues of cost allocation and certainty remain to be resolved, but, acknowledges that it is the best revision possible in the given time frame. “We were pushing to get it done really fast. We did get more transparency, more definition, more timelines, and better clarification of the rules,” he said. One of the most useful wins, he said, is the Pre-Application Report. “Now you can get a report from the utility telling you how much it will cost to plug in to a location before you even apply. It cuts down on the number of non-viable apps the utilities have to deal with,” he said.
Rule 21’s interconnection procedures had become untenable following the passage of two landmark pieces of renewable energy legislation–California Senate Bill 32 on curtailing greenhouse gas emissions and Assembly Bill 1613 on connecting combined heat & power systems to the grid. “The driving reason we had to move forward was SB32, which expands the feed-in tariff program that requires expedited procedures, and no path was available under Rule 21, because they were wholesale systems,” says Stanfield.
Indeed, says Ko, those bills specifically targeted the market for wholesale distributed generation systems trying to connect to the grid and sell to the utilities. “SB32 said that systems up to 3 MW, we have to get them into the grid quickly, not just leave them hanging,” he said. “There has been a spike in interconnections of this type in the last 3-4 years; it has jumped by factor of 10. SCE has hundreds of megawatts of solar waiting to connect.” See the chart below.
Saying it supports the CPUC’s decision, SCE said, “The Rule 21 Settlement will benefit renewable developers and increase the eligibility limit for Fast Track evaluation to 3 MW from 2 MW. The revised tariff should also improve the efficiency of the interconnection process by replacing the one-at-a-time study process with a group study process and by adding deadlines that apply to both generators and SCE.”
Electric Rule 21 is a tariff that describes the interconnection, operating and metering requirements for generation facilities to be connected to a utility’s distribution system, over which the California Public Utilities Commission (CPUC) has jurisdiction. The Rule 21 tariff for each of California’s large investor owned utilities (IOUs) is available on each IOU’s website. Note that the posted Rule 21 may not reflect updates to the tariff that may be pending before the CPUC:
The CPUC’s open interconnection proceeding is R.11-09-011. For information or to discuss a matter related to distribution system interconnection, contact Rachel Peterson, Energy Division, firstname.lastname@example.org or (415) 703-2872.
September 25, 2012: Assigned Commission Phase II Scoping Memo Issued
Assigned Commissioner Michel P. Florio issued a Phase II Scoping Memo in R,11-09-011, setting out the high-priority issues to achieve the Commission’s goal of ensuring a timely, non-discriminatory, cost-effective, and transparent process for interconnection to the utility distribution system.
September 13, 2012: Rule 21 Settlement Approved
In Decision 12-09-018 the Commission approved the full set of reforms to Rule 21 proposed via a multi-party settlement. The Commission anticipates that the significant reforms achieved in Rule 21 will advance the Commission’s goals of ensuring a timely, non-discriminatory, cost-effective, and transparent interconnection process for distributed generation in California.
March 16, 2012: Rule 21 Settlement filed
On March 16, 2012, fourteen parties to the Distribtuion System Interconnection Settlement Process filed a settlement in CPUC Rulemaking (R.)11-09-011.
The settling parties are: Aloha Systems, California Farm Bureau Federation, Center for Energy Efficiency and Renewable Technologies, Clean Coalition, Interstate Renewable Energy Council, Pacifc Gas and Electric Company, San Diego Gas & Electric Company, Sierra Club, solar Energy Industries Association, Southern California Edison, SunEdison, Sunlight Partners, Sustainable Conservation, and Vote Solar Initiative.
The centerpiece of the settlement is significantly reformed CPUC-jursidictional 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.
September 22, 2011: CPUC approves Distribution Interconnection Proceeding
The CPUC approved an OIR (R.11-09-011) to “review the rules and regulations governing interconnecting generation and storage resources to the electric distribution systems of Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), and San Diego Gas & Electric Company (SDG&E).” The OIR is the procedural forum for the Distribution System Interconnection Settlement Process.
