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

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

Complex web of procedures

Backlog in interconnection queue

Reform at CAISO, PG&E and SCE

Possible Reform of Rule 21

Fundamental to participation in the energy market

Utility WDATs (FERC)

PG&E

SCE

SDG&E

Rule 21 (CPUC)

• Transmission or Distribution
• Location
• Wholesale or Net Metered System?

• 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

• 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

• 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

• 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)

• 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

• Higher upfront fees- $50,000 + 1,000/MW
• Financial Security Deposits
• Due after Phase I and incrementally thereafter
• Potentially more equitable overall

• 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

• 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

• 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

• CPUC jurisdictional
• Principally used for net metered systems
• Three Components:
• Simplified interconnection
• Supplemental review
• Study process

• 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

• Issue raised in SB32
• PG&E proposing use of WDAT for all QF interconnections
• Will Rule 21 reform take on the study process?

• SCE and PG&E’s FERC filings
• Will SDG&E start reform?
• Rule 21 reforms
• CAISO has started GIP Reform II

sstanfield@keyesandfox.com

www.irecusa.org