Electric Generation Interconnection
William Chung – Principal
MWCb@pge.com

FERC Interconnections
• Applies to all voltage levels of interconnection if the generator is selling energy exported to the utility grid
– Except generators under CPUC jurisdiction listed in the CPUC Section below
•
Interconnection is completed pursuant to the following:
– Transmission voltage (60 kV and above): CAISO Tariff
– Distribution voltage (below 60 kV): PG&E Wholesale Distribution Tariff (WDT)
• Rates for any load or standby power are governed by CPUC jurisdictional PG&E tariffs even for FERC jurisdictional interconnection projects (i.e. Standby Tariff)
CPUC Interconnections
• Applies to interconnection if the generator is one of the following:
– Self Generation (all voltage levels):
• Onsite generation that serves on-site or over the fence load only
•
Net-Energy Metering (NEM)
–
Exporting generation (distribution voltage only):
• New Qualifying Facilities (QFs) selling all their exports to the grid to their serving utility under a PURPA
PPA (i.e. Standard Offer, AB1613, SB32)
– New Transmission interconnected QFs will interconnect under the CAISO process
– Grandfathered QFs selling under PURPA PPAs may continue under Rule 21 interconnections at either Distribution or Transmission
•
Interconnection is completed pursuant to Electric Rule 21
•
Rates for any load or standby power is governed by CPUC jurisdictional PG&E tariffs
2

PG&E filed on December 3 rd an amendment to PG&E’s Wholesale Distribution Tariff (WDT). Please see link below for the transmittal and filing.
• Title: Amendment to WD Tariff: Generator Interconnection Procedures
• File Date: 12/3/2012
Docket : ER13-494-000
• Electronic Link: http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20121203-5003
• Amended WDT Effective Date pending FERC approval: 12/4/2012
• Amended WDT Link: http://www.pge.com/wholesale/
• Amended Rule 21 Effective Date: 9/20/2012
• Amended Rule 21 Link: http://www.pge.com/tariffs/tm2/pdf/ELEC_RULES_21.pdf
These changes were made to conform WDT with the amended Rule 21 for Queue generators (Queue generators are exporting generators and Rule 21 non-NEM generators) following these guiding principles:
• Fair and Consistent Queue management
– PG&E’s public Queue contains both WDT and non-NEM Rule 21 interconnection requests and the amended WDT results in an identical procedure to process interconnection requests
• Eliminate policy driven differences between the WDT and Rule 21 except for limited cases such as:
– WDT Fast Track Process is at actual costs vs. Rule 21 which has some fixed fees
• Allow for easy transition between WDT and Rule 21
– Rule 21 is limited to eligible Generating Facilities that enter into PURPA PPAs and as a result, Rule 21 Interconnection Requests should be allowed to transition to WDT if PURPA PPA not obtained
– Allow Rule 21 Interconnection Requests that fail Screens Q & R (a.k.a. Electrical Independence Test) to use the WDT Cluster
Study Process and transition back to Rule 21 post study

The following pages outline the various changes made in PG&E’s WDT Amendment:
General Changes:
• Improved clarity on applicability of the WDT
• Matched application processing fee (previously only study deposits)
• Eliminated 3 out of 6 security posting mechanisms
• Clarified when interest is paid on customer funds for studies/reviews
• Added language in SGIA to state the Network Upgrades shall be refunded pursuant to the CAISO tariff
• Conformed Queue process (did not match Queue posting requirement language)
• Did not add Pre-Application Report and process (The Pre-Application Report is available to all customers)
• Expanded the Annual Deliverability Assessment to allow Rule 21 generators to participate
• Allows Rule 21 generators that fail the Electrical Independence Test to utilize the WDT Cluster Study
Process and opt for a Rule 21 GIA post study
• Allows Rule 21 generators that fail to maintain eligibility to interconnect under Rule 21 to enter the WDT procedures

Fast Track Changes:
• Fast Track Review Process Alignment
– Matched the 20BD timeline for Supplemental Review (from 10BD)
– Matched the process for Initial Review and Supplemental Review Results Meetings
– Added the non-binding cost estimate milestone and timelines
– Eliminated the optional facilities study
– Matched the IA process and timelines
Independent Study Process Changes:
• Matched study deposit structure for projects less than 5MW
– $10k for SIS and $15k for FAS (previously $50k + $1k/MW up to $250k)
• Matched 1st posting deadline of 60CD (previously 30CD)
• Matched the IA process and timelines (can tender IA after Results Meetings if held)
Cluster Study Process Changes:
•
Rule 21 projects may apply for Cluster but opt out of WDT after study
• Study deposit structure remained the same (Currently no Cluster Study Process under Rule 21)

General:
• Rule 21 has a Pre-Application Process. All customers can elect the Rule 21 Pre-Application
Process and submit an interconnection request under Rule 21 or WDT.
• Rule 21 has detailed Queue Posting requirements. PG&E will post the same information for WDT projects.
Fast Track:
• Rule 21 Fast Track is limited to 3MW. WDT has discretionary limits and exceeding these limits will likely result in Fast Track screen failures.
• Rule 21 Fast Track is open to all interconnection requests 3MW or less. WDT is limited to certified generators (however Rule 21 has a screen for certified generators).
• Rule 21 Fast Track includes detailed Supplemental Review process and screens information in the tariff language. As business practice, PG&E will apply the same process and screens for WDT projects as well (100% min load is an example).