August 23, 2011: Distribution System Interconnection Settlement Process
The CPUC launched a multi-party Distribution System Interconnection Settlement Process intended to reach a global settlement on issues regarding distributed generation interconnection to the investor-owned utility distribution system in California. The Settlement Process is subject to confidentiality rules, pursuant to CPUC Rule 12, and FERC Rule 602.
Rule 21 Working Group
The Rule 21 Working Group has served since 2000 as the source of ideas for maintaining and updating technical and other standards within the Rule 21 tariff. The Rule 21 Working Group is not meeting in its usual format while the Distribution System Interconnection Settlement Process is underway. Future public meetings of the Rule 21 Working Group will be noticed in the Commission’s Daily Calendar.
August 2011 Working Group Workshops
- August 19, 2011, 9:00 a.m.-12:00 p.m., CPUC Auditorium: Rule 21 Working Group Workshop. Off-site participation: This workshop will be available via video webcast in real-time and archived. Presentation available here.
- August 19, 2011, 1:00-4:00 p.m., CPUC Courtyard Room: Rule 21 Working Group Technical Subcommittee Meeting. Offsite participation will be available by phone. Phone-in information will be sent only to participants who have completed an rsvp form at the link below. Presentation available here.
- August 23, 2011, 1:00-4:00 p.m., CPUC Courtyard Room: Rule 21 Working Group Business Practices Subcommittee Meeting. Offsite participation will be available by phone. Phone-in information will be sent only to participants who have completed an rsvp form at the link below. Presentation available here.
April 2011 Working Group Workshops
CPUC held a Rule 21 Working Group Workshop Friday, April 29, 2011 at the CPUC Auditorium.
Download a printable agenda here
Workshop presentation materials:
- CPUC’s presentation
- PG&E’s Case Study: Accommodating High Volumes of NEM Interconnection
- SCE’s Case Study: Exporting Generators Under Rule 21
- Download notes from the workshop here
- Download workshop participant comments here
- Download CPUC’s interconnection data request to the IOUs here
- Rule 21 Glossary and Resources
About the Rule 21 Working Group
The intent of the Rule 21 Working Group is to build consensus among the CPUC, IOUs, generators, and advocates for Rule 21 reforms to meet the technical needs and policy goals of interconnecting distributed generation. The Rule 21 Working Group succeeded at this goal in its past work, making California’s Rule 21 a national model tariff establishing metering and operating standards for interconnecting distributed generation resources. Following three years of extensive change in the statutory, technological, and generator context, however, Rule 21 is widely agreed to be in need of reconsideration.
The purpose of this kickoff meeting is to initiate discussion of the issues emerging under Rule 21 that may be hindering the achievement of California’s distributed generation goals. Below are examples of such issues that CPUC has identified:
- Need for transparency in terms of processing, queue information, and customer application information;
- Need for review and potential reconsideration of technical screens within Rule 21 to ensure that the appropriate issues are being studied;
- Need for articulation of cost allocation methodology where network upgrades are required;
- Need for review of utility tariff consistency with each other and with state law;
- Need for additional standard interconnection agreements to accommodate the different types of distributed generation projects anticipated to come online.
June 20 2008: Workshop on Rule 21
On June 20, 2008, the California Public Utilities Commission (CPUC) held a workshop on the topic of the Rule 21 interconnection standard. The primary focus of the workshop was to discuss the transition of Rule 21 oversight from the California Energy Commission (CEC) to the CPUC.
- Post Workshop Comment Request Form – Questions from CPUC
- Post Workshop Comments:
- Utilities panel launches probe of troubled San Onofre nuclear plant (latimesblogs.latimes.com)
- Interconnection Reform Clears the Way for Californians to Go Solar (cleantechies.com)
- Easier Distributed Interconnect Emerges in California (renewableenergyworld.com)
- Will Energy Storage Be Required for Renewable Energy Projects? (sustainablebusiness.com)