3. Preliminary Scoping Memo - Issues

As set forth in Rule 7.1(d), we include a preliminary scoping memo in this Order Instituting Rulemaking. As discussed in the sections below, this preliminary scoping memo is composed of the proposed issues, preliminary determination of category, preliminary determination of need for hearing, and proposed schedule.

The general scope of this proceeding is to consider revisions to PG&E's SCE's, and SDG&E's Electric Tariff Rule 21. A preliminary list of issues is identified below.

Issue 1: Reform Distribution-Level Interconnection Process and Reporting Requirements

Review and revise existing distribution-level interconnection procedures, including, but not limited to, the following:

· Define the appropriate interconnection study process for all types of generation resources seeking interconnection to the distribution system.

· Create distribution-level interconnection procedures for storage technologies.

· Evaluate and determine appropriate processes for establishing distribution-level interconnection queues (serial or cluster).

· Establish data and reporting requirements.

Issue 2: Technology Operating Standards, Standardized Engineering Study Methodology, and Deliverability Study Methodology

Determine appropriate engineering standards and the appropriate path to qualify for resource adequacy, including but not limited to, the following:

· Evaluate the need to revise technical operating standards due to advances in technology, communications, and the potential need for the system operator to control these systems.

· Define distinct engineering methodologies based on the characteristics of the resource, such as the resource's impact on the transmission system.

· Establish a path to resource adequacy qualification for resources that have certain characteristics.

Issue 3: Limits on Distributed Generation Penetration

Review and define limits on the amount of generation that can be safely interconnected to the distribution system without additional engineering study, including, but not limited to, the following:

· Review and modify, if necessary, the screening mechanism that limits an expedited interconnection to fifteen percent of a line section's peak load.

Issue 4: Cost Allocation for Infrastructure Upgrades

Review existing infrastructure upgrade cost-allocation rules including, but not limited to, the following:

· Evaluate mechanisms to improve cost certainty around infrastructure upgrades throughout the interconnection study process.

· Evaluate methodologies to allocate infrastructure upgrade costs between generators and ratepayers.

Issue 5: Procedural Forum for Rule 21 Settlement Efforts

This rulemaking may be used by the Commission as the procedural forum for the recently initiated settlement efforts to address matters related to Rule 21.