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. The Scoping Memo directs Working Group Three to develop proposals to address eleven issues related to streamlining and improving the interconnection process. The working group is to submit a final report no later than June 14, 2019. See the Scoping Memo for the full scoping proposed for Working Group Three. The report shall recommend proposals to address the following issues:
- Issue 12: How can the Commission improve certainty around timelines for distribution upgrade planning, cost estimation, and construction? Should the Commission consider adopting enforcement measures with respect to these timelines? If so, what should those measures be? Addition: When should the Commission consider results of an initial review or detailed study to be binding? Under what circumstances should the Commission allow the results to be changed?
- Issue 15: Should the Commission require itemized billing for distribution upgrades to enable customer comparison between estimated and billed costs and verification of the accuracy of billed costs?
- Issue 16: Should the Commission encourage third party construction of upgrades to support more timely and cost-effective interconnection, and if so, how?
- Issue 20: How should the Commission coordinate Commission-jurisdictional and Federal Energy Regulatory Commission-jurisdictional interconnection rules for behind-the-meter distributed energy resources, including modification of queuing rules for Rule 21 and Wholesale Distribution Access Tariff (WDAT) projects seeking to interconnect at the same location, clarification of the rules for projects wanting to transfer between the Rule 21 and WDAT queues, and streamlining of the transfer process?
- Issue 22: Should the Commission require the Utilities to make improvements to their interconnection application portals? If yes, what should those improvements be?
- Issue 23: Should the Commission consider issues related to the interconnection of electric vehicles and related charging infrastructure and devices and, if so, how?
- Issue 24: Should the Commission modify the formula for calculating the Cost-of-Ownership charge and, if so, how?
- Issue 27: What should be the operational requirements of smart inverters? What rules and procedures should the Commission adopt for adjusting smart inverter functions via communication controls?
- Issue 28: How should the Commission coordinate with the Integrated Distributed Energy Resource proceeding to ensure operational requirements are aligned with any relevant valuation mechanisms?
- Issue A: What changes are needed to clarify the parameters for approval of system design to achieve non-export and limited export.
- Issue B: How should utilities treat generating capacity for behind the meter paired solar and storage systems that are not certified non-export?
Gridworks is the lead Facilitator for this Working Group. For all other information related to R.17-07-007, please visit the CPUC website.
All Rule 21 Working Group Two documents can be found on Gridworks website here.