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California Interconnection 101 An Update on Reform: What’s Happening and Why it is Important . March 16, 2011 Sky C. Stanfield sstanfield@keyesandfox.com (510) 314-8204. Fundamental to solar development Complex web of procedures Backlog in interconnection queue

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california interconnection 101 an update on reform what s happening and why it is important

California Interconnection 101An Update on Reform: What’s Happening and Why it is Important

March 16, 2011

Sky C. Stanfield

sstanfield@keyesandfox.com

(510) 314-8204

interconnection issues
Fundamental to solar development

Complex web of procedures

Backlog in interconnection queue

Reform at CAISO, PG&E and SCE

Possible Reform of Rule 21

Interconnection Issues
why interconnection matters
Interconnection procedures govern how a solar system gets to connect to the grid so that the energy it produces can be used by others off-site.

Fundamental to participation in the energy market

Why Interconnection Matters
the many ways to interconnect in california
CAISO’s GIP (FERC)

Utility WDATs (FERC)

PG&E

SCE

SDG&E

Rule 21 (CPUC)

The Many Ways to Interconnect in California
three factors determine which procedure applies
Three factors determine which procedure applies:
  • Transmission or Distribution
  • Location
  • Wholesale or Net Metered System?
the jurisdictional debate
The Jurisdictional Debate
  • FERC generally has jurisdiction over interconnection of wholesale systems
  • CPUC has jurisdiction over QF interconnections to a utility distribution system when selling full output to the utility.
    • There is some debate about whether the CPUC has jurisdiction over interconnection of QFs that are not selling their full output to the utility
  • CPUC also has jurisdiction over the connection of net metered systems
    • If AB 920 rate is avoided cost should be CPUC jurisdiction
interconnection pre 2011
Interconnection Pre-2011
  • CAISO and the IOUs previously had two sets of interconnection procedures
    • Larger Generators (LGIP) employing a cluster process
    • Small Generators (SGIP) used a serial study process
  • They are now merging them into one set of procedures, known simply as the GIP
why the need for change
Why the Need for Change?
  • Many more systems trying to interconnect than historically
    • RPS Goals
    • Emphasis on Distributed Generation (RAM, SB 32, IOU PV Programs)
  • Interconnection speculation
  • Lead to a clogged serial study queue
the new gip
The New GIP
  • From serial to clusters
  • CAISO, SCE and PG&E (SDG&E??)
  • Four Processes
    • Cluster Study
    • Independent Study Process (ISP)
    • Fast Track
    • 10kw Inverter Process (not in CAISO)
the cluster study
The Cluster Study
  • Essentially the same at CAISO, PG&E and SCE
  • Any size project
  • One study a year, two application windows
  • Takes minimum of 510 days
    • Does not include time for upgrades
    • Assumes application filed last possible day
  • A two study process- Phase I and II
cluster study costs
Cluster Study Costs
  • Higher upfront fees- $50,000 + 1,000/MW
  • Financial Security Deposits
    • Due after Phase I and incrementally thereafter
  • Potentially more equitable overall
independent study process
Independent Study Process
  • Any size project
  • Can apply at any time- takes ½ a year
  • Same application fees and deposits as the Cluster
  • Must pass “Electrical Independence” Test
  • CAISO Requires a Commercial Operation Date (COD) that cannot be met in the cluster study
fast track
Fast Track
  • Size Restricted
    • CAISO- 5MW
    • PG&E- 5MW (3MW on 21kv, 2MW on 12kv)
    • SCE- 2MW
  • Can apply at any time- takes just over a month
  • Lower fees
  • Must pass 6 to 10 screens
  • Improved by allowing some construction of interconnection facilities
what s the fuss about
What’s the Fuss About?
  • Cluster study takes 18 months
  • Most Wholesale DG Programs require 18 months to COD
  • Limited applicability of expedited processes
  • High upfront costs of participation
  • Variation on key aspects amongst programs
rule 21
Rule 21
  • CPUC jurisdictional
  • Principally used for net metered systems
  • Three Components:
    • Simplified interconnection
    • Supplemental review
    • Study process
rule 21 s limitations
Rule 21’s Limitations
  • No-export screen:
    • Screen 2: Will power be exported across the PCC? If Yes, Generating Facility does not qualify for Simplified Interconnection
  • If screens are failed move to supplemental review and/or full study
  • Full study process has no defined parameters on cost or timing
rule 21 vs wdat
Rule 21 vs. WDAT
  • Issue raised in SB32
  • PG&E proposing use of WDAT for all QF interconnections
  • Will Rule 21 reform take on the study process?
on the radar
On the Radar
  • SCE and PG&E’s FERC filings
  • Will SDG&E start reform?
  • Rule 21 reforms
  • CAISO has started GIP Reform II
irec resources
Sky Stanfield

sstanfield@keyesandfox.com

IREC Resources

www.irecusa.org