Rule 21: Working Group 2
On July 13, 2017, the Commission issued the Order Instituting this Rulemaking (OIR) in order to consider a variety of refinements to the interconnection of distributed energy resources under Electric Tariff Rule 21 of Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company (the Utilities), and the equivalent tariff rules of the small and multi-jurisdictional electric utilities. Among the principal topics to be considered in the new rulemaking (R.17-07-007) is the incorporation into Rule 21 of the utilities’ Integration Capacity Analysis (ICA) tools, currently under development in the Distribution Resources Plan (DRP) proceeding (R.14-08-013). The ICA tools use power flow analysis to determine the ability of a circuit to host distributed energy resources. Incorporating the ICA tools into Rule 21 may better inform interconnection siting decisions and further streamline the Fast Track process for certain projects. The Scoping Memo directs Working Group Two to develop proposals to address issues related to Integration Capacity Analysis and streamlining interconnection. The working group is to submit a final report no later than September 15, 2018. See the Scoping Memo for the full scoping proposed for Working Group Two. The report shall recommend proposals to address the following issues: 8) How should the Commission incorporate the results of the Integration Capacity Analysis into Rule 21 to inform interconnection siting decisions, streamline the Fast Track process for projects that are proposed below the integration capacity at a particular point on the system, and facilitate interconnection process automation? 9) What conditions of operations should the Commission adopt in interconnection applications and agreements to allow distributed energy resources to perform within existing hosting capacity constraints and avoid triggering upgrades? 10) How can the Commission coordinate the Integration Capacity Analysis and each Utility’s Rule 21 processes with the Rule 2, Rule 15, and Rule 16 processes in order to improve efficiency of the overall interconnection process? This is a coordination issue at this time. However, modifications to Rules 2, 15, or 16 will be addressed if necessary. 11) Should the Commission adopt a notification-based approach in lieu of an interconnection application for non-exporting storage systems that have a negligible impact on the distribution system? If so, what should the approach entail? 6) Should the Commission require the Utilities to develop forms and agreements to allow distributed energy resource aggregators to fulfill Rule 21 requirements related to smart inverters? If yes, what should be included in the forms and agreements? [added via February 14 Email Ruling] Gridworks is the lead Facilitator for this Working Group. For all other information related to R.17-07-007, please visit the CPUC website.