• The following slides provide more information on the various changes made to the
WDT
• PG&E is updating the following to address these changes found at www.pge.com/wholesale :
– PG&E’s online application under WDT
– WDT process overviews
– WDT FAQs
• For questions on the WDT changes and how to submit an interconnection request, please contact WholesaleGen@pge.com
.
• Similarly for Rule 21, please contact Rule21Gen@pge.com
.
7

Fast Track Process
•
Screening process to allow for a quick path for proposed generators that do not require detailed study
–
Up to 3MW for Rule 21 (or limit export)
– Up to 5MW for WDT and limited to certified generators
Independent Study Process
• Serial study process for proposed generators that are not in a location common to other interconnection requests under study
Cluster Study Process
• Group study process for proposed generators that are in a location common to other interconnection requests under study

Study Path
Fast Track
Independent
Study Process
Cluster Study
Process
Eligibility Studies Timelines
Rule 21: less than
3MW (or limit export)
WDT : Certified,
Advisory limit of
2MW on 12kV and
3MW on 21kV
Must pass EIT
Rule 21: no size limit but, given current programs, rare to exceed
20MW
WDT: no size limit
Initial Review (IR)
& Supplemental
Review (SR)
System Impact
Study (SIS) &
Facilities Study
(FAS)
IR – 10 BD
SR
– 20 BD
SIS
FAS
– 60 BD
– 60 BD
Rule 21: Go to
WDT
WDT: no size limit
Process Costs Deliverability
Option
$800 Application Fee include IR, $2500 SR fee
Rule 21:
Nonrefundable fee
WDT: Actual cost post study
For 5MW or less: SIS
- $10K deposit and
FAS - $15K deposit
All else: $50K +
$1K/MW up to $250K
Energy Only
Rule 21: Energy
Only
WDT: Energy
Only or Full
Capacity
Phase I Study &
Phase II Study
Phase I – 134 CD
Phase II – 196 CD
$50K + $1K/MW up to $250K
Rule 21: Go to
FERC process
WDT: Energy
Only or Full
Capacity

Characteristic
Size Limit
Rule 21
3MW (or limit export)
Eligibility Any technology
Studies or Reviews Initial Review (IR) & Supplemental
Review (SR)
WDT
5MW (2MW on 12kV, 3MW on
21kV, 5MW on higher voltages
Certified technology
Initial Review (IR) & Supplemental
Review (SR)
Initial Fee or
Deposit (actual cost)
IR Timeline
SR Timeline
IR Screens
$800 App Fee covers IR, $2500 SR
Fee
SET FEE
15 BD
$800 App Fee toward IR, SR
Deposit (amount not specified in tariff)
ACTUAL COSTS
15 BD
20 BD 20 BD
13 Screens 10 Screens
Changes to WDT
No change
No change
Eliminated the Optional
Facilities Study
Add $800 IR deposit and change practice to collect
$2500 for SR
No Change
Change from 10 BD to 20
BD
No Change
SR Screens 3 Screens plus failed screens.
100% min load screen vs. 15% peak load (proxy for 50% min load) failed screens No Change to Tariff but will change practice to evaluate 100% min load

Results Meetings
•
Changed Options Meeting to Optional Initial Review Results Meeting
• Added Optional Supplemental Review Results Meeting
Non-Binding Cost Estimate
• Added a 15 BD non-binding cost estimate process for projects that pass Initial
Review or Supplemental Review but require Interconnection Facilities or minor
Distribution Upgrades
Contract
• Changed process similar to ISP except the 90CD deadline is triggered by issuance of the draft GIA
• Maintained SGIA (Rule 21 has a Fast Track IA but very similar to SGIA)

Characteristic
Size Limit
Eligibility
Studies or Reviews
Rule 21
None (Rare over 20MW)
Any technology
Pass EIT
System Impact Study (SIS) &
Facilities Study (FAS)
WDT
None
Any technology
Pass EIT
System Impact Study (SIS) &
Facilities Study (FAS)
Changes to WDT
No change
No change
No change
Deposit (actual cost) For 5MW or less: $10K for SIS and $15K for FAS
All else, $50K + $1K/MW up to
$250K
For 5MW or less: $10K for SIS and
$15K for FAS
All else, $50K + $1K/MW up to
$250K
Added the 5MW or less difference
SIS Timeline
1 st Posting
FAS Timeline
2 nd Posting
IA timeline
60 BD
60 CD after SIS
60 BD
120 CD after FAS
Tender 30 CD after study or
Results Meeting
Execute by 90 CD after study
60 BD
60 CD after SIS
60 BD
120 CD after FAS
Tender 30 CD after study or
Results Meeting
Execute by 90 CD after study
No Change
Change from 30 CD to 60
CD
No Change
No Change
Change to allow tendering of
IA after results meeting

Characteristic
Size Limit
Eligibility
Studies or Reviews
Deposit (actual cost)
Phase I Timeline
1 st Posting
Phase I Timeline
2 nd Posting
IA timeline
Rule 21
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
WDT
None
Any technology
Phase I and Phase II
$50K + $1K/MW up to $250K
134 CD start June 1
90 CD after Phase I
196 CD start Jan 15
180 CD after FAS
Tender 30 CD after study or Results
Meeting
Execute by 90 CD after study
Changes to WDT
No change
No change
No change
No change
No Change
No Change
No Change
No Change
Change to allow tendering of IA after results meeting