WDT Changes Filed December 3, 2012

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2012 PG&E Wholesale Distribution Tariff (WDT)

Generator Interconnection Procedures (GIP) Changes

Electric Generation Interconnection

William Chung

– Principal

MWCb@pge.com

Definitions

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

WDT Update

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

WDT Changes

– Part 1

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

WDT Changes

– Part 2

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)

Remaining Differences

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).

Appendix

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

Overview of Study Paths

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

Overview of Study Paths

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

Fast Track Review Process and Changes

Characteristic

Size Limit

Eligibility

Studies or Reviews

Initial Fee or

Deposit (actual cost)

IR Timeline

SR Timeline

IR Screens

Rule 21

3MW (or limit export)

Any technology

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)

$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

Additional Changes to Fast Track

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)

Independent Study Process and Changes

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

Cluster Study Process and Changes

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

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