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
Interconnection Issues
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Fundamental to solar development
Complex web of procedures
Backlog in interconnection queue
Reform at CAISO, PG&E and SCE
Possible Reform of Rule 21
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
The Many Ways to Interconnect in California
• CAISO’s GIP (FERC)
• Utility WDATs (FERC)
– PG&E
– SCE
– SDG&E
• Rule 21 (CPUC)
Three factors determine which
procedure applies:
• Transmission or Distribution
• Location
• Wholesale or Net Metered System?
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
• 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?
• 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
• 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
• 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
• 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
• 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
• 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?
• 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
• CPUC jurisdictional
• Principally used for net metered systems
• Three Components:
– Simplified interconnection
– Supplemental review
– Study process
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
• 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
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SCE and PG&E’s FERC filings
Will SDG&E start reform?
Rule 21 reforms
CAISO has started GIP Reform II
IREC Resources
www.irecusa.org
Sky Stanfield
sstanfield@keyesandfox.